Financial Intelligence Agency Slams Orange GSM Company with L$15m Fine for Systemic Anti-Money Laundering Violations

Monrovia, Liberia: In a daring move that seems an unprecedented enforcement action for violation of Liberia’s financial compliance framework, the Financial Intelligence Agency (FIA) has levied a monetary penalty of fifteen million Liberian dollars (L$15,000,000) against Orange Liberia.

The fine follows the Orange Liberia GSM Company Mobile Banking system's failure to adhere to core Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) preventive standards.

By: Abraham Sylvester Panto

As mandated by Liberia’s AML/CFT Act of 2021, the alleged violation of Orange Liberia is said to have raised red flags over persistent institutional lapses and regulatory nonconformity within a critical sector of the nation’s financial services infrastructure.

The penalty was imposed as a direct outcome of a comprehensive, full-scope, risk-based AML/CFT compliance inspection undertaken by the FIA between September 2 and 13, 2024. The investigation targeted structural, procedural, and oversight weaknesses in OML’s internal compliance architecture. 

According to the FIA, the inspection was initiated to scrutinize the effectiveness of policies, procedures, and controls related to financial crime prevention, as well as the degree of adherence to Mobile Money Regulations, Corporate Governance standards, and Risk Management Guidelines as issued by the Central Bank of Liberia.

Core findings from the inspection unmasked extensive systemic irregularities, foremost among them being a demonstrable lack of board-level oversight over money laundering, terrorist financing, and weapons of mass destruction (WMD)-related financial risks.

Furthermore, the absence of documented performance reviews of compliance systems by the Board ofrs is a failure to meet fiduciary obligations for corporate risk governance.

Of particular concern to the FIA was the identification of a potential breach in the confidentiality of Suspicious Transaction Reports (STRs), where third-party involvement by CECOM—an entity operating within another jurisdiction—violated the integrity and secure processing requirements mandated under Section 15.3.22(2.b) of Liberia’s AML/CFT legal framework, exposing the institution to external compromise.

Furthermore, the inspection disclosed OML’s direct contravention of Section 6, Paragraph 5 of the Mobile Money Regulation No. CBL/RSD/003/2014 by failing to allocate a mandatory 20% capital shareholding opportunity to private Liberian investors or Liberian-owned institutions, thereby circumventing legal provisions aimed at domestic participation in the financial sector.

The FIA also highlighted the outdated and non-compliant status of Orange Money's 2024 AML/CFT Policies and Procedures Manual, which, at the time of inspection, had not been harmonized with prevailing legislative instruments. 

The manual includes the AML/CFT Act of 2021, Financial Institutions AML/CFT Regulations No. CBL/RSD/002/2017, and Corporate Governance Regulation No. CBL/SD/001/2012, which highlight operational vulnerabilities and regulatory neglect.

Compounding the infractions was the absence of a risk management system capable of properly identifying and classifying high-risk customers such as Politically Exposed Persons (PEPs), money service businesses, and agents dealing with high cash volumes—including supermarkets, foreign bureaus, and wholesale distributors—thereby limiting OML’s capacity to mitigate potential abuse of its platform.

The FIA also uncovered serious lapses in transaction monitoring at the level of full agents and merchants, where “unlimited transaction thresholds” were maintained without adequate surveillance mechanisms.

These lapses led to disproportionately low volumes of STR filings despite the volume and nature of transactional flows, suggesting operational negligence or deliberate evasion of detection obligations.

In light of these pervasive deficiencies and institutional failures, the FIA concluded that Orange Money Liberia had not only breached statutory obligations under the AML/CFT regime but had also failed to institute effective internal controls essential for detecting and deterring illicit financial activities.

As a mandatory corrective measure, the FIA has ordered Orange Liberia Governance Structure to develop a comprehensive remediation action plan—complete with detailed timelines—approved by its management and subject to certification by the FIA, with a submission deadline no later than Monday, June 23, 2025, as part of a structured compliance overhaul.

Moreover, Orange Liberia has been given until September 1, 2025, to implement all risk mitigation measures in full alignment with the FIA’s Compliance Report recommendations, particularly those aimed at addressing internal control failures, risk exposure vulnerabilities, and regulatory gaps that facilitate money laundering and terrorism financing.

Orange Money Liberia is also required to deposit the entire amount of L$15 million as a financial penalty for these violations into a designated Liberian government escrow account within ten working days, with the deadline for payment expiring on June 9, 2025.

The FIA’s decision underscored the seriousness of the regulatory action and the agency’s zero-tolerance approach toward AML/CFT violations.

The agency emphasized that Orange Liberia's failure to meet these timelines and remediation benchmarks will prompt additional supervisory actions, including escalated penalties or operational restrictions.

In its report, the FIA cautioned that systemic failures, if left uncorrected, not only compromise Liberia’s compliance profile with international watchdogs such as the Financial Action Task Force (FATF) but also elevate the country’s exposure to financial isolation and transactional restrictions from global financial institutions.

For their part, neither Orange Money Liberia nor has issued a formal public response to the findings or the imposed sanctions, although internal compliance restructuring is expected to commence under close FIA supervision pending satisfactory fulfillment of the agency’s mandates.