The Central Bank of The Gambia (CBG) has issued a circular directing all commercial banks operating in the country, including Nigerian lenders Access Bank, Guaranty Trust Bank (GTBank), FirstBank, and Zenith Bank, as well as Ecobank, to phase out non-Gambian employees by December 31, 2026. The directive, dated September 16 and signed by CBG Second Deputy Governor Dr Paul J. Mendy, requires banks to replace foreign staff with qualified Gambian nationals. The move follows an industry-wide review that found a high number of foreign workers in banks beyond those covered by recognised expatriate arrangements.
CBG Review Uncovers High Foreign Worker Numbers
The CBG said its review, conducted after a meeting with commercial bank managing directors on August 27, uncovered a “relatively high number” of non-Gambians working at banks beyond those formally recognised under expatriate arrangements. The regulator stated that this situation violates The Gambia's Labour Act 2023 and is inconsistent with Guideline 9, which governs how banks employ expatriate staff.
The circular stated: “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.” Banks were also instructed to ensure that as positions are localised, the transition does not cause the loss of critical institutional knowledge or disrupt day-to-day banking services.
Labour Act Requirements and Penalties
The CBG's directive draws on Section 38(1) of the Labour Act, which requires any employer granted an expatriate quota to also hire a Gambian understudy for that role, as reported by BusinessDay. The provision is designed to ensure that research, technology, and skills are transferred to local workers over time. The law also stipulates that the Expatriate Quota Board should not approve an expatriate quota for any role where the required skills already exist within The Gambia.
Employers who bring in foreign workers without the necessary quota clearance, or who fail to renew an existing quota, risk a fine of at least 500,000 dalasis on conviction. The same penalty applies to employers who do not assign a Gambian understudy to an expatriate employee. The legal framework stops short of banning expatriate employment entirely; instead, it ties such employment to regulatory approval and places an obligation on employers to build local capacity.
Industry-Wide Measure Affects Nigerian Banks
The CBG circular did not name any individual bank as being in breach of the rules, and it did not single out Access Bank, GTBank, FirstBank, Ecobank, or Zenith Bank for non-compliance. The directive is an industry-wide measure requiring all commercial lenders to align their workforce structures with existing labour laws. Each bank is expected to identify suitably qualified Gambian nationals who can fill affected roles as the transition progresses. The affected Nigerian lenders were contacted for comment on the directive but requested additional time to respond.
In related news, Nigeria's leading banks are spending more than ever to attract and retain workers. An analysis of the 2025 audited financial statements of Access Holdings, United Bank for Africa (UBA), Zenith Bank, and Wema Bank shows that the four lenders increased their combined workforce by 12.75% to 33,675 employees, while total wages and salaries rose 27.49% to N1.05 trillion. The surge in compensation comes as banks battle inflation and rising living costs, according to a previous Legit.ng report.
