The Financial Intelligence Agency of Liberia (FIA) has taken robust anti-money laundering and counter-terrorism financing (AML/CFT) action by imposing monetary fines of L$10 million and L$5 million Liberian dollars, respectively, against Oceano Casino and Citi Trust Liberia.
The penalties stem from egregious violations of Liberia's AML/CFT Laws and the significant inherent risk exposure posed by the casino to money laundering and terrorist financing.
According to the FIA, both institutions failed to meet critical AML/CFT requirements as mandated by the country's AML/CFT Act of 2021. These conclusions followed a detailed Risk-based AML/CFT Compliance Inspection conducted by the FIA from October 2, 2024, to March 17, 2025.
For Oceano Casino, the FIA uncovered a series of major violations during its inspection. The casino failed to take appropriate legal steps to identify, assess, and monitor its money laundering risk, including risks associated with pre-existing customers, products, services, geographical locations, and delivery channels.
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This is in breach of Section 15.3.1 and Section 15.3.10 of the AML/CFT Act of 2021. Additionally, the casino failed to establish an independent AML/CFT compliance function, including the absence of a designated compliance officer, which contravenes Section 15.3.12 (1).
The FIA further found that the casino's AML/CFT policies, procedures, and controls were neither risk-based nor adequate to address the institution's money laundering and terrorist financing vulnerabilities. Its policy also failed to align with Section 15.3.12 (2.c) of the AML/CFT Act of 2021, lacking essential provisions for customer screening, especially for politically exposed persons (PEPs), and for conducting risk-based customer due diligence, enhanced due diligence, and ongoing monitoring.
Moreover, Oceano Casino lacked the necessary mechanisms to monitor business relationships and transactions using a risk-based approach and had no system in place to detect or report suspicious transactions.
As a result, the FIA has mandated Oceano Casino's governance structure to develop a comprehensive Action Plan with well-defined timelines and submit it to the FIA by Monday, May 12, 2025.
The casino must also implement all appropriate measures to address the deficiencies identified in the compliance report and mitigate the risks of money laundering, terrorism financing, and the proliferation of weapons of mass destruction by July 9, 2025.
In a related development, the FIA has also imposed a L$5 million fine on Citi Trust Savings and Loans Limited Liberia, Inc. due to inadequate internal controls and serious non-compliance with AML/CFT obligations. These findings followed a full-scope risk-based compliance inspection conducted from December 2, 2024, to March 12, 2025.
The inspection assessed Citi Trust's AML/CFT compliance programs, policies, systems, and controls in accordance with the AML/CFT Act of 2021, along with the Regulation for Microfinance Deposit-Taking Institutions No. CBL/RSD/003/2014, the AML/CFT Regulations for Financial Institutions No. CBL/RSD/002/2017, and Corporate Governance Regulations No. CBL/RSD/001/2012, among others.
Among the violations cited, Citi Trust Liberia failed to properly identify, assess, and monitor money laundering risks, including those related to existing customers, products, services, and geographical footprints.
The FIA noted a lack of board oversight over AML/CFT compliance, in violation of Section 12.0 of the Corporate Governance Regulations. The company's AML/CFT procedure manual was also outdated and not risk-based, with several sections referencing Nigerian financial laws and institutions rather than Liberian ones. This contradicts the requirements of Section 15.3.12(2.c) of the AML/CFT Act.
Furthermore, Citi Trust failed to ensure that its compliance officer was appointed by the board, as stipulated by Section 12 of the Corporate Governance Regulations. The institution lacked a proper risk management framework for conducting risk-based customer due diligence and had no system in place to detect or report suspicious transactions.
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To address these serious shortcomings, the FIA has instructed Citi Trust Liberia's governance structure to submit an Action Plan by Monday, May 12, 2025. The company must fully address all deficiencies and mitigate identified risks by Tuesday, July 1, 2025.
The FIA has directed both institutions to deposit their respective fines--L$10 million for Oceano Casino and L$5 million for Citi Trust--into the Liberian Government escrow account within ten working days, from May 5 to May 16, 2025.
Meanwhile, the FIA has vowed to take further supervisory actions where necessary to ensure both institutions comply with the full range of AML/CFT obligations as mandated by Liberian law.
