Fia Slaps L$20 Million Total Fine On Golden And Riverside For Poor Anti-money Laundering Controls

MONROVIA – In an effort to reinforce AML/CFT compliance and to protect Liberia’s financial system, the Financial Intelligence Agency of Liberia (FIA) has strengthened its AML/CFT compliance function by penalizing Golden Casino and Riverside Casino with monetary fines of L$10 Million Liberian dollars each for failure to meet critical and essential Anti Money Laundering and Countering the Financing of Terrorism, Preventive Measures, and Proceeds of Crimes Act Requirements as provided by Liberia’s AML/CFT Act of 2021.

According to a press statement issued by the Financial Intelligence Agency (FIA) on Thursday, May 8, 2025, the agency conducted a full scope, risk based Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) compliance inspection at Golden Casino between October 10, 2024 and March 17, 2025. The inspection aimed to assess the adequacy of Golden Casino’s compliance program, specifically its policies, procedures, and internal controls, in line with the full requirements of Liberia’s AML/CFT Act of 2021. It also sought to evaluate the level of risk inherent in the casino’s operations.

The Agency’s risk-based inspection identified other major violations, which include the following:

GOLDEN Casino’s failure to establish an Independent AML/CFT Compliance function that is proportional to and consistent with the level of Money Laundering, Terrorist Financing, and Proliferation of Weapon of Mass Destruction (WMB) Risk.

GOLDEN Casino does not have an AML/CFT Compliance Officer in violation of Section 15.3. 12 (1) of the AML/CFT Act of 2021.

GOLDEN Casino’s AML/CFT Policies, Procedures, and Controls are not risk-based and significantly inadequate to address the Money Laundering and Terrorist Financing Risk of the institution. For example, the existing policy does not address the following in line with section 15.3.10(2) of the AML/CFT Act, Risk Assessment, PEPs, and BO, compliance functions. In addition, the existing Policy is not approved by Senior Management consistent with section 15.3. 12(2.b) of the AML/CFT Act of 2021.

GOLDEN Casino does not implement Know-your-Customers/Customer Due Diligence, Enhanced Due Diligence requirement, as required by Golden Casino AML/CFT Policy and Procedures Manual.

GOLDEN Casino AML/CFT Manual is not communicated/distributed to all relevant staff, nor is the manual implemented in a coordinated way across appropriate departments.

GOLDEN Casino has not conducted independent audit arrangements to review, test, and verify compliance with the effectiveness of the measures taken in accordance with Liberia’s AML/CFT Act of 2021.

GOLDEN Casino lacks the appropriate mechanism and framework to effectively conduct ongoing monitoring of all business relationships and functions employing a risk-based approach.

GOLDEN Casino lacks the system to monitor, detect, and report Suspicious Transactions.

Now henceforth, the FIA instructs the Governance Structure of GOLDEN Casino to perform the following mitigating measures:

Develop an Action Plan and Compliance Inspection Report) with well-defined timelines as part of remediation measures and submit the same to the FIA Monday, May 19, 2025.

Ensure that all appropriate measures are put in place to address all deficiencies identified in the FIA Risk-based AML/CFT Compliance Report and mitigate the risk of Money Laundering and Financing of Terrorism and Proliferation of Weapon of Mass Destructions, no later than Wednesday, July 9, 2025.

In a related development, the Financial Intelligence Agency of Liberia (FIA) has penalized Riverside Casino by levying a monetary fine of L$10 million Liberian dollars for its failure to meet critical and essential Anti Money Laundering and Countering the Financing of Terrorism, Preventive Measures, and Proceeds of Crime Act Requirements as provided by Liberia’s AML/CFT Act of 2021.

The Agency enforced the AML/CFT decision, following a Risk-based AML/CFT Compliance Inspection that details the outcomes of the FIA Risk-based AML/CFT Compliance Inspection conducted at RIVERSIDE Casino from October 9, 2024 – March 17, 2025.

The inspection was a full scope Risk-based AML/CFT Compliance Inspection with primary objectives of evaluating the following processes:

Assessing the adequacies of RIVERSIDE Casino’s Compliance Programs, including policies, procedures, and control, consistent with the full range of the AML/CFT Obligations as provided by Liberia’s AML/CFT Act of 2021, and

evaluating the level of Risk inherent with RIVERSIDE Casino’s operations.

The FIA has identified major violations in the Risk-based AML/CFT Compliance Inspections, which include the following:

RIVERSIDE Casino’ failure to establish an Independent AML/CFT Compliance function. RIVERSIDE does not have an AML/CFT Compliance Officer in violation of section 15.3.12 (1) of the AML/CFT Act of 2021.

RIVERSIDE Casino AML/CFT Policies, Procedures, and Controls are not risk-based and significantly inadequate to address the Money Laundering and Terrorist Financing Risk of the institution. For example, the existing policy does not address the following in line with Section15.3.10(2) of the AML/CFT Act of 2021, Risk Assessment, PEPs, and BO, Compliance Functions. In addition, the existing Policy is not approved by Senior Management consistent with Section15.3.12(2.b) of the AML/CFT Act of 2021.

RIVERSIDE Casino does not implement Know-your-Customers/Customer Due Diligence/Enhanced Due Diligence requirements, as required by RIVERSIDE Casino AML/CFT Policy and Procedures Manual.

RIVERSIDE Casino AML/CFT Manual is not communicated/distributed to all relevant staff, neither is the manual implemented in a coordinated way across appropriate departments.

RIVERSIDE Casino has not conducted independent audit arrangements to review, test, and verify compliance with the effectiveness of the measures taken in accordance with the AML/CFT Act of 2021.

RIVERSIDE Casino lacks the appropriate mechanism and framework to effectively conduct ongoing monitoring of all business relationships and transactions, employing a risk-based approach.

RIVERSIDE Casino lacks the system to monitor, detect, and report Suspicious Transactions.

Now henceforth, the FIA instructs the Governance Structure of RIVERSIDE Casino to enforce the following mitigating measures:

1) Develop an Action Plan with well-defined timelines as part of remediation measures and submit the same to the FIA Monday, May 19, 2025.

2) Ensure that all appropriate measures are put in place to address all deficiencies identified in the FIA Risk-based AML/CFT Compliance Report and mitigate the risk of Money Laundering and Financing of Terrorism and Proliferation of Weapon of Mass Destructions, no later than Wednesday, July 9, 2025.

Therefore, the FIA has instructed Golden Casino and Riverside Casino to deposit L$10 million Liberian dollars each in the Liberian Government escrow account no later than ten ( 10) working days, commencing from today, May 8, 2025, to May 21st, 2025.

The FIA shall take appropriate supervisory actions, where necessary, to ensure Golden Casino and RIVERSIDE Casino Comply fully with the Full range of AML/CFT Obligations.