Institutional Frameworks Suite
Five operational framework packs. Twenty artefacts. Built for institutions that need to demonstrate AML/CFT effectiveness — not just document its existence.
The gap between a compliant programme and a supervisory-defensible programme is the evidence trail.
Most institutions have AML/CFT policies. The challenge GIABA assessors and BoG examiners consistently surface is not the absence of policy — it is the absence of a documented, auditable trail showing that the policy works in practice. The Institutional Frameworks Suite closes that gap. Each pack combines a methodology document (the framework) with the analytical tools that produce the evidence supervisors actually ask for.
Enterprise-Wide Risk Assessment
EWRA · Pack A1
4 artefacts · 3 documents + 1 functional tool
The EWRA is the foundational document of every AML/CFT programme — the instrument that defines an institution's risk profile, justifies its control design, and maps to the Ghana National Risk Assessment findings that GIABA assessors will reference directly. A weak EWRA is one of the most common and most consequential gaps identified in Ghanaian supervisory examinations.
Pack A1 delivers a complete EWRA methodology built around Ghana's five risk dimensions (Customer 0.25 · Product 0.25 · Geographic 0.20 · Channel 0.15 · Transaction 0.15), with a scoring tool that produces a documented, auditable risk rating the institution can defend under examination.
STR Quality Framework
Suspicious Transaction Reporting · Pack C1
4 artefacts · 3 documents + 1 functional tool
Failure to file an STR within 24 hours of suspicion carries criminal liability under Act 1044 s.38(1). But the quality of STR filings — not just their timeliness — is now a specific focus of BoG examination and GIABA assessment. Poor STR quality (incomplete grounds of suspicion, missing customer context, weak narrative) draws adverse findings even where the filing itself was timely.
Pack C1 provides an STR quality framework, a scoring instrument for existing filings, and the QA tools that produce the MI a compliance function needs to demonstrate to supervisors that its STR process is actively managed and continuously improved.
Beneficial Ownership Framework
Beneficial Ownership · Pack E2
4 artefacts · 3 documents + 1 functional tool
Beneficial ownership identification is a persistent examination gap in Ghana. The BO threshold under the BoG/FIC Guideline 2025 is 5% for AML/CDD purposes (§2.4.2(12)), anchored in Act 1044 and the Companies Act 992, s.373. Complex ownership structures — nominee arrangements, bearer instruments, multi-tier corporate chains — create identification challenges that generic BO policies do not resolve.
Pack E2 delivers a BO identification framework, a complex structures guide, and a calculation worksheet that produces the documentation supervisors require when testing whether an institution's BO procedures function for real corporate structures, not just straightforward cases.
BoG 2025 Implementation Framework
BoG/FIC Guideline 2025 · Pack F1
4 artefacts · 3 documents + 1 functional tool
The BoG/FIC AML/CFT/CPF Guideline issued in September 2025 introduced materially new obligations — fraud management under §2.3.4(7), Know Your Employee (KYE) lifestyle audit reporting under §2.10, and a standalone Whistleblower Policy requirement under §2.12. Compliance programmes built before September 2025 have structural gaps that examiners are now identifying.
Pack F1 is an implementation framework, gap analysis instrument, and institutional toolkit designed specifically for the September 2025 Guideline. It maps every new obligation to the practical steps, policy changes, and evidence outputs required to satisfy each requirement under examination conditions.
GIABA Readiness Framework
GIABA Supervisory Readiness · Pack F2
4 artefacts · 3 documents + 1 functional tool
Ghana's on-site GIABA evaluation was completed in January–February 2026. The final Mutual Evaluation Report is expected at the November 2026 GIABA Plenary. Institutions that can demonstrate effectiveness against the GIABA Immediate Outcome methodology before that report is published are in a materially stronger position for the next evaluation cycle.
Pack F2 provides a complete GIABA readiness framework: a self-assessment instrument aligned to the IO methodology, an examination challenge question bank (40–70 supervisory-style questions by topic), an inspection narrative playbook, and a supervisory readiness toolkit. The challenge question bank reflects the actual lines of questioning GIABA and BoG examiners pursue — not theoretical examination scenarios.
Each pack is delivered as a documented institutional handover.
Institutional Frameworks Suite packs are not downloads. Each pack is delivered as a formal handover: the framework document(s) in final PDF, the functional tool(s) in their operational format, and an onboarding session to orient your compliance team on implementation. Delivery is scheduled from 30 June 2026.
Pricing for the Institutional Frameworks Suite is provided on request and is calibrated to institution type and pack combination. To obtain indicative pricing or to discuss a multi-pack engagement, use the contact form below.