The Central Bank of The Gambia (CBG) has directed commercial banks operating in the country, including subsidiaries of Nigerian lenders – Access Bank, GTBank, FirstBank, Ecobank and Zenith Bank, to begin a phased replacement of non-Gambian employees with suitably qualified Gambian nationals.
The CBG set a December 31, 2026 deadline for full compliance.
The directive, contained in a September 16 circular signed by the Second Deputy Governor, Dr. Paul J. Mendy, followed a meeting between the regulator and managing directors of banks on August 27, 2026, 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 9 governing the employment of expatriate staff 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.
The regulator directed banks to complete the transition by December 31, 2026, while ensuring that the process does not disrupt banking operations or result in the loss of critical institutional knowledge.
The directive also required lenders to make arrangements for the transfer of skills and knowledge to Gambian employees as affected positions are progressively localised.
The CBG’s position 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 of expatriate employment requirements.
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 therefore does not impose an outright ban on expatriate employment but makes such employment subject to regulatory approval while placing emphasis on developing local capacity.
For banks owned or backed by Nigerian financial groups, the directive is expected to trigger reviews of existing staffing structures and expatriate arrangements in their Gambian subsidiaries, particularly where positions are occupied by non-Gambian personnel who are not covered by recognised expatriate arrangements.
However, the CBG circular did not name any individual bank as having breached the law or specifically accuse the Nigerian-owned institutions of non-compliance.
The directive is consequently framed as an industry-wide regulatory measure requiring banks to align their employment structures with existing labour laws and banking-sector guidelines.
It also places the onus on individual lenders to identify qualified Gambians capable of assuming affected positions while ensuring that the transition does not undermine operational continuity.
THISDAY contacted most of the banks affected for their perspectives on the directive and its implications for their operations in The Gambia. The institutions requested time to respond to the enquiries.
James Emejo and Nume Ekeghe
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