The Central Bank of The Gambia has directed all commercial banks operating in the country to phase out non-Gambian employees and replace them with qualified Gambian nationals by 31 December 2026.
The directive, contained in a circular dated 16 September and signed by Second Deputy Governor Dr Paul J. Mendy, followed a meeting between the regulator and bank managing directors on 27 August and an industry-wide study of foreign employment in the banking sector.
According to the central bank, the study found a “relatively high number” of non-Gambians employed beyond those formally recognised under expatriate arrangements, in breach of The Gambia’s Labour Act 2023 and Guideline 9 on expatriate employment.
“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 bank said.
The order applies to all 11 licensed commercial banks, but is expected to have the biggest impact on subsidiaries of Nigerian and pan-African groups – including Access Bank Gambia, Guaranty Trust Bank Gambia, FirstBank Gambia, Zenith Bank Gambia and Ecobank Gambia – which have historically deployed staff from headquarters into risk, IT and control functions.
Under Section 38(1) of the Labour Act, employers granted an expatriate quota must employ a Gambian counterpart to understudy the expatriate to facilitate skills transfer. Employers who fail to comply face a fine of at least 500,000 dalasi – about $7,000 – on conviction. The Act also created an Expatriate Quota Allocation Board to restrict foreign hires to roles where local skills are scarce.
The regulator stressed the transition should not disrupt banking operations or lead to loss of institutional knowledge. Banks have just over three months from the date of the circular to map affected positions, validate quota status and complete handovers.
The circular has sparked debate online. Some have framed it as a standard localisation and local-content policy common across West Africa. Others have questioned its implications for labour mobility under the Economic Community of West African States (ECOWAS), whose protocol guarantees citizens of member states the right of entry, residence and establishment.
The Central Bank has not publicly responded to the online commentary. The banks named in the circular have not issued public statements, with several saying they needed time to review the directive.
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