The Gambia - Threat Assessment - 2020 Page of 1 30

The Gambia 🇬🇲

Executive Summary

Grey Lists: The Gambia is not listed by the US as a Country of Primary Concern in respect of ML & FC, or listed by FATF, and the EU on their “Grey” lists.

NRA: The Gambia has not yet published a National Risk Assessment, though this is expected in 2020, with Banks & other financial services as well as DNFBP’s identified to be the main sectors that are vulnerable to laundering the proceeds of crime.

Organised Crime Index: Low Criminality - Low Resilience with a score of 4.61, ranked 39/54 Africa and 5/15 W Africa, ranked 11/15 W African Countries for resilience, (response). The main markets, according to the OCI, with highest criminality scores are Illegal Logging & Human Trafficking (7/10), Illegal Drugs Cannabis (6/10), Cocaine (6/10), Heroin (5/) and Synthetic Drugs (2.5/), Human Smuggling (4.5/10). On Groups, State enabled actors (7/10) received the highest score, followed by Criminal networks (6.5/10).

Corruption: TI CPI - 2019 - ranked 96/198, with a score of 37/100 in 2020, a score below 50 is indicative of a country struggling with corruption issues. The 2018 TRACE Bribery Risk Matrix - “high” ranked 143/200 with a score of 61/100. PWC’s Global Economic Crime & Fraud Survey 2018 gave the Gambia a 31% incidence rate for Bribery and Corruption.

Modern Slavery: US Trafficking in Persons: Tier 2 Watchlist country; Global Slavery Index: 33/51 African Countries, 11,000 modern day slaves, incidence of 5.8/1000 people. The Gambia has a GSI rating of “CCC” in response.

Sanctions & Terrorism: No Comprehensive Sanctions against the Country, Tier 3 PPI (Proliferation) Index with a score of 283/1300 (low controls score), GTI - 138/138 - Terrorism poses no threat (Score 0/10,000).

Response & Resilience: FATF - The Gambia was evaluated in April 2008 and is subject to another evaluation in 2021, reporting in 2022. The Gambia scores 4.63/10 for resilience, ranked 17/54 Africa and 5/15 for Western Africa in the OC Index, with ratings for AML of (5/10) & Economic Regulatory Environment (5/10), Law Enforcement (5/10) & International Co operation (4/10).

Indices: Freedom House 2019 - score 46/100, “partly free”, 54.9/100 in Mo Ibrahim Index of African Governance, and rated “Increasing Improvement", Basel AML score in 2019 is 5/10 ranked 71 from 129 countries, an improvement from 2017 (6.7/10).

Overall FCN Ratings: The Gambia is rated overall “Moderate” Risk, 4th out of 14 Western African Countries and 13 out of 40 with FCN’s Overall Risk score of 49/100, and with an “Improving” tend.

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FCN Rating:“Mod-High ” Risk 49/100 Trend “Improving”

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Score: 49/100 “Mod-High” FCN Risk Rating (Average Country Score is 32 - SSA )

Rank: 13/40 SSA - 4/14 Region WA Proceeds / Laundering

range 7.5% - 10.5% GDP / 40 - 50% of Proceeds

Costs of Corruption range up to approx 10 - 15% of Proceeds

Organised Crime range up to approx 24 - 26% of Proceeds

(State Enabled 7/10, Criminal Networks 6.5/10, Foreign Actos 2/10, Mafia Style 1/10)

The Gambia ↗ Improving Population: 2.2 million Capital: Banjul President: Adama Barrow (since January, 2017) GDP: US$1.6 billion (0.1% of SSA GDP) Economic Sector Breakdown: Agriculture (20%), Industry (14%), Services (66%) Exports: US$72.9 million: Peanut products, fish, cotton lint, palm kernels to Guinea-Bissau (52%), Vietnam (15%), Senegal (9%), Mali, (7%) - 2017 Imports: US$37.7 million Foodstuffs, manufactured goods, fuel, machinery and transport equipment from the Ivory Coast (11.5%), Brazil (11%), Spain (10%), China (8%), Russia (6%), Netherlands (5%), India (5%) - 2017

Total Criminal Proceeds in Sub Saharan Africa in US$ Billions - FCN

2020 (not including fraud and corruption and tax evasion)

Mining10

Wildlife2

Logging12.5

Theft15

Drugs3

Modern Slavery8.3

Goods Piracy9

Fishing2.5

FCN SSA Country Risk Rating - “Low - Mod” Response - "

GovFree GSI

BaselOCI PPI

Seizures US$NRA

FATF/EU ListsFATF 40

FATF 11Overall

FCN SSA Country Risk Rating - “Moderate” Threats - "

INCSRWEF OC

US Terror GTITI CPI GSI

US TIP

IUUF Index

US END Wildlife

OC IndexGFI IFF’s

Overall

The Gambia Higher (Inherent) Risk Factors

Customer Risks

Sector Risks

Geography Risks

Customers with elevated exposures to: Criminal

activities such as: illegal logging, fishing, drug & human trafficking, with corruption (e.g PEP’s)

which also helps facilitate these crimes & tax

evasion as a high risk concern also & to Higher

Risk Sectors and/or Geography Risks

Banks (in particular Retail and Correspondent

Banks)

Other FI’s such as Bureau de-Change, MSB’s MMO’s

Gambling Operations

DNFBP’s, in particular, precious metals and

stones dealers, lawyers, notaries and micro finance

Informal Sectors

Country Neighbours; Major Export / Import

Partner Countries (Trade Mispricing and IFF’s)

Senegal, Guinea Bissau (Timber/Fish)

Major Export / Import Partner Countries (Trade

Mispricing and IFF’s)

Third Countries China (Timber/Fish)

Brazil, S America (Cocaine)

Section 2 - Country Dashboard

Section 3 - Country Information

People & Geography: The Gambia is a country in Western Africa that is almost entirely surrounded by Senegal with the exception of its western coastline along the Atlantic Ocean. It is the smallest country within mainland Africa. The Gambia is situated on both sides of the Gambia River, which flows through the centre of The Gambia into the Atlantic Ocean. It has a population of 2.2 million people, most living outside Banjul, the Gambian capital, which has just over 30,000 people, whereas, Brikama, has around 700,000 people, and Kanifing, almost 400,000 inhabitants. For Migration immigration was at 215,400 & emigration at 118,500 in 2019 . 1

Recent History & Leadership: The Gambia gained independence from the UK in 1965, under the leadership of Dawda Jawara, who ruled until Yahya Jammeh seized power in a bloodless 1994 coup, ruling a corrupt government for 23 years. Adama Barrow became The Gambia's third President in January 2017, after winning elections, against Jammeh who initially accepted the results, then refused to accept them, which triggered a constitutional crisis and military intervention by the Economic Community of West African States, resulting in his exile.

Economy & Trade: The Gambia's economy is dominated by agriculture, fishing & tourism. Banjul is a regional entry point, where merchandise can be imported and exported without paying import duties. As a result, Gambia re-exports constitute over 80% of the country’s total exports. Gambia’s main exports are: peanuts, fish and cotton. Gambia main export partners are Senegal and Guinea followed by the UK and China. Others include: Guinea-Bissau, Ghana and India. Gambian agriculture is generally characterised by basic farming of food crops, for example cereals

(millet, maize, sorghum, rice), groundnut, cotton, sesame and horticulture. The crops sub-sector generates approximately 40% of the foreign exchange earnings and provides about 75% of total household income. The crop-sub-sector employs 70% of the labour force, and accounts for about 30% of GDP of the country. Livestock production in the Gambia is still predominantly traditional, with a livestock population estimated at around 300,000 cattle, mainly sheep and goats, as well as poultry. The fisheries sub-sector is both industrial and artisanal, with the latter accounting for about two thirds of the total catch. Marine fish resources are enhanced by the freshwater flows of the River Gambia . 2

Environment: The Gambia was ranked 156/180 and scored 42.42/100 in the 2018 Environmental Performance Index . 3

Tourism: The Gambia's location on the ocean and proximity to Europe has made it one of the most frequented tourist destinations in West Africa, accounting for more than 20% of GDP, with 162,000 tourists in 2017, largely from European Countries . 4

Finance: The Gambia’s financial profi le is 5

underdeveloped and has limited financial products. The banking penetration rate is approximately 25% for the urban population and 5% for the rural areas. The sector comprises 12 banks, 1 of which is an Islamic bank – mainly concentrated in the greater Banjul area. The 11 conventional banks are mostly foreign-owned. Four large banks control 68% of the industry’s total assets, indicating high concentration in the banking sector. Remittance inflows are crucial to The 6

Gambia amount to about 22% of the country’s GDP in 2016 , with Gambian migrants 7

remitting US$181 million.

The Gambia - Threat Assessment - 2020 Page of 4 30

Section 4 - Country Ratings & Country Risk Heat Map

Source Gambia 🇬🇲 Source Gambia 🇬🇲 Source Gambia 🇬🇲

World Economic Forum Organised Crime Index

68.9 / 100 Transparency International (TI) Corruption Perceptions Index

37/100 (96/198)

Proliferation Index - PPI Threat

Tier 3 Lowest Threat Level

OC Index Criminaility

4.62 TI & Afrobarometer Citizens Views and Experiences of Corruption

Report

21% Overall Bribery Rate

Proliferation Index - PPI Controls

283 / 1300 Low Controls score

OC Index Criminal Actors

4.13/10 TRACE Bribery Risk Matrix

59/100 Rated 137/200

Global Terrorism Index GTI - Impact

0 “Zero” Impact

OC Index State Embedded Actors

7/10 Global Slavery Index GSI Incidence

5.8/1,000 Incidence

US Dept of State Country Reports on Terrorism

No

OC Index Criminal Networks

6.5/10 Global Slavery Index No of estimated Modern Day Slaves

11,000 Estimated numbers of modern day

slaves

Global Cybersecurity Index 2018

0.280 (104/ 175)

OC Index Foreign Actors

2/10 Global Slavery Index Country Response Rating

“CCC” Rating Mo Ibrahim Governance Index (49.9 - All Africa)

54.9/100 “Increasing Improvement”

OC Index Mafia Style Gangs

1/10 US Dept of Labor Child Labour

N/A Freedom House Freedom Index

46/100 “partly free”

OC Index Drugs Trafficking

Cannabis & Cocaine 6/10, Heroin 5/10 - Synthetic’s 2.5/10

US Dept of State Trafficking in Persons

Tier 2 Watchlist Rated (2020)

Heritage Foundation Economic Freedom Index

56.3/100 “Mostly Unfree”

OC Index Arms Trafficking

4/10 IOM Migration E - Emigration / I - Immigration

I- 215,400/E- 118,500 Basel AML Index 5/10 71st out of 129 Countries

OC Index People Smuggling

4.5/10 Illegal Unreported and Unregulated (IUU) - IUU Fishing Index

2.23 FIU Egmont Member

No

OC Index Human Trafficking

7/10 EU Listing of Countries for Illegal Fishing

No Interpol Member

Yes

OC Index Illegal Timber

7/10 US DoS - Wildlife Trafficking Focus / Countries of Concern

Not Included Asset Confiscations over 1% of Proceeds

No

OC Index Illegal Wildlife

4/10 Environment Performance Index 42.42/100 156/180

Country National Risk Assessment

No

OC Index Illegal Mining

5/10 EUIPO & OECD Counterfeit Goods Propensity of Exports

0.335 (2016)

Financial Information Sharing Partnership

No

OC Index Resilience

4.63/10 Tax Justice Network Financial Secrecy Index

75 High Risk

US Dept of State INCSR Vol I & Vol II

Not Listed

OC Index AML

5/10 EU List of None Co operative Jurisdictions for Tax purposes

Not Included European Union List No

OC Index Law Enforcement

5/10 OECD - Global Forum on Transparency & Exchange Info for Tax Purposes

Not Included FATF Standards 40 Recommendations

71% FUR 2019

OC Index International Co- operation

4/10 Global Financial Integrity Illicit Financial Flows

US$41 million - 36.69% (2017) FATF Standards 11 IO’s on Effectiveness

6% Report 2015

OC Index Economic Regulatory Environment

5/10 Embassy’s from N Korea, Syria, Iran or Cuba

Cuba FATF Standards Core 10 Recommendations

70% FUR 2019

Illegal Drug Dependency / Disorders Number/Share

9,680 0.5%

Embargoes - Country Sanctions (Comprehensive - UN, US, EU, UK)

None FATF Standards Core 4 IO’s on Effectiveness

0% Report 2015

Numbeo Crime Survey 2020 Not Included OFAC Listed Parties with Local Addresses

18 FATF Counter - Measures

Strategic Deficiencies ListNo

FCN Final Ratings - The Gambia 🇬🇲 Financial Crime News

Threat Rating 59/100

“Moderate” ThreatFinancial Crime News Financial Crime Rating

49/100 “Mod - High” Risk 13/40 SSA - 4/14 WA

Financial Crime News Response Rating

39/100 “Low - Moderate” Response

Trend (TI CPI, Mo Ibrahim, FATF, Basel Index & GTI - 3-5 years)

Improving

For more details on the scoring model for FCN Ratings contact the Editor FCN directly for access to the Methodology

The Gambia - Threat Assessment - 2020 Page of 5 30

Section 4 Continued - Country Threats Heat Map

There are many threats that effect The Gambia, which are in most part targeted towards its resources, it’s trading status and its port as well as its natural resources, the people, it’s forests, crops and fish. The effect of past endemic corruption had increased the threats and reduced the ability to effectively respond. For more details in summary form see the figure below.

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Section 5 - Key Threats

In this Section 5, the most important criminal markets, are assessed and summarised based on available sources.

5.1 National Risk Assessment (NRA): The Gambia has not yet published a National Risk Assessment, though the first assessment has been largely completed and is expected in 2020.

The NRA is expected to identify illegal logging by facilitating cross border illegal exports from Senegal, drug trafficking, including of Cocaine and Cannabis as the most important and the highest risks affecting the Gambia along with Corruption which also helps facilitate these crimes and Tax evasion as a high risk concern also.

It is expected that the NRA, is likely to consider theft, stolen goods and smuggling as a “Medium High” money laundering threat which includes, theft and goods smuggling across borders mainly to evade taxes. Crimes considered as “Medium” money laundering threats include: armed robbery, counterfeiting of banknotes and imported pirated goods, (which has resulted in the establishment of an Anti-Intellectual Property Crime Unit), banking fraud, human trafficking, people smuggling, other environmental crimes, and other activities from organised crime including racketeering.

It is expected that Banks and other financial services as well as DNFBP’s have been identified to be the main sectors that are vulnerable to laundering the proceeds of crime.

5.2 US INCSR: The Gambia is not listed as one of 80 Countries categorised by the US State Department as a Country of Primary Concern in respect of Money Laundering and Financial Crimes

in their International Narcotics Control Strategy Report 2019 (INCSR) . 8

Gambia not listed US INCSR 2019

The Gambia was though a ‘Monitored’ Jurisdiction in the 2016 INCSR Report , which stated that; “The 9

Gambia is a regional re-export centre....most transactions conducted in cash....smuggling of goods occurs..... it is unclear to what extent money laundering is related to narcotics, but seizures of large amounts of cocaine and marijuana two years ago heightened concerns regarding links to international drug trafficking....problems of persistently weak bank controls and supervision, the dominance of cash transactions, a poor know-your-customer compliance culture, and significant inflows of tourists.”

5.3 Corruption: Corruption is not only a significant generator of illicit funds, but it is also an enabler of other serious crimes and protects those involved from investigation, prosecution and or conviction.

Transparency International’s (TI) Corruption Perceptions Index (CPI) 2019 scored Gambia 10

37/100 and ranked 96/198 of all Countries listed, no change from 2018 but an increase from 30/100 in 2015, and a then ranking of 130 (score are from zero (highly corrupt) to 100 (very clean).

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TI - CPI Scores (out of 100) - 🇬🇲 (higher scores are better)

2010 2013 2016 2019

37.0

26.028.032.0

37/100 (corrupt”) ranked 96/198, up from 30/100 and ranked 130th in 2015

TI CPI 2019

The 2018 TRACE Bribery Risk Matrix places the Gambia in the high risk category, ranking it 143 out of 200 surveyed countries, with a risk score of 61/100 . 11

The improvements in The Gambia’s corruption ratings, whilst still being high, are mainly due to the ousting of the former President Yahya Jammeh (from 1994 to 2016) and the new Governments action, under President Barrow who has stated his intention to rid the country of pervasive corruption and a culture of impunity.

According to the Organized Crime and Corruption Project (OCCRP) former President Jammeh, who was ousted at the end of 2016, was responsible for the theft of up to US$1billion of state assets, 12

through his tenure, through embezzling public funds and illegal timber revenue, controlling the cross border illegal Senegalese timber trade to Asia, through the Gambia.

According to TI , “despite promising 13

improvements in international governance indices, it remains too early to tell if the new government will succeed in its efforts to curb widespread corruption.” Indices including TI’s own CPI do show improvements , for example: 14

• the Gambia’s percentile rank for control of corruption in the Worldwide Governance Indicators (WGI) shows a marked improvement in 2017 to 27.4, after a period of steady decline from 2012 (30.3) to 2016 (21.6) (World Bank 2018)

• the 2018 TRACE Bribery Risk Matrix places the Gambia in the high risk category, ranking it 143

out of 200 surveyed countries, with a risk score of 61/100.

• the Gambia's Doing Business rank for 2019 is 149/190 with a Distance to Frontier (DTF4) score of 51.72 (The World Bank 2019) which measures the distance of an economy to the “frontier”, which represents the best performance observed on each of the indicators across all economies in the Doing Business sample since 2005. An economy’s distance to frontier is reflected on a scale from 0 to 100, where 0 represents the lowest performance and 100 represents the frontier. The ease of doing business ranking ranges from 1 to 190 (World Bank 2019).

• Afrobarometer's first national survey in the 15

Gambia (2018) results revealed that:

• overall bribery rate was at 21%, namely that 21% of users of public service paid a bribe in the previous 12 months

• almost half of all Gambians (46%) perceive a decrease in corruption over the past year, but one-third (32%) say the level of corruption in the country has increased.

• more than half (54%) of Gambians say the government is doing “fairly well” or “very well” in fighting corruption.

• two thirds (66%) think ordinary citizens can make a difference in fighting corruption, and six

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TI & Afrobarometer Findings 2019 (% Survey) - 🇬🇲

”Increasing” ”Doing Badly” ”Paid Bribe” ”Most Corrupt” - Police

36.0

21.0

37.032.0

in 10 (58%) say they can report corruption incidents without fear of retaliation.

• A majority (55%) say it is “somewhat likely” or “very likely” that authorities will take action when incidents of corruption are reported.

• Large majorities of Gambians say the rich are more likely than ordinary people to get away with paying a bribe or using personal connections to avoid taxes (71%), avoid going to court (75%) and register land that is not theirs (74%).

• Police and business executives are perceived to be the most corrupt officials, according to 38% and 31% of respondents, respectively, say “all” or “most” of them are corrupt. Officials perceived to be least corrupt are religious leaders (11%), members of parliament (15%) and traditional leaders (15%).

• Religious leaders, traditional leaders and the president are the most trusted leaders. They are trusted “somewhat” or “a lot” by 85%, 71% & 67% of respondents, respectively.

The US has criticised The Gambia for a lack of 16

fiscal transparency, stating the Government had off the books accounts supporting military and intelligence spending that were not subject to adequate oversight or audit. Despite this, the official budget reports that most of the money is spent on defence, security and military affairs, with education and health lower priorities . 17

With Gambia in transition, after 22 years under the rule of Yahya Jammeh, an Economic Commission has been established to investigate the many ways the former regime enriched itself criminally, including investigating the former President’s role in trafficking Rosewood. According to the UNODC

in its Wildlife Crime Threat Assessment 2019 , for 18

the CITES Cop18, the President took control of a trafficking flow that had been running since 2010. To do this, he established his own export company, called “Westwood”. All other companies wishing to export Rosewood were required to pay a fee of US$3,000 per container to Westwood before they were authorised to gain access to export.

Low Criminality - Low Resilience Africa’s OC Index 2019

5.4 Organised Crime: According to the Global Initiative against Transnational Organised Crime, in its Organised Crime Index (“OCI”) published in 2019 the Gambia is rated as Low criminality and 19

Low Resilience, ranked 34th out of 54 African Countries (lower ranking means higher criminality), though the Gambia is also rated low in terms of resilience at 17th out of 54 Countries.

The positive score on criminality reflects “its significant progress in anti corruption initiatives in the post “Jemma’s” era, aided to a significant degree by the strength of none State actors operating in the Country, and its modest ability to control its borders.”

Main Criminal Markets, Illegal Logging and Human Trafficking for OC’s  

Africa’s OC Index 2019

The Gambia - Threat Assessment - 2020 Page of 9 30

OC Index Criminal Markets - Importance - 🇬🇲

Heroin Wildlife HT Mining Logging Arms Cannabis People Smugg Cocaine

6.04.5

6.04.0

7.05.0

7.0

4.05.0

Nevertheless, the most pervasive criminal markets in the Gambia are illegal logging (7/10) and human trafficking (7/10).

The Gambia is a main destination for illegally felled rosewood timber from neighbouring Senegal, “with trafficking routes extending along Gambia’s southern borders with Senegal’s Casamance province, and supply chains running from Guinea-Bissau, through Casamance and Gambia’s capital Banjul, where the timber is exported to Asian End Markets.”

Other important criminal markets are in Illegal Drugs Cannabis (6/10), Cocaine (6/10), Heroin (5/10) Synthetic Drugs (2.5/10) & Human Smuggling (4.5/10).

On Groups, State Embedded actors (7/10) received the highest score, followed by Criminal networks (6.5/10), Foreign actors (2/10) and Mafia style groups (1).

The OCI describes criminal actor results as follows, “State embedded actors are the most influential individuals in the organised criminal activity taking place in Gambia. Corruption is rife in the country, particularly within the law enforcement bodies. It is state complicity in the Gambia this allows drug trafficking to persist, as the groups operating in the market act with impunity. Criminal networks are similarly influential, driving the major criminal markets in the Gambia, including the drugs markets,

the illicit logging market and the human trafficking market.”

State Embedded Actors are the most influential individuals in organised criminal

activity Africa’s OC Index 2019

5.5.1 Environmental “Green” Crimes - Timber: Whilst more than 40% of the Gambia is classified as forest land, only 10% is made up of woodland, down over the last decades, when the Country was covered in pristine forests. The Gambia is nevertheless almost entirely surrounded by Senegal which had abundant forests and high quality timber types such as desirable rosewood.

According to the OC Index, not only is illegal logging the most pervasive criminal market in the Gambia (7/10), along with Human Trafficking, it is also the most prevalent in neighbouring Senegal too (7/10), with activity growing significantly in the last decade, and trafficking routes extending to the southern borders of the Gambia with Senegal and supply chains running from Guinea Bissau through Senegal and Gambia’s capital, Banjul and then onwards to Asian export markets.

The OCI index states that, “the Casamance Forest, along the Gambian border, has been decimated by the illegal logging activities of both rebel forces in the country and foreign actors. The destruction of the forest has had a severe detrimental impact on the living conditions of the population, who depended largely on agriculture and tourism. However, since the fall of Gambia's President Yahya Jammeh, who played a major role in the illegal timber industry, the Senegalese government has made genuine efforts to strengthen governance over the Casamance region.”

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OC Index - Criminal Actor Types - Importance - 🇬🇲

Criminal Networks State Embedded Foreign Actors Mafia Style

1.02.0

7.06.5

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Illegal Logging is the most pervasive criminal market in The Gambia

Africa OC Index 2019

To date the Casamance Region has lost over a third of its forest or approx 1 million trees, due to a combination of actors including Senegalese and Gambian businessmen, Indian and Chinese traders, and also the local population, particularly the movement of Democratic Forces of Casamance (MFDC), a separatist group that has been fighting for independence since 1982, sustaining itself largely through timber trafficking.

According to the Africa’s OC Index, “it is estimated that more than 70% of the total timber harvested is unaccounted for, including high-value protected species. This causes huge losses in govt revenue and biodiversity.”

After Nigeria, the Gambia is West Africa’s second largest exporter of timber to China. Between 2010 and 2015, the Country’s export of rosewood to China was worth an estimated US$238.5 million . 20

5.5.2 Environmental “Green” Crimes: Illegal Fishing: One of the Gambia’s key natural resources is the abundant fisheries that lie off its coast. The country’s fishing grounds contain large stocks of fish, which migrate up and down the West African coast and provide a vital source of protein for 50% of the population, as well as providing jobs for 200,000 people (or approx 10% of the population. Gambians consume 25 kg of fish each, compared to an African average of 8.2 kg . According to a 21

2019 Report by the Changing Markets Foundation (the “Report”), The Gambia aims to increase fisheries as a % of GDP from 6.4% to 15% by 2021, not least to supply Fish Meal and Fish Oil (FMFO) for export for use in global aquaculture supply chains. This intensive activity is precipitating the

collapse of fish stocks, compromising food security, and destroying the social and economic fabric of communities living from the sea, at a time when the oceans are being pushed to the brink by the impacts also of climate change and pollution.

FMFO is mainly used as an ingredient in feeds for aquaculture and agriculture, with almost one-fifth of the world’s annual wild-fish catch used for this purpose. Global demand for FMFO is mainly driven by China’s huge aquaculture sector, but export-oriented sectors, such as salmon farming in Norway and Scotland and prawn farming in Asia, are also significant consumers. The Gambia has established three relatively new operational FMFO plants, located along a 30-kilometre stretch of coastline, financed by Chinese loans. According to the 2019 Report, the combined fish catch of just one of the Gambia’s FMFO plants accounted for approximately 40% of the country’s total reported catches in 2016, revealing the massive scale of this new industry in the country. The findings from the Report are that, “FMFO destined for human consumption is being exported without legally required food-safety certificates; that pollution from FMFO production is damaging the Gambia’s budding ecotourism industry and all 3 plants have been exporting FMFO illegally,” in breach of Food Safety and Quality standards.

Illegal export of Fish Meal and Fish Oil (FMFO) from the Gambia

Changing Markets Foundation - 2019

The findings from the 2019 Report suggest significant overfishing is happening off the coast of the Gambia which is visibly accelerating the decline of fish stocks and fisheries for human consumption which are now pushed to breaking point.

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5.6 Modern Slavery: The Gambia was rated as a Tier 3 Country in the US Trafficking in Persons Report 2018, and was downgraded from Tier 2 22

(Watchlist) due to the Gambia’s perceived lack of effort in its response. The TIP 2018 stated that The Gambia is; “a source, transit, and destination country for men, women, and children subjected to forced labor and sex trafficking. Most trafficking occurs within the country's borders and involves women and children from rural areas exploited in cities in domestic servitude or forced labor in agriculture, textile production, mining, construction, small businesses such as bakeries, and forced begging.” The TIP Report also identifies Gambia and neighbouring countries like Guinea, Senegal, Sierra Leone, Liberia, Ghana and Benin which take advantage of Gambia’s porous borders and as such is an active transit zone for women and girls and to a lesser extent boys trafficked for commercial sexual exploitation.

A notable exploitation comes from European tourists, seeking Gambian and West African women, girls, and, to a lesser extent, boys. Another area noted relates to some Koranic schools, where boys are forced into street vending or begging.

In the recently released US TIP 2020, The Gambia improved its rating from Tier 3 to Tier 2 Watchlist.

According to the Global Slavery Index report released in 2018, the Gambia was ranked 58th/167 in the index globally and 32nd out of 51 African Countries. GSI estimated 11,000 modern slaves living in The Gambia , reporting an incidence rate 23

of 5.74/1000 people. Based on an African average value estimated of US$3,900 per slave this would 24

generate approx US$43 million a year.

11,000 Human Trafficking Victims Global Slavery Index 2018

5.7 Drug Trafficking: The Gambia has an estimated 9,680 People with illegal drug use 25

disorders (2017), representing up to 0.5% of the population.

Drug markets in the Gambia, are according to the OCI, “established, given the country’s role as a transit state in the transnational trade. The Country is a significant trans-shipment point for Cocaine being trafficked from South America to European markets. It is one of the main countries for Cocaine trafficking in Africa, and huge volumes of Cocaine shipped by sea and air have been seized. State corruption is a significant contributor to the trafficking environment, as drug trafficking groups act with impunity in the Country, able to use Gambia as a

regional staging point for receipt and onward shipping of large volumes of cocaine.”

The OC Index also states that, “There is also a growing domestic market for Cocaine consumption, led in part by the increase in tourism development and the consequential influx of European tourists. According to the Country’s Interior Minister, Cannabis is the most problematic drug in The Gambia and is responsible for most of the drug related crimes committed in the Country. The Country currently opposes the decriminalisation of Cannabis use and confiscates over a million metric tonnes of marijuana every year. Young people are the demographic group that most consume Cannabis. The Gambia also acts as a transit point

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OC Index Drug Markets - Importance - 🇬🇲 (Scores out of 10 - lower scores are better)

Heroin Cannabis Cocaine Synthetics

2.5

6.06.05.0

for Heroin, en route to Europe. The volume of Heroin trans-shipping via the Gambia is increasing and the government has indicated that it perceives this growing market as a national threat.”

Cannabis has been grown for consumption and export in West Africa, including in the Gambia for decades, with the crop providing significant revenue to small-scale farmers, with little alternative sustainable and acceptable livelihoods.

Theft, stolen goods and smuggling likely to be rated as “Medium High”

FCN Prediction

5.8. Theft /Stolen Goods Smuggling & Other Crimes: It is expected that the NRA, is likely to consider Theft, stolen goods and smuggling as a “Medium High” money laundering threat which includes, theft and goods smuggled across borders mainly to evade taxes. Crimes considered as “Medium” money laundering threats include: armed robbery, counterfeiting of banknotes and imported pirated goods, (which has resulted in the establishment of an Anti-Intellectual Property Crime Unit), banking fraud, human trafficking, people smuggling, other environmental crimes, and other activities from organised crime, e.g. racketeering.

Armed robbery, counterfeiting of banknotes & imported pirated goods,

banking fraud, human trafficking, people smuggling, other environmental crimes, & other activities from organised crime, e.g.

racketeering likely to be rated as “Medium” FCN Prediction for The Gambia’s AML NRA

5.9. Financial Fraud: Whilst fraudulent misappropriation of State assets was rampant under the former regime of President Yammeh, and has been summarised by the OCCRP , Gambians 26

are not particularly exposed to financial fraud

directly against them, including from cybercrime, largely due to the fact that a significant numbers of Gambians still do not have Bank accounts (estimated at around 25% in urban areas and are not active online, though this will change over time. According to the West Africa Cybersecurity Indexing and Readiness Report 2017 , the Gambia 27

had 373,865 internet users in 2017 and was rated poorly for readiness to tackle cybercrime at 0.888 overall and 0.33 in FI’s out of 0-1.00 with 1.00 being the least ready. In the 2018 Cybersecurity Index, The Gambia scored 0.280/1 and was ranked 104/175.

5.10 Tax Evasion: Tax evasion is expected to be highlighted in the NRA as one of the major concerns from a Gambian perspective. According to the African Union based on work and data 28

provided by GFI, it is estimated that the Gambia suffered from illicit Financial Flows from 2004-2013, averaging US$90 million a year, and US$37 million from 2008-2017, according to Global Financial Integrity (GFI), to have left the Country, 29

representing a significant loss in tax revenues to The Gambia.

The Tax Justice Network gives Gambia a “high” secrecy score of 77 out of 100 in its Financial Secrecy Index 2018, making it it the 9th most secretive African Country and the 3rd most secretive West African country . 30

5.11 Overall Threat Level: According to FCN, the overall FC Threat Level is rated as “Moderate - High” Threat with a score of 59/100, ranked equal 14th/40 for lowest threats.

The Gambia - Threat Assessment - 2020 Page of 14 30

The Gambia - Threat Assessment - 2020 Page of 15 30

Section 6 - Sanctions & Terrorism

In this Section 6, the focus in on Sanctions and Terrorism threats.

6.1 Sanctions: The Gambia is not subject to international sanctions.

No Embassy’s in nor any trade (insignificant) is apparent regarding

Iran, Syria, or North Korea Various

It is listed as a Tier 3 Country, reflecting a low potential proliferator threat with a low controls scored at 283/1,300 , according to the PP 31

Index.

No Embassy’s in nor any trade (insignificant) is apparent regarding, Iran, Syria, or North Korea. There is a Cuban embassy in the capital Banjul.

There are 18 persons and or entities listed by US OFAC with addresses in the Gambia . 32

6.2. Terrorism: According to the Global Terrorism Index (GTI) , the Gambia is rated 33

equal lowest at equal 138/138 - with a score of 0/10,000 measuring the terrorism impact on the Gambia.

The Gambia was rated equal lowest of 138 countries with terrorism having “No” impact

Global Terrorism Index - 2020

Nevertheless, the Senegalese separatist group, the Movement of Democratic Forces of Casamance (MFDC), has been fighting for independence from Senegal since 1982, and operates on the Southern Gambian border sustaining itself largely through timber

trafficking, and is thought to have had ties to Gambia’s and Guinea Bissau’s former Presidents. The Casamance region although connected in the East to Senegal, is separated from the rest of Senegal by the Gambia. The principal inhabitants of the region are members of the Jola ethnic group and many are Christians or animists, unlike the majority of Senegalese who are Muslims. The sentiment has existed that the Jola do not benefit sufficiently from the region's richness and that Dakar, the capital, reaps most of the profit from the region's products. Despite some elements of the MFDC seeking peace in 2014 the conflict continues. Member of the group were suspected of being behind an ambush that left 13 people dead in Senegal in January 2018. Leaders of the MFDC, however, have denied responsibility for the execution-style killing, which they say was connected with the illegal harvesting of teak wood and rosewood from the forested region, not the gathering of firewood.

The Gambia is not included in the US State Departments Country Terrorism Reports.

According to UK Foreign Office travel advice , 34

“terrorist groups continue to mount attacks on beach resorts, hotels, cafés and restaurants visited by foreigners. Be especially vigilant in these places. There’s a heightened threat of terrorist attack globally against UK interests and British nationals from groups or individuals motivated by the conflict in Iraq and Syria.”

The Gambia - Threat Assessment - 2020 Page of 16 30

The Gambia - Threat Assessment - 2020 Page of 17 30

Section 7 - Money Laundering

In this Section 7, the focus is on the Gambia’s vulnerability to money laundering.

7.1 Higher Risk Areas: Higher risk areas have been identified through the published sources and set out in this Country Threat Assessment. In many cases a single risk factor may not be evidence of actual higher risks, and higher risks may be more likely to arise where a number of risk factors are identified.

According to the draft NRA, the Banking sector and DNFPB’s are identified as the main sectors, outside the large cash, cash smuggling and the informal sectors, which are vulnerable to having the proceeds of crime channelled. DNFPB’s with increased vulnerability are likely dealers in precious stones and metals, bureau de change, gambling operations, lawyers, notaries and micro finance.

7.2 Cash Based Money Laundering: The Gambia remains a cash based economy, despite problems with the currency, though this is changing. Much of the day to day,

person to person transactional activity occurs via exchange of cash for goods or services, with many areas of the Country still unbanked, but mobile money is becoming more and more popular. It is still not unusual for relatively large cash transactions to be undertaken, including for high value assets, such as real estate, vehicles, gold & gems.

Criminal Proceeds are generated in The Gambia for example, through theft or sexual exploitation of forced labour, but also in neighbouring Countries, for example through smuggling goods, and overseas, through sales of illegal logging in destination markets such as Asia. The amounts laundered in The Gambia will include domestic proceeds and some proceeds generated in neighbouring countries or overseas though these will be limited. Domestic Proceeds may also be laundered overseas, for example monies from corruption. Most transactions are carried out by mobile or in cash, where that is available. Some parts of the country, still do not have banking services, and so cash laundering or exchange is fairly straightforward.

7.3 Trade Based Money Laundering: Trade based money laundering is another technique that is used. See Section 8 for more details, on trade misinvoicing.

7.4 Other Money Laundering: Securities, Transaction and Virtual Currency laundering are not considered significant.

The Gambia Higher (Inherent) Risk Factors

Customer Risks

Sector Risks

Geography Risks

Customers with elevated exposures to: Criminal

activities such as: illegal logging, fishing, drug & human trafficking, with corruption (e.g PEP’s)

which also helps facilitate these crimes & tax evasion as a high risk concern also & to Higher

Risk Sectors and/or Geography Risks

Banks (in particular Retail and Correspondent

Banks)

Other FI’s such as Bureau de-Change,

MSB’s MMO’s Gambling Operations

DNFBP’s, in particular, precious metals and

stones dealers, lawyers, notaries and micro

finance

Informal Sectors

Country Neighbours; Major Export / Import

Partner Countries (Trade Mispricing and IFF’s)

Senegal, Guinea Bissau (Timber/Fish)

Major Export / Import Partner Countries (Trade

Mispricing and IFF’s)

Third Countries China (Timber/Fish)

Brazil, S America (Cocaine)

The Gambia - Threat Assessment - 2020 Page of 18 30

Section 8 - Illicit Funds including Estimated Criminal Proceeds

In this Section 8, the focus is on the Gambia’s vulnerability to Illicit Financial Flows and illegal Proceeds and to the laundering of criminal and other illicit funds.

According to the African Union based on 35

work and data provided by GFI, it is estimated that the Gambia suffered from illicit Financial Flows from 2004-2013, averaging US$90 million a year, and US$37 million a year from 2008-2017, according to Global Financial Integrity (GFI), to have left the 36

Country.

The Gambia’s Tax to GDP ratio of 17.7% , exceeds the 37

average African figure of 16.2, ranking 24th out of 40 SSA Countries (1st being the lowest Tax to GDP Country), and rated across Africa as a “Medium” Tax Collection Country.

According to GFI, the most common method for transferring illicit financial funds, is through trade mis pricing. GFI believe this method or series of techniques may represent up to 80% of illicit financial flows, and can involve 38

abusive and or aggressive transfer pricing, trade mis pricing and mis-invoicing, for example intentionally overpaying for imports of goods or services (or underpaying for exports or services) is a straightforward way of illegally transferring monies out of a Country.

The risks increase in trade with so called advanced economies. Whilst not all IFF’s are made up of criminal activity, a significant proportion will be.

According to the sources and analysis carried out in this Threat Assessment, estimates for criminal proceeds, laundered funds and, funds generated by corruption and organised crime,

amongst others, (see Appendix 1 for rationale) are as follows:

•Total estimates for criminal proceeds combined of 7.5% to 10.5% of GDP and with 10 - 15% of this estimated as costs of corruption.

• Total estimates for monies available for laundering through the formal sector is

40 - 50% of criminal proceeds and 24 - 26% involving organised crime, with most significant criminal actors being State Enabled Actors, closely followed by criminal networks.

• The largest criminal markets in The Gambia will include Illegal Logging, Fishing, Drugs & Human Trafficking with Corruption (e.g PEP’s) which also helps facilitate these crimes & Tax Evasion and some of those crimes identified as the largest markets across Sub Saharan Africa (see Pie Chart), but particularly Illegal Logging.

The Gambia - Threat Assessment - 2020 Page of 19 30

Total Criminal Proceeds in Sub Saharan Africa in US$ Billions - FCN 2020 (not including fraud

and corruption and tax evasion)

Mining10

Wildlife2

Logging12.5

Theft15

Drugs3

Modern Slavery8.3

Goods Piracy9

Fishing2.5

The Gambia - Threat Assessment - 2020 Page of 20 30

Section 9 - Resilience & Response

In this Section 9, the focus is on The Gambia’s level of resilience and response.

9.1 FATF: The Gambia was evaluated in April 2008 and will be subjected to another evaluation in February 2021, with reporting expected in 2022.

The Gambia was subject to a follow-up Mutual Evaluation Report in 2014 and according to that 39

Evaluation, The Gambia was deemed Compliant for 4 and Largely Compliant for 8 of the FATF 40 + 9 Recommendations. It was Partially Compliant or Non-Compliant for 5 of the then 6 Core Recommendations.

The Gambia is not on the FATF list of countries that have been identified as having strategic AML deficiencies.

Country Evaluation expected in 2022 FATF MER Calendar

9.2 Resilience to Organised Crime: According to the Organised Crime Index 2019, The Gambia has “Low Resilience.

“Low Resilience” OC Index - 2019

The OC Index states that “Gambia’s resilience to organised crime is greater than the majority of Countries on the continent,” although it also states that, “the government does not appear to have made countering organised-crime a priority, although it has made concerted efforts to reduce corruption within the state apparatus. Nevertheless, much more needs to be done to address corruption in order to put an end to state involvement in criminal activity.”

On resilience, the overall score is 4.63/10 and rated 17th/54 African Countries and 5th out of 15 West African Countries. Key component ratings include:

• AML (5/10)

• Economic Regulatory Environment (5/10),

• Law Enforcement (5/10)

• International Co operation (4/10).

The Draft NRA identifies the lack of institutional capacity building in competent authorities at a national level as a weakness and the quality of AML supervision for FI’s was also highlighted as one of the key sources of vulnerability.

9.3 Law Enforcement/Financial Intelligence Unit: In 2014, a total of 3,693kg of cannabis and 1kg of cocaine were seized in The Gambia, and in 2017, the amounts seized were 2,563 kg of cannabis and 0.7 kg of cocaine . 40

The reported number of arrests on account of drug related offences remained stable, though significantly higher (22/100,000) than the West African average (4.3/100,000) of population arrested on account of drug related offences, putting The Gambia is in the top 3 Countries in the region for the numbers of arrests in proportion to their population.

Less than 1% of estimated criminal proceeds seized”

FCN estimate

Despite these efforts there is no evidence that that more than 1% of criminal proceeds are

The Gambia - Threat Assessment - 2020 Page of 21 30

The Gambia - Threat Assessment - 2020 Page of 22 30

seized. Gambia’s FIU joined the Egmont Group in 2014. No SAR reporting by the FIU has been published to date.

9.4 Freedom: Beyond the definitions ascribed to Human Trafficking and or Modern Slavery, a broader concept of freedom is described by Freedom House’s, Freedom in the World Index, which ranks Countries and their citizens as either, “free” “partly free” or “not free.”

“Partly Free” Freedom in the World Index - 2019

The Gambia is scored at 46/100, and rated “partly free ”, but called out in 2019 as one of 3 Sub 41

Saharan African Countries, describing Gambia’s “rapid democratic gains for a second year, following the dramatic exit of strongman Yahya Jammeh in early 2017, “ and with the “political opening under President Adama Barrow reinforced by 2018 legislative elections, in which seven parties and several independent candidates won seats.” The 2018 improvement moved the country from the “not free” category in 2017 to a “partly free” in 2018.

According to the Heritage Foundation’s 2019 Index of Economic Freedom , The Gambia’s economic 42

freedom score is 56.3 making its economy one described as “mostly unfree”..

Score of 56.3/100 “Mostly Unfree” Heritage Economic Freedom Index - 2019

9.5 Governance: Under former President Jammeh’s autocratic rule, the Gambia was one of the 10 countries experiencing the most dramatic deteriorations in governance quality between 2007 and 2016, but in 2018 scored 54.9/100 up 3 from 2008 in the Mo Ibrahim Index of African Governance 2018 , rated 22 43

best out of 54 African Countries, with an “increasing Improvement”rating.

54.9 rating and 22/54 in Africa Mo Ibrahim African Governance Index - 2018

9.6 Basel AML Index: According to the 2019 44

findings, The Gambia is rated 71st worst out of 129 with a 2018 score of 5/10, which records an improvement from 2017 which was scored at 6.7/10.

Ranked 71st worst out of 129 Countries, scoring 5/10,

Basel AML Index 2019

The Gambia - Threat Assessment - 2020 Page of 23 30

Arrests due to drug related offences - UNODC 2014 - 2017 - 🇬🇲 (per 100,000 people)

2014 2015 2016 2017

22.019.420.721.0

Section 9 - Resilience & Response Continued

Based on the FCN Sub Saharan Africa Risk Rating Model, The Gambia is rated overall at 49/100 “Moderate - High”, with threats at 59/100 “Moderate” and “Low - Mod” Response 39/100.

Ranges for individual components are summarised below, with Low Response - RED, Moderate Response - Amber & Higher Response - Green, (see Section 4 for actual ratings). Key component ratings for FATF MER ratings and for OC Index for Resilience, and over time in the Mo Ibrahim African Governance Index and the Basel AML index are also shown.

The Gambia - Threat Assessment - 2020 Page of 24 30

Not Yet Available

Section 10 - Observations & Recommendations (O&R’s)

Based on this Gambian Threat Assessment, the following Observations and Recommendations (O&R) are made as follows:

• The Gambian Country Threat Assessment should be finalised and published, and should assess threats and vulnerabilities from a Gambian domestic perspective as well regional threats, in particular from Senegal, but also imports and exports, including Drugs from South America and of illegal Timber / fish from Senegal / Gambia to Asian Markets, as well as the role of Corruption.

• The 4th round Mutual Evaluation will take some time to carry out the review and publish findings, giving The Gambia time to close gaps and make enhancements. This time should not be wasted.

• The Gambian Government has made a good start in taking measures to move away from the corruption under the former President, though concerns remain around sustaining this progress and continuing the positive progression.

• The Gambian Government should review current priorities and resourcing to ensure a renewed focus on the main criminal markets and those activities that pose the greatest threats and harms. This means considering also the issue of illegal fishing as well as the focus on illegal timber in combatting financial crime as well as protecting the natural resources available.

O & R for Gambian Financial Institutions: Gambian Fi’s may want to consider whether their AML/CTF/Proliferation Programmes reflect the threats identified and/or if changes or enhancements are needed. Particularly important are exposures to logging and fishing, and to PEP’s,

particular those associated with the former President, including business associates. In particular a number of higher risk names of leading businesspeople and their companies have been implicated in the illegal timber business and are available via open source research.

O & R for Foreign Financial Institutions: Foreign FI’s that have exposures to the Gambia, from outside the Country may want to consider the following:

• Gambian PEP’s are likely inherently higher risk, due to high levels of corruption in the Gambia, and the State enabled actor scores in the OC Index, (albeit this relates to the previous ruling Presidency than the current one) so FI’s should consider EDD+ & Heightened Monitoring.

• The Gambia can be considered “Mod - High” FC risk from a Foreign FI’s perspective, relative to other Countries around the world. The Gambia is also having an “Improving” trend.

• Pending the publication of the MER 4th round Report, it is premature to speculate as far as compliance with FATF Recommendations, (particularly R-8 NPO’s, R10-CDD, R12-PEP, R13-CBR, R14-MSB’s, R15-NewTech, R23- Supervision & R26-FIU, and on Effectiveness (particularly IO3 Supervision, IO4-FI (& others) Preventative Measures, IO6-FIU & IO8-Confiscations. Once published these may have an impact on risk ratings for NPO’s, CBR’s, MSB’s, VASP’s and other FinTech’s from Gambia, and the overall Gambia Risk Ratings.

The Gambia - Threat Assessment - 2020 Page of 25 30

Appendix 1 - Range Matrices by FCN

In Section 8 Illicit funds including “Criminal Proceeds”, estimates for criminal funds in percentage terms and for “Costs of Corruption”, as well as estimates for “Laundering” and “Organised Crime” are set out, based on the inputs and calculations explained below.

1. Criminal Proceeds and Corruption: Table A1 below illustrates how the final estimates for Criminal Proceeds and Costs of Corruption are estimated. By taking the level of Criminality in the OC Index 2019, and the score from TI’s Corruption Index 2019, FCN’s overall Country Risk Rating, and based on the aggregate of these 3 sources a final range estimate for criminal proceeds can be established. For corruption, the three sources are used, but ranges then depend on the level of corruption based on TI’s Corruption Perception Index 2019 score.

Note: TI CPI Scores below 50 are rated: 40-49 Moderate to High, 30 to 39, High, below 30 Very High; OCI Criminality Scores are rated: 6 or above at Very High, 5 - 5.9 at High, 4 - 4.9 Moderate and below 4 as Low; FCN Scores are rated: 1-19 - Extremely High, 20 - 29 Very High, 30 - 39 High, 40 - 49 Moderate - High, 50 - 59 Moderate, 60 - 69 Low- Mod, 70 - 79 Low, & 80 - 100. For Costs of Corruption, ranges then depend on the level of corruption based on TI’s Corruption Perception Index 2019 score. For more details on source information for the OC Index, see HERE , for TI CPI Index see HERE and for the results for The Gambia for criminality for 45 46

corruption and the FCN Country Risk Rating Score see Section 3 above.

The Gambia - Threat Assessment - 2020 Page of 26 30

Table A1. Range Matrix for Estimating Criminal Proceeds & Corruption by FCN - 2020 - (Very High Rating is 4, High Rating is 3, Moderate Rating is 2 & Low Rating is 1 - with all scores aggregated for OCI Criminality, TI CPI & FCN Country Score

ScoreBottom of the Range % of

GDP Top of the Range % of GDP Corruption % of Proceeds If

Very High Levels (CPI)Corruption % of Proceeds If

High Levels (CPI)Corruption % of GDP If Moderate Levels (CPI)

12 10.5% 12.5% 15-20% 10-15% 5%-10%

11 10% 12% 15-20% 10-15% 5%-10%

10 9.5% 11.5 15-20% 10-15% 5%-10%

9 (Includes a V High)

9% 11% 15-20% 10-15% 5%-10%

9 (No V Highs)

8.5% 11.5% 15-20% 10-15% 5%-10%

8 8% 11% 15-20% 10-15% 5%-10%

7 7.5% 10.5% 15-20% 10-15% 5%-10%

6 (Includes a High)

7% 10% 15-20% 10-15% 5%-10%

6 (No Highs)

6.5% 9.5% 15-20% 10-15% 5%-10%

5 6% 9% 15-20% 10-15% 5%-10%

4 5.5% 8.5% 15-20% 10-15% 5%-10%

3 (Includes a Moderate)

5% 8% 15-20% 10-15% 5%-10%

3 (no Moderates)

4.5% 7.5% 15-20% 10-15% 5%-10%

2 4% 7% 15-20% 10-15% 5%-10%

1 3.5% 6.5% 15-20% 10-15% 5%-10%

2. Monies available for Laundering: Table A2 below illustrates how the final estimates for the range for monies available for Laundering was established. The top of the estimated range is 76% of criminal proceeds, based on the findings of the UNODC 2011 Study, which found that of US$2.1 trillion estimated global proceeds, that US$1.6 trillion was available for laundering or 76%, and that most of this this was expected to be available to be laundered via the formal financial sector. Based on the relatively low levels of financial inclusion in most Sub Saharan African Countries compared with the rest of the world, and the size of the shadow and informal economies, as well as the dominance still of cash within Sub Saharan economies, the estimates available for laundering through the formal financial sector have been assessed with these factors in mind based on the range estimates set out below, from sources estimating bank account and mobile money penetration, The Gambia is rated “Very Low.” For more details on source information on Financial Access, see HERE . 47

3. Criminal Proceeds Involving Organised Crime: Table A3 below illustrates how the final estimates for the range for criminal proceeds involving Organised Crime was established. The top of the estimated range is 46% of criminal proceeds, based on the findings of the UNODC 2011 Study, which found that of US$2.1 trillion organised crime were involved in US$960 million or approx 46%. Table A takes the different scores for organised crime in Sub Saharan African Countries reported by the OC Index and presents an estimate or range as a % of criminal proceeds, established as set out in Appendix 1 Section 1 above. The Gambia is rated 4.13. For more details on OC information, see HERE . 48

The Gambia - Threat Assessment - 2020 Page of 27 30

Table A2. Ratings Range Matrix for Laundering by FCN - 2020

Financial Access Range % for Laundering Criminal Proceeds

Financial Access Range % for Laundering Criminal Proceeds

V Low Access Levels < 30% bank accounts AND <30% mobile money

40-50 Moderate Access Levels >40% - 50% bank accounts OR >40% - 50% mobile money OR vice versa

60-70

Lower Access Levels >30% - 40% bank accounts OR >30% - 40% mobile money

50-60 Higher Access Levels > 50% bank accounts OR > 50% mobile money

70-76

Table A3. Ratings Range Matrix for Involvement by Organised Crime by FCN - 2020

Criminal Actors Score in OC Index Range % for OC Involvement

Financial Criminal Actors Score in OC Index Range % for OC

Involvement

Below 4 /10 in OC Index 2019 22-24 Rated 6 - 6.5/10 in OC Index 2019 32-34

Rated 4 - 4.5/10 in OC Index 2019 24- 26 Rated 6.5 -7/10 in OC Index 2019 34-36

Rated 4.5-5/10 in OC Index 2019 26-28 Rated 7-7.5/10 in OC Index 2019 36-38

Rated 5-5.5/10 in OC Index 2019 28-30 Rated 7.5-8/10 in OC Index 2019 38-40

Rated 5.5-6/10 in OC Index 2019 30-32 Rated 8/10 in OC Index 2019 or above 40-46

The Gambia - Threat Assessment - 2020 Page of 28 30

Message from the Editor - FCN

This Country Threat Assessment focuses on the financial crime threats and responses and is both a stand-alone publication, but can also be read in conjunction with the Global Threat Assessment, published in 2019 and the Sub-Saharan Threat Assessment published in 2020. The Sub-Saharan Threat Assessment has been supplemented by this country threat assessment, as well as for other countries in Sub-Saharan Africa. The individual threat assessments have been co-created with dedicated financial crime fighters from the countries covered, and/or with the help of professionals familiar with the country and the region, based on a consistent approach researching available open source information. Judgement has been applied in deciding what to include and what to emphasise. Each threat assessment follows the same structure and includes the same main sources, usually over 50 sources from important and credible agencies, in the form of reports, papers and or ratings. The threat assessments include the results from the FCN Sub-Saharan Africa 2020 Risk Rating Scorecard which includes a significant number of these sources to aggregate the threats and the responses to derive a final rating and a final ranking.

Author(s) & Editor The Author of this work are John Cusack, and Bintou Coker. The Editor is John Cusack, the publisher is Financial Crime News / Metriqa Limited. All rights remain with FCN/ Metriqa Limited.

John Cusack is a leading financial crime fighter, Founder & Editor of the Financial Crime News, former Global MLRO at UBS and Standard Chartered Bank, Two time Co Chair of the Wolfsberg Group (to end 2019), Board Member of the Traffik Analysis Hub, a Human Trafficking NGO, & adviser to Leading Regtech Providers Quantexa and Caspian and to numerous FI’s. Bintou Coker is a leading West African based financial crime fighter, the Head of Financial Crime Compliance at Standard Chartered Bank, The Gambia. Bintou Coker works in The Gambia currently, and prior to that established the Compliance Unit at GT Bank Liberia Ltd and acted as MLRO, also contributing to the setting up of the Liberia Financial Intelligence Unit.

Acknowledgements: Thanks and appreciation to a number of colleagues and collaborators who freely gave their time, to research, comment and provide advice in connection with this Gambian Country Threat Assessment, including: Hans Peter Bauer, Ursula M’Crystal, Victoria Meyer and Andrew Williams.

Information to Note: The information, provided in this Country Threat Assessment is designed to help those involved in combating financial crime. The Editor (John Cusack) takes responsibility for the contents of this document, including any opinions, observations or recommendations, but does not take responsibility for referenced materials, that are the responsibility of the authors and as appropriate. References are provided for information purposes and do not constitute endorsement of any information. readers should be aware that website references listed may change.

More Financial Crime Materials from FCN

Global Threat Assessment by FCN -

2019

Phase 1 - 19 Country Threat Assessments

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by FCN - 2020

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FCN - 2020

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Or Contact the Editor: JohnCusack.fcc@gmail.com

Endnotes: See: https://migrationdataportal.org/data?i=stock_abs_&t=2019&cm49=2701

See: http://www.fao.org/gambia/gambia-at-a-glance/en/2

See: https://epi.yale.edu/2018-epi-report/results3

See: https://unctad.org/en/pages/newsdetails.aspx?OriginalVersionID=21014

See: http://www.apjor.com/downloads/2501201714.pdf5

See: https://businessingambia.com/gambian-diaspora-remittance-2016/6

See: https://businessingambia.com/gambian-diaspora-remittance-2016/7

See: https://www.state.gov/wp-content/uploads/2019/03/INCSR-Vol-INCSR-Vol.-2-pdf.pdf 8

See: https://2009-2017.state.gov/j/inl/rls/nrcrpt/2016/vol2/253369.htm9

See: https://www.transparency.org/whatwedo/publication/corruption_perceptions_index_201910

See: https://www.traceinternational.org/trace-matrix#matrix-results11

See: https://www.occrp.org/en/greatgambiaheist/how-yahya-jammeh-stole-a-country 12

See: https://knowledgehub.transparency.org/assets/uploads/helpdesk/Gambia-overview-of-corruption-and-anti-corruption-2019_PR.pdf13

See: https://knowledgehub.transparency.org/assets/uploads/helpdesk/Gambia-overview-of-corruption-and-anti-corruption-2019_PR.pdf14

See: https://afrobarometer.org/sites/default/files/publications/Summary%20of%20results/gam_r7_sor.pdf15

See: https://www.state.gov/2019-fiscal-transparency-report/ 16

See: https://www.theguardian.com/global-development/2019/sep/23/gambia-joy-gives-way-to-sinking-distrust-adama-barrow-clings-to-power/ 17

See: https://cites.org/sites/default/files/eng/cop/18/doc/E-CoP18-034.pdf18

See: https://ocindex.net/country/gambia 19

See: https://issafrica.org/iss-today/the-silent-destruction-of-senegals-last-forests20

See: http://changingmarkets.org/wp-content/uploads/2019/10/CM-WEB-FINAL-FISHING-FOR-CATASTROPHE-2019.pdf21

See: https://www.refworld.org/docid/5b3e0a36a.html22

See: https://www.globalslaveryindex.org/2018/data/country-data/gambia/23

See: https://www.ilo.org/wcmsp5/groups/public/---ed_norm/---declaration/documents/publication/wcms_243391.pdf24

See: https://ourworldindata.org/illicit-drug-use25

See: https://www.occrp.org/en/greatgambiaheist/how-yahya-jammeh-stole-a-country 26

See: https://www.3tsconsulting.com/cybersecurity2017.pdf27

See: https://au.int/sites/default/files/documents/37326-doc-k-15353_au_illicit_financial_flows_devv10_electronic.pdf 28

See: https://secureservercdn.net/45.40.149.159/34n.8bd.myftpupload.com/wp-content/uploads/2020/03/GFI-Trade-IFF-Report-2020-Final.pdf?29

time=1583530239 See: https://www.financialsecrecyindex.com/PDF/Gambia.pdf30

See: https://isis-online.org/uploads/isis-reports/documents/ThePeddlingPerilIndex2019_POD.pdf31

See: https://sanctionssearch.ofac.treas.gov32

See: http://visionofhumanity.org/app/uploads/2019/11/GTI-2019web.pdf33

See: https://www.gov.uk/foreign-travel-advice/the-gambia/terrorism34

See: https://au.int/sites/default/files/documents/37326-doc-k-15353_au_illicit_financial_flows_devv10_electronic.pdf 35

See: https://secureservercdn.net/45.40.149.159/34n.8bd.myftpupload.com/wp-content/uploads/2020/03/GFI-Trade-IFF-Report-2020-Final.pdf?36

time=1583530239 See: https://au.int/sites/default/files/documents/37326-doc-k-15353_au_illicit_financial_flows_devv10_electronic.pdf 37

See: https://gfintegrity.org/gftrade/38

See: https://www.giaba.org/reports/mutual-evaluation/Gambia.html?lng=eng39

See: https://www.unodc.org/documents/westandcentralafrica/WENDU_REPORT_VF_V5_291019_FINAL_VERSION.pdf40

See: https://freedomhouse.org/report/countries-world-freedom-201941

See: https://www.heritage.org/index/country/gambia42

See: https://www.tralac.org/documents/resources/africa/2363-2018-ibrahim-index-of-african-governance-index-report/file.html43

See: https://www.baselgovernance.org/sites/default/files/2019-08/Basel%20AML%20Index%202019.pdf44

See: https://ocindex.net45

See: https://www.transparency.org/cpi2019?/news/feature/cpi-201946

See: https://datareportal.com/library47

See: https://ocindex.net48

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The Gambia - Threat Assessment - 2020 Page of 30 30