Gambia Mandates Localisation of Banking Sector Roles, Nigerian Lenders Face Staff Transition
The Central Bank of The Gambia (CBG) has issued a sweeping directive requiring all commercial banks operating within the nation, including subsidiaries of prominent Nigerian financial institutions such as Access Bank, GTBank, FirstBank, Ecobank, and Zenith Bank, to commence a phased replacement of non-Gambian employees with qualified local nationals. This significant regulatory shift, aimed at bolstering domestic employment and capacity building within the financial sector, mandates full compliance by December 31, 2026.
The directive, formally communicated via a September 16 circular signed by Second Deputy Governor Dr. Paul J. Mendy, follows extensive engagement between the banking regulator and bank managing directors, including a meeting on August 27, 2026, and a comprehensive industry-wide study. This study identified a “relatively high number” of non-Gambian personnel employed by banks beyond those formally recognised as expatriates, a practice the CBG asserts contravenes The Gambia’s Labour Act 2023 and Guideline 9 on expatriate staff employment in the banking industry.
The CBG’s mandate requires banks to implement a structured approach to transitioning existing non-Gambian staff to suitably qualified Gambian nationals. Crucially, this process must incorporate robust arrangements for skills transfer and ensure the continuity of banking operations, thereby safeguarding against disruption and the loss of critical institutional knowledge. The regulator has underscored that the transition should facilitate the transfer of research, development, technology, knowledge, and skills to Gambian employees, aligning with Section 38(1) of the Labour Act, which mandates that employers granted expatriate quotas must ensure a Gambian counterpart understudies the expatriate.
The legal framework underpinning this directive does not impose an outright prohibition on expatriate employment but subjects it to stringent regulatory oversight and prioritises local capacity development. The Expatriate Quota Board is empowered to deny expatriate quotas for positions where the requisite local expertise already exists. Violations of these expatriate employment requirements carry substantial penalties, including fines of not less than 500,000 dalasis for engaging expatriates without clearance or failing to renew quotas, and similar penalties for failing to provide a Gambian understudy.
For Nigerian financial groups with operations in The Gambia, this directive necessitates a thorough review of their current staffing structures and expatriate arrangements, particularly for roles occupied by non-Gambian personnel not covered by formal expatriate authorisations. While the CBG circular did not name specific banks for non-compliance, it frames the directive as an industry-wide measure to ensure adherence to labour laws and banking sector guidelines. The onus now rests on individual lenders to identify suitable local talent and manage the transition effectively without compromising operational integrity. Affected institutions have indicated they require time to formulate responses to the CBG’s directive and its operational implications.
