Reported by: Ijeoma G | Edited by: Oravbiere Osayomore Promise.
The Central Bank of The Gambia has issued a sweeping regulatory directive requiring all commercial banks operating in the country to phase out non-Gambian employees and replace them with suitably qualified Gambian nationals by December 31, 2026. The directive, contained in a September 16 circular signed by Second Deputy Governor Dr. Paul J. Mendy, follows an industry-wide study that found a "relatively high number" of non-Gambians employed by banks beyond those formally recognised as expatriates. The regulator said the practice contravenes The Gambia's Labour Act 2023 and Guideline 9 governing the employment of expatriate staff in the banking industry. Four institutions within the scope of the directive are subsidiaries of Nigerian banking groups: Access Bank Gambia, First Bank Gambia, Guaranty Trust Bank Gambia, and Zenith Bank Gambia. Ecobank Gambia belongs to a pan-African parent listed on the Nigerian Exchange.
The directive applies to all 11 licensed commercial banks in The Gambia, including AGIB Bank, BSIC, Bloom Bank Africa, Mega Bank, Trust Bank, and Vista Bank. However, the biggest impact falls on Nigerian multinational subsidiaries that have historically dominated Gambian banking. For decades, banks like GTBank Gambia, FirstBank Gambia, Access Bank, and Zenith Bank have deployed middle-management, IT, risk, and operational leads directly from Lagos to run their Banjul operations. Under the new mandate, that model is now illegal. Banks must immediately design structured succession and skills-transfer plans, and the regulator has insisted that operational continuity must be maintained throughout the transition. "You are hereby directed to ensure full compliance with the law and strict compliance with CBG's guidelines," the circular states.
The Central Bank's directive is anchored in provisions of the Labour Act dealing with the training of Gambians by employers. Under Section 38(1) of the 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 requisite knowledge, skills, or expertise already exists locally. It also prescribes penalties for violations. An employer that engages an expatriate without obtaining 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 placing emphasis on developing local capacity. The published expatriate quota regime states that the total workforce should comprise 80 per cent Gambians and 20 per cent non-Gambians with skills unavailable locally. Applicants must also submit a programme for reducing expatriate employment, with target dates. The Central Bank's directive is therefore framed as an industry-wide regulatory measure requiring banks to align their employment structures with existing labour laws and banking-sector guidelines. It places the onus on individual lenders to identify qualified Gambians capable of assuming affected positions while ensuring that the transition does not undermine operational integrity.
For Nigerian banking groups with operations in The Gambia, the directive presents severe operational hurdles. A senior manager of one of the affected banks told The Standard that the four-month deadline presents severe hurdles for foreign parents' talent pipeline pressure. "With this order, banks must rapidly source, train, and promote Gambians into specialised technical and managerial roles previously held by seconded Nigerians," the banker said. The source added that core systems in IT, risk management, and operations must be handed over to locals at speed. Banks now have just over three months to identify replacements, train Gambian staff, and wind down non-compliant contracts while keeping operations running. Affected institutions have indicated they require time to formulate responses to the Central Bank's directive and its operational implications.
The directive also raises questions about the treatment of valid expatriate quotas. The Central Bank's letter does not disclose the number of affected employees, identify the institutions with the highest exposure, or state how valid expatriate quotas will be treated. As of September 20, the Central Bank had not published the circular on its public directives page, and Guideline 9 on expatriate staff, cited in the letter, is also not publicly available. The assessment standard therefore rests on the letter reviewed by Proshare rather than a published supervisory circular. Available information does not support a reliable estimate of transition costs or earnings impact.
For The Gambia, the directive is a significant step toward localising the banking sector and building domestic capacity. The country's Labour Act 2023 created an Expatriate Quota Allocation Board to limit foreign workers to roles where local skills are scarce, and official guidance has previously aimed for workforces that are predominantly Gambian. The Central Bank's decision to enforce these provisions in the banking sector reflects a broader push to prioritise local employment and reduce reliance on foreign personnel. For Nigerian banks operating in The Gambia, the directive is a test of their ability to adapt to changing regulatory environments and to demonstrate their commitment to the countries in which they operate. The coming months will determine whether they can meet the December 31 deadline without disrupting services or losing critical institutional knowledge. The Central Bank has made its position clear: operational continuity must be maintained, but non-compliance will not be tolerated.
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