Gambia Orders Access Bank, GTBank, Other Banks To Replace Non-Gambian Staff By December

The Central Bank of The Gambia (CBG) has directed commercial banks operating in the country to begin a phased replacement of non-Gambian employees with suitably qualified Gambian nationals.

The directive affects banks across the sector, including Gambian subsidiaries of Nigerian financial institutions such as Access Bank, GTBank, FirstBank, Ecobank and Zenith Bank.

The regulator gave the banks until December 31, 2026, to complete the transition, while stressing the need for proper skills transfer and continuity of banking operations.

The directive was contained in a circular dated September 16, 2026, and signed by the CBG’s Second Deputy Governor, Dr. Paul J. Mendy.

It followed a meeting between the central bank and managing directors of commercial banks on August 27, as well as an industry-wide study into the employment of non-Gambian personnel in the banking sector.

According to the CBG, the study found a “relatively high number” of non-Gambians employed by banks beyond those formally recognised as expatriate staff.

The regulator said the practice contravenes provisions of The Gambia’s Labour Act 2023 and is inconsistent with Guideline 9, which governs the employment of expatriate personnel in the banking industry.

“Consequently, all banks are required to adopt a phased approach to replacing existing non-Gambian staff with suitably qualified Gambian nationals, with appropriate arrangements for skills transfer and continuity of operations,” the CBG stated.

Under the directive, banks are expected to progressively localise positions currently occupied by affected non-Gambian employees.

However, the central bank said the process must be handled in a way that prevents disruption to banking services and avoids the loss of critical institutional knowledge.

Banks are also required to establish arrangements for transferring relevant skills and knowledge to Gambian employees as the affected positions are localised.

The directive is linked to provisions of The Gambia’s Labour Act concerning the training and development of Gambian workers.

Section 38(1) of the Act provides that an employer granted an expatriate quota for an expatriate position must employ a Gambian counterpart to understudy the expatriate.

The requirement is designed to promote 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 are already available locally.

Nigerian-Owned Banks Affected

The directive has particular relevance for Nigerian financial groups with operations in The Gambia, including Access Bank, GTBank, FirstBank, Ecobank and Zenith Bank.

The affected institutions are expected to review their existing staffing structures and expatriate arrangements, particularly positions occupied by non-Gambian employees who are not covered by recognised expatriate arrangements.

However, the CBG circular did not name any individual bank as having breached the law, nor did it specifically accuse Nigerian-owned banks of violating the regulations.

Instead, the directive applies across the banking industry and requires individual lenders to align their employment structures with existing labour laws and banking-sector guidelines.

The legal framework also does not impose an outright prohibition on expatriate employment in The Gambia.

Rather, expatriate employment remains subject to regulatory approval, with employers required to meet conditions designed to encourage the development of local expertise.

Employers that engage expatriates without obtaining the required quota clearance, or fail to renew an existing clearance, can face a fine of at least 500,000 dalasis upon conviction.

Similarly, an employer that fails to provide a Gambian understudy for an expatriate employee commits an offence and may also face a minimum fine of 500,000 dalasis upon conviction.

The CBG’s latest directive therefore places the responsibility on banks to identify qualified Gambian nationals who can assume affected positions while ensuring a structured transfer of knowledge and maintaining the stability of their operations.

The transition is expected to continue through the end of 2026, with banks required to achieve full compliance by December 31, 2026.