As part of efforts to enhance National Coordination regarding effective Risk-based Supervision in the Gaming Sector, the Financial Intelligence Agency of Liberia (FIA) has recently concluded a specialized training program for staff of the National Lottery Authority (NLA). The comprehensive capacity building initiative is a direct response to critical deficiencies identified in Liberia’s gaming sector by the Inter-Governmental Action Group Against Money Laundering in West Africa (GIABA).
The specialized Anti-Money Laundering and Countering the Financing of Terrorism training was designed to address specific AML/CFT regulatory gaps highlighted in Liberia’s Second Round Mutual Evaluation Report (MER2).
The GIABA June 2023 report underscored major deficiencies in Liberia’s legal and regulatory framework with specific regards to: 1) no requirements prescribing the transaction threshold or specific activities involving Casinos, 2) Internet and ship-based casinos are not included in the definition of casinos in the NLA Act, 3) Fit and Proper is not explicitly defined in the National Lottery Act or Lottery Regulations, 4) Fit and Proper requirement is mainly on financial capacity, knowledge, and experience and does not cover assessment of character (including criminal background check), 5) Fit and Proper assessment is not conducted on individuals exercising control of other forms than capital control and the criteria for testing the suitability of character, honesty, and integrity were not provided in the Regulation and, 6) AML Act also designates the NLA as an AML/CFT supervisor but there is an absence of clarity related to these powers and whether the NLA Act would need to be revised to make this responsibility effective.
Dozens of staff of the National Lottery Authority individually received specialized training certificates following the climax of the daylong capacity building initiative that was conducted by FIA’s Compliance Department that is supervised by Manager Bobby Q. Harris. The curriculum focused on practical, actionable measures for NLA staff, including identifying red flags for money laundering, understanding customer due diligence requirements, and implementing effective transaction monitoring systems. Participants were equipped with the knowledge to serve as a first line of defense, ensuring that Liberia’s gaming operations are not exploited for criminal purposes
Speaking during the opening of the specialized training at FIA’s Headquarters, the Agency’s Officer-In-Charge, Mohammed Ali Nasser emphasized the program’s strategic importance for staff of NLA who are working in Liberia’s gaming sector to be more knowledgeable in combating financial crimes.
According to OIC Nasser, the gaming sector handles significant cash flows, making it imperative that its regulators and operators are continuously equipped with the latest skills to detect and report suspicious activities.
He stated that the specialized training is not merely a regulatory exercise; it is a critical investment in safeguarding the integrity of Liberia’s entire financial system. “By strengthening the NLA’s capacity, we are effectively closing a potential gateway for illicit funds.”
The FIA OIC urged NLA staff to continuously cultivate a culture of reading to enable them to clearly understand the various rules, standards, and regulations governing Liberia’s gaming sector.
Also speaking during the opening of the training program, NLA Deputy Director General for Lotto Games, Richlue O. Burphy, asserted that the National Lottery Authority welcomed the collaboration because the regulatory partnership with the FIA is invaluable and timely.
According to Burphy, the NLA has been empowered with the expertise needed to operate at international best practices. “We are now better positioned to ensure that our services contribute to national development, not to financial crime, “
He emphasized that the National Lottery Authority’s (NLA) statutory mandate extends beyond mere revenue generation.
Burphy stated that the Authority is equally tasked with a dual responsibility: to help maintain public trust and to positively uphold national security protocols within the country’s gaming sector. “This underscores a strategic shift from viewing the NLA solely as a commercial entity to recognizing its vital role in ensuring the integrity and security of the national lottery system.”
During a training program presentation, FIA Compliance Manager Bobby Q. Harris stressed that the National Lottery Authority’s critical role as a sector supervisor makes the continuous capacity building of its staff essential for technically conducting the required ‘fit and proper’ assessments before licensing new gaming operators.
According to Manager Harris, fostering collaboration, cooperation, and coordination between the FIA and the NLA is essential to promoting a culture of voluntary compliance among operators in the gaming sector.
He stated that the Financial Action Taskforce (FATF) Recommendation 27 and 28 mandate that national supervisors must be granted the legal authority to conduct inspections, compel the production of records, and take decisive action against non-compliant institutions. He intoned that the FATF’s recommendation emphasizes that without these essential powers, oversight bodies are effectively “toothless” and cannot ensure that banks and other financial entities are properly implementing anti-money laundering safeguards.
Harris pointed out that FATF Recommendation 28 specifically extends these supervisory powers and the requirement for “effective, proportionate, and dissuasive” sanctions to a list of Designated Non-Financial Businesses and Professions (DNFBPs). “This group includes real estate agents, lawyers, accountants, dealers in precious stones, and trust and company service providers.”
He said the purpose is to prevent criminals from simply shifting their activities from the heavily- regulated banking sector into less-scrutinized areas of the economy, ensuring a more comprehensive defense against financial crime.
Hon. Amos Y. Boakai, Deputy Director General of the Financial Intelligence Agency of Liberia, and FIA Director for Operations, Carlos Railey, attended the training program, where they both emphasized the timeliness of the capacity building initiative in addressing critical AML/CFT skills gaps among NLA staff.
Meanwhile, this capacity-building exercise marks a significant step in Liberia’s ongoing efforts to remediate the findings of the MER2 and demonstrates a proactive commitment to meeting its international AML/CFT obligations.