Ghana’s battle against corruption is increasingly being undermined not only by
politically exposed persons and criminal networks, but by an uncomfortable truth that receives far less attention: corruption often succeeds because bank officers allow it to succeed.
Across multiple high-profile corruption scandals, money does not simply vanish or appear.
It is deposited, transferred, converted, concealed, and invested — all through
regulated financial institutions.
This reality places banks, and the officers who operate them, at the centre of the corruption ecosystem.
Yet in Ghana, prosecutions overwhelmingly target the beneficiaries of corruption, while the financial gatekeepers who facilitated the transactions frequently escape criminal accountability, despite clear breaches of banking and anti-money-laundering laws.
How the Breaches Occur
Patterns emerging from corruption-related investigations reveal repeated banking
failures:
1. Processing unusually large cash transactions without questioning source of funds.
2. Opening and operating accounts for politically exposed persons without enhanced due diligence.
3. Ignoring red flags such as rapid fund movements, round-tripping, and structured withdrawals.
4. Allowing asset transfers even after investigations or public scrutiny have commenced.
These are not accidental oversights.
They are specific duties imposed by law, entrusted to trained professionals who understand the implications of non-compliance.
Ghana’s Laws Are Clear
Under the Banks and Specialised Deposit-Taking Institutions Act, 2016 (Act 930), banks and their officers are legally bound to conduct business in a safe, sound, and lawful manner.
Officers who engage in unsafe or improper practices may be sanctioned or
prosecuted.
The Anti-Money Laundering Act, 2020 (Act 1044) goes further by criminalising the
facilitation of money laundering.
It imposes strict obligations on bank officers to:
➢ Verify customer identities
➢ Apply enhanced scrutiny to politically exposed persons
➢ Monitor and report suspicious transactions
Failure to report suspicious activity is itself an offence.
The law does not distinguish between the principal offender and the professional who enables the transaction.
Similarly, the Anti-Terrorism Act, 2008 (Act 762) and the Foreign Exchange Act, 2006 (Act 723) impose criminal liability on bank officers who permit illegal fund movements or unauthorised foreign exchange dealings.
Global Precedents: How Other Countries Hold Bankers Accountable
Ghana is not charting unknown territory.
Around the world, bank officers and institutions have been held criminally and financially accountable for facilitating corruption and illicit financial flows.
HSBC (United Kingdom / United States)
HSBC admitted to massive failures in its anti-money-laundering controls, which
allowed Mexican drug cartels and other criminal networks to launder billions of dollars through the bank.
The case established that ignoring red flags and weak internal controls constitutes criminal conduct, not mere compliance failure.
The bank paid record fines, and senior compliance failures were publicly exposed.
Danske Bank (Denmark / Estonia)
In one of the largest money-laundering scandals in history, over €200 billion in
suspicious transactions flowed through Danske Bank’s Estonian branch.
Investigations revealed that bank officers ignored obvious warning signs and failed to report suspicious transactions.
The fallout included criminal investigations, resignations of top executives, and severe regulatory penalties.
Several jurisdictions treated the case as a
crime facilitated by banking professionals, not merely customer misconduct.
Wells Fargo (United States)
While different in nature, the Wells Fargo scandal demonstrated how institutional pressure and internal misconduct by bank officers led to systemic abuse.
Thousands of employees were sanctioned, and senior executives were personally penalised.
The case reinforced the principle that individual accountability is essential to restoring trust in the banking system.
Credit Suisse (Switzerland)
Credit Suisse was implicated in multiple corruption and money-laundering cases
involving politically exposed persons from different countries.
Investigations showed failures in enhanced due diligence and transaction monitoring.
The bank faced criminal convictions and regulatory sanctions, reinforcing the international standard that banks must not be safe havens for illicit wealth.
Standard Chartered (United Kingdom / United States)
The bank was penalised for facilitating illegal transactions linked to sanctioned entities.
Authorities held that knowingly or recklessly processing prohibited transactions
amounted to criminal conduct by financial institutions and responsible officers.
The Lesson for Ghana
These global precedents establish a simple but powerful principle: financial crime is rarely possible without professional enablers inside banks.
In jurisdictions where corruption is aggressively prosecuted, enforcement agencies do not stop at tracing stolen funds.
They ask harder questions:
1. Who approved the transaction?
2. Who ignored the red flags?
3. Who failed to report suspicious activity?
4. Who benefited from silence?
5. Where answers point to bank officers, prosecutions follow.
Why Ghana must act now
1. Deterrence: Without real consequences, compliance becomes paperwork. Prosecuting complicit bank officers will force strict adherence to AML and banking laws.
2. Economic Protection: Illicit financial flows weaken the cedi, deplete foreign reserves, and distort national accounts. Banks that facilitate corruption undermine macroeconomic stability.
3. Public Trust: Ordinary Ghanaians face rigorous scrutiny for modest transactions, while powerful actors move millions unchecked. This double standard is eroding trust in the banking
system.
4. Alignment with International Standards: Ghana risks reputational damage and increased scrutiny under global AML frameworks if it fails to enforce individual accountability within banks.
Why Prosecuting Bank Officers Is Not Optional
1. Legal Obligation, Not Policy Choice: Ghana’s laws already criminalise facilitation. Failure to prosecute is an enforcement failure, not a legal gap.
2. Ending the “Middleman Immunity” Culture: As long as bankers believe they are untouchable, corruption will continue to flow smoothly through the system.
3. Protecting Ghana’s International Reputation: Weak enforcement exposes Ghana to reputational risk under global AML and FATF frameworks, potentially increasing scrutiny of Ghanaian banks abroad.
4. Restoring Public Trust: Ordinary citizens face intense scrutiny for modest transactions, while powerful individuals move millions unchecked.
This imbalance undermines confidence in the financial system.
Conclusion: The Gatekeepers Must Answer
Global precedents show that bank officers are prosecuted when they enable crime.
Ghana’s own cases show that corruption repeatedly passes through banks without
consequence for those who open the gate.
Until Ghana begins prosecuting complicit bank officers alongside corrupt officials and businesspersons, corruption will continue to find safe passage through the financial system.
The message must be unambiguous; Banking expertise does not confer immunity.