Two institutions namely, Oceano Casino and Citi Trust Liberia are now the latest to be booked by the Financial Intelligence Agency for alleged failure to meet up with critical and essential obligations of the entity.
As the Financial Intelligence Agency continues its crack down on violators, the move the FIA stated is intended to serve as a deterent to would be violators to avoid recurrence.
According to the intelligence agency due to the gravity of the offense, the two institutions, Oceano Casino and Citi Trust Liberia have been fine L$10 million and L$5 million Liberian dollars totalling 15m Liberian dollars respectively.
The FIU emphasized that their latest action was also due to egregious violations of Liberia’s Anti Money Laundering and Countering the Financing of Terrorism (AML/CFT) Laws and significant inherent risk exposure of the Casino to Money Laundering and Terrorist Financing.
The Agency at the same time frowns at Oceano Casino and Citi Trust Liberia for their failure to meet critical and essential AML/CFT requirements as provided by the country’s AML/CFT Act of 2021.
The decision came following a detailed Risk-based AML/CFT Compliance inspection conducted by the FIA from October 2, 2024-March 17, 2025.
As part of the inspection, The FIA identified major violations in the Risk-based AML/CFT Compliance Inspections of Oceano Casino, which include the alledged failure of OCEANO Casino to take appropriate steps consistent with law to identify, assess, and monitor its Money Laundering Risk, including those of pre-existing Customers, Products, Services, Geographical Locations, and Delivery Channels, which the FIA stressed constitute violation of Section 15.3.1, Section 15.3.10 of the AML/CFT Act of 2021.2)
Additionally, pointed out the alleged failure of OCEANO Casino to establish an Independent AML/CFT Compliance function that is proportional to and consistent with the level of Money Laundering and Terrorist Financing and Proliferation of Weapon of Mass Destruction (WMB) Risk.
“OCEANO Casino does not have an AML/CFT Compliance Officer in violation of Section 15.3.12 (1) of the AML/CFT Act of 2021.3) OCEANO Casino AML/CFT Policy, procedures, and controls are not Risk-based and significantly inadequate to address the Money Laundering and Terrorist Financing risks of the Institution”, FIA disclosed.
The Intelligence Agency also indicated that , OCEANO Casino AML/CFT Policy does not align with the requirements of section 15.3.12 (2.c) of the AML/CFT Act of 2021; it does not provide for Screening of Customers, including Politically Exposed Persons (PEPs), Risk-based Customer Due Diligence, High-risks, Low risks, Enhanced Due Diligence, and Ongoing Simplified Due Diligence.
OCEANO Casino, FIA alleged lacks the appropriate mechanism and framework to effectively conduct ongoing monitoring of all business relationships and transactions, employing a risk-based approach.
Providing more justification for its action, FIA said OCEANO Casino lacks the system to monitor, detect, and report Suspicious Transactions (STR).
However and in bid to ensure compliance, the FIA instructs the Governance Structure of OCEANO Casino to perform key mitigating measures to include, The development of an Action Plan with well-defined timelines as part of remediation measures and submit the same to the FIA on Monday, May 12, 2025.
The FIA also called on them to ensure that all appropriate measures are put in place to address all deficiencies identified in the FIA Risk-based AML/CFT Compliance Report and mitigate the risk of Money Laundering and Financing of Terrorism and Proliferation of Weapon of Mass Destructions, no later than July 9, 2025.
At the same time, the Financial Intelligence Agency of Liberia (FIA) also took a radical step in a drive to enforce mitigating measure by imposing a fine of L$5 million Liberian dollars against CITITRUST Savings and Loans Limited Liberia, Inc.
The decision was due to what FIA described as the significant inadequate controls, egregious non-compliance, and violations to AML/CFT obligations as identified in the FIA Risk-based AML/CFT Compliance Inspection Report.
Amongst other things, The FIA identified the failure of CITITRUST Saving and Loans Limited Liberia, Inc to meet critical and essential AML/CFT requirements as provided by Liberia’s AML/CFT Act of 2021, following a Risk-based AML/CFT Compliance Inspection conducted by the FIA from December 2, 2024 – March 12, 2025.
According to the FIA, The inspection was a Full scope Risk-based AML/CFT Compliance Inspection.
The agency inspection primary objectives include; policies, procedures, compliance system, and control with the full range of the AML/CFT Obligations consistent with the country’s AML/CFT Act of 2021.2.
Moreover, the Reviewing of CITITRUST Liberia compliance with the Regulation for Microfinance Deposit Taking Institutions (MDIs) No. CBL/RSD/003/2014, AML/CFT Regulations for Financial Institutions in Liberia, No. CBL/RSD/002/2017, Corporate Governance Regulations for Financial Institutions No. CBL/RSD/001/2012, Central Bank of Liberia (CBL) Risk Management Guidelines; and Evaluate the level of Inherent Risk with CITITRUST Liberia’s operations as of November 28, 2024.
However, the FIA identified major violations in its Risk-based AML/CFT Compliance Inspections at CITITRUST Liberia, which include failure to take appropriate steps to identify, assess, and monitor its Money Laundering Risk, including those of pre-existing Customers, Products, Services, Geographical Locations, and Delivery Channels, which constitute violation of section 15.3.1, section 15.3.10 of the AML/CFT Act of 2021, Section 2.9 AML/CFT Regulations for Financial Institutions in Liberia, Regulations No. CBL/RSD/002/2017.2)
The alledged Lack of Board oversight on the AML/CFT Compliance function with a view of correcting weaknesses consistent with Section 12.0 of the Amended Corporate Governance Regulations for Financial Institutions, No CBL/RSD/001/2012.3) CITITRUST Liberia AML/CFT Procedure Manual is not Risk-based.
At the same time, FIA identified that the AML/CFT manual is outdated and does not reflect the current and emerging AML/CFT risk implicit of the institution’s customers, products, services, delivery channels, and geographical locations.
” The Manual does not technically align with the requirements of section15.3.12(2.c) of the AML/CFT Act of 2021. Numerous sections of CITITRUST Liberia AML/CFT Manual explicitly reference the Nigeria FIU and the legal and regulatory framework of Nigeria”.
Moreover, the Failure to ensure that the Head of Compliance is appointed by the Board in line with Section 12 of the Corporate Governance Regulations for Financial Institutions (FIs), No. CBL/RSD/001/2012.5) CITITRUST Liberia lacks the appropriate risk management framework to conduct Risk-based Customer Due Diligence.6)
Additionally, CITITRUST Liberia lacks the system/mechanism to monitor, detect, and report Suspicious Transaction Report (STRs).
Meanwhile, the FIA instructs the Governance Structure of CITITRUST LIBERIA to carry out the mitigating measures, which include the Development of an Action Plan with well-defined timelines as part of remediation measures and submit the same to the FIA Monday, May 12, 2025.2)
Ensure that all appropriate measures are put in place to address all deficiencies identified in the FIA Risk-based AML/CFT Compliance Report and mitigate the risk of Money Laundering and Financing of Terrorism and Proliferation of Weapon of Mass Destructions, no later than Tuesday, July 1, 2025.
At the same time, The Agency (FIA) has mandated CITITRUST Savings and Loans Limited Liberia, Inc to deposit L$5 million Liberian dollars in the Liberian Government escrow account no later than ten (10) working days beginning today May 5, 2025, to May 16th, 2025.
Similarly, Oceano Casino has been instructed by the FIA to deposit L$10 million Liberian dollars into the Liberian Government escrow account no later than ten (10) working days beginning today May 5th, 2025, to May 16th, 2025.
The FIA also emphasized that it shall take appropriate supervisory actions, where necessary, to ensure CITITRUST LIBERIA and Oceano Casino Comply with the Full range of AML/CFT Obligations.
