The Central Bank of The Gambia (CBG) on Wednesday, September 23, announced a directive for commercial banks operating in the country, including Access Bank, FirstBank, Ecobank and Zenith Bank, to begin replacing non-citizen employees with suitably qualified Gambian nationals.
The directive, contained in a circular dated Wednesday, September 16 and signed by the CBG’s second deputy governor, Dr Paul J. Mendy, set December 31, as the deadline for full compliance.
It followed a meeting between the regulator and managing directors of banks on Thursday, August 27, as well as an industry-wide study on the employment of non-Gambian personnel in the banking sector.
The CBG said the study revealed a “relatively high number” of non-Gambians employed by banks beyond staff formally recognised as expatriates.
According to the regulator, the practice contravenes provisions of The Gambia’s Labour Act 2023 and is inconsistent with guideline nine governing the employment of expatriate staff in the banking industry.
The central bank directed all banks to adopt a phased approach to replacing existing non-Gambian employees with suitably qualified Gambian nationals, while making arrangements for skills transfer and continuity of operations.
The regulator also instructed banks to ensure that the transition does not disrupt banking operations or result in the loss of critical institutional knowledge.
Under Section 38(1) of The Gambia’s Labour Act, an employer granted an expatriate quota for an expatriate position is required to employ a Gambian counterpart to understudy the expatriate.
The provision is intended to facilitate the transfer of research, development, technology, knowledge and skills to Gambian employees.
The law further provides that the Expatriate Quota Board should not grant an expatriate quota for a position where the required knowledge, skills or expertise already exists locally.
An employer that engages an expatriate without the required expatriate quota clearance, or fails to renew an existing clearance, is liable upon conviction to a fine of not less than 500,000 dalasis.
Similarly, an employer that fails to provide a Gambian understudy for an expatriate employee commits an offence and is liable to a fine of not less than 500,000 dalasis upon conviction.
The legal framework does not impose an outright ban on expatriate employment but makes such employment subject to regulatory approval while emphasising local capacity development.
The CBG circular did not name any individual bank as having breached the law or specifically accuse Access Bank, GTBank, FirstBank, Ecobank or Zenith Bank of non-compliance.
Instead, the directive applies across the banking industry and requires banks to align their employment structures with existing labour laws and banking-sector guidelines.
The affected banks are expected to identify qualified Gambians capable of assuming affected positions while ensuring that the transition does not undermine operational continuity.
The institutions were contacted for their views on the directive and its implications for their operations in The Gambia but requested time to respond.





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