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Liberia’s Staggering L$15M AML Fines Spark Urgent Compliance Action

liberia oceano casino city trust aml fine

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Monrovia, Liberia — On May 5, 2025, the Financial Intelligence Agency of Liberia (FIA) delivered a resounding enforcement action, levying a combined L$15 million in penalties against two prominent financial institutions: Oceano Casino (L$10 million) and Citi Trust Savings and Loans Liberia, Inc. (L$5 million) FrontPage Africa. These fines—the largest civil sanctions since the enactment of the AML/CFT Act of 2021—underscore the FIA’s intensified commitment to safeguarding Liberia’s financial system from money laundering and terrorist financing risks.

Oceano Casino’s penalty stems from a multi-month, risk-based inspection conducted between October 2024 and March 2025, which exposed deep-rooted failures across its AML framework. First, the casino lacked any formal risk-assessment program for pre-existing customers, new product lines, or delivery channels, in direct violation of Section 15.3.1(2) of the AML/CFT Act of 2021, which mandates tailored risk-profiling for all customer relationships . Without such assessments, the institution could not identify high-risk Politically Exposed Persons (PEPs) or geographically high-risk regions.

Compounding this, Oceano Casino operated without an independent AML/CFT compliance officer or dedicated function—an explicit requirement under Section 15.3.12(1) of the Act . The absence of a designated officer meant there was no governance structure to oversee policy implementation or escalating suspicious activity reports. The casino’s policy manual remained outdated and misaligned with international standards, omitting critical screening protocols and due-diligence procedures. Finally, Oceano’s systems lacked automated transaction-monitoring tools, rendering it incapable of detecting or reporting unusual activities in real time.

Citi Trust Liberia’s Regulatory Gaps

During a parallel review from December 2024 to March 2025, Citi Trust Savings and Loans Liberia, Inc. exhibited similarly alarming compliance deficiencies. The institution failed to conduct any meaningful inherent-risk assessments, neglecting Section 15.3.1(2–3) of Liberia’s AML law . This failure left its board of directors without critical oversight responsibilities, in breach of Liberia’s Corporate Governance Regulations.

Further, Citi Trust’s AML/CFT policy manual cited Nigeria’s regulatory framework instead of Liberia’s own 2021 Act—creating a misalignment that violated Section 15.3.12(2.c) FrontPage Africa. Without a locally compliant policy, the institution could not implement risk-based due diligence or enhanced due-diligence measures for higher-risk customers. The appointment of its Head of Compliance also fell short of statutory requirements, as the selection process did not conform to Liberia’s corporate governance standards.

Enforcement Timelines and Financial Penalties

To remedy these systemic issues, the FIA has imposed strict deadlines. Both Oceano Casino and Citi Trust must submit detailed corrective action plans by May 12, 2025, outlining the establishment of independent compliance functions, updated policy frameworks, and robust transaction-monitoring systems. Oceano must implement all measures by July 9, 2025, while Citi Trust’s deadline is July 1, 2025 FrontPage Africa. Both entities are ordered to deposit their fines into a designated government escrow account by May 16, 2025, or face further supervisory actions, including potential license suspensions.

Broader Implications for Liberia’s Financial Integrity

These enforcement measures arrive against a backdrop of ongoing efforts to align Liberia with global AML/CFT standards. According to the latest FATF-GIABA mutual evaluation report, Liberia’s 2021 Act represents a significant legislative overhaul, yet practical implementation remains a work in progress . The FIA’s decisive action signals to banks, casinos, and other reporting entities that compliance is non-negotiable—and that technical legal reforms must be matched by operational rigor.

As Liberia seeks to maintain correspondent banking relationships and attract foreign investment, strengthening its AML/CFT regime will be essential. Institutions across the financial sector are now under pressure to invest in compliance training, risk-assessment tools, and advanced monitoring technologies. By driving home the cost of non-compliance, the FIA aims to foster a culture of proactive risk management and regulatory adherence.

Conclusion

Liberia’s FIA has set a watershed precedent: robust enforcement paired with clear remediation deadlines demonstrates that the nation’s AML/CFT framework is more than just legislation on paper. The potency of these fines—and the transparency of the enforcement process—will reverberate across the financial services industry, compelling institutions to elevate their compliance standards or face substantial penalties.