Gambia’s Banking Reset: Why the Central Bank Is Pushing for Local Staff

 The banking industry in The Gambia is facing a significant staffing transition.

 By the end of 2026, commercial banks operating in the country are expected to progressively replace non-Gambian employees in affected positions with suitably qualified Gambian nationals, following a directive from the Central Bank of The Gambia (CBG).

 The measure affects the wider banking industry, including subsidiaries of major Nigerian financial institutions such as Access Bank, GTBank, FirstBank, Ecobank and Zenith Bank

 The CBG has set December 31, 2026 as the deadline for full compliance.

 At the heart of the directive is a policy question that has become increasingly important across African economies: how can foreign investment and international expertise coexist with the development of local professional capacity?

 For the Gambian central bank, the answer lies in a gradual transition that gives qualified Gambians greater access to positions currently occupied by non-Gambian personnel, while ensuring that banks do not lose critical skills or disrupt their operations.

 A directive rooted in existing law

 The CBG’s decision did not emerge in isolation.

 A September 16 circular signed by the bank’s Second Deputy Governor, Dr. Paul J. Mendy, followed an August 27 meeting between the regulator and managing directors of commercial banks, as well as an industry-wide study of non-Gambian employment in the banking sector.

 According to the CBG, the study identified a “relatively high number” of non-Gambians working in banks beyond those formally recognised as expatriate employees.

 The regulator said such arrangements were inconsistent with provisions of The Gambia’s Labour Act 2023 and Guideline 9, which governs the employment of expatriate personnel in the banking industry

 Rather than ordering an immediate removal of foreign workers, however, the CBG instructed banks to adopt a phased approach.

 The objective is to progressively localise affected positions while providing opportunities for Gambian employees to acquire the skills and knowledge necessary to take over those responsibilities.

The understudy principle

 The policy is built around a relatively straightforward principle: where an expatriate is employed, a Gambian counterpart should be developed alongside that worker.

 Section 38(1) of The Gambia’s Labour Act requires an employer granted an expatriate quota for a position to employ a Gambian counterpart to understudy the expatriate.

 The provision is intended to facilitate the transfer of knowledge, technology, research, development and professional skills to Gambian employees.

 The legislation also places limits on the use of expatriate workers. The Expatriate Quota Board is not expected to grant an expatriate quota where the required knowledge, skills or expertise already exists within the Gambian workforce.

 In effect, expatriate employment is permitted within a regulated framework, but the system is designed to ensure that foreign expertise contributes to the development of local capacity rather than permanently replacing it.

 What the December deadline means

 For banks, the December 31 deadline creates a relatively compressed period for reviewing their existing staffing structures.

 Lenders will need to identify positions occupied by non-Gambian employees, determine which roles fall within the scope of the regulatory requirements and assess whether suitably qualified Gambian professionals are available to assume those responsibilities.

 Where skills gaps exist, banks are expected to facilitate the transfer of knowledge before affected positions are localised

 The CBG has also stressed that the transition must not interfere with banking operations or result in the loss of important institutional knowledge.

 That requirement makes the directive more than a simple headcount exercise.

 For specialised positions, the challenge will be ensuring that the departure or replacement of experienced foreign personnel does not create operational gaps, particularly in areas where technical knowledge has accumulated over several years.

 A new phase for Nigerian banks in The Gambia

 The directive could have particular implications for Nigerian banking groups with established operations in the Gambian market.

 Access Bank, GTBank, FirstBank, Ecobank and Zenith Bank are among the Nigerian-linked institutions operating in the country.

 Their Gambian subsidiaries may now have to undertake detailed reviews of expatriate arrangements and staffing structures, particularly where non-Gambian employees are occupying positions without formally recognised expatriate status.

 But the CBG circular makes an important distinction

 The regulator did not identify any particular bank as having violated the law. Nor did it specifically accuse the Nigerian-owned banks of non-compliance.

 Instead, the directive applies across the banking industry and requires individual institutions to bring their employment structures into line with existing labour legislation and banking-sector guidelines.

 That distinction is significant because it frames the development as a regulatory and workforce-localisation measure rather than a sanction against particular banks.

 The cost of getting it wrong

 The legal framework also provides financial penalties for violations of expatriate employment requirements.

 An employer that engages an expatriate without the required expatriate-quota clearance, or fails to renew an existing clearance, can face a fine of at least 500,000 Gambian dalasis upon conviction.

 The same minimum penalty applies where an employer fails to provide a Gambian understudy for an expatriate employee.

 For banks, therefore, compliance is not simply a question of meeting a regulatory deadline. It also involves ensuring that expatriate arrangements are properly authorised and accompanied by mechanisms for developing Gambian counterparts.

 Beyond foreign workers

 At a broader level, the CBG’s directive reflects an attempt to deepen local participation in one of the country’s most important professional sectors.

 Banks require expertise in areas ranging from risk management and information technology to treasury operations, compliance, credit administration and executive management

 The challenge for regulators is to encourage local professionals to occupy more of these positions without weakening the technical and institutional capabilities of the banking system

 That is why the CBG has paired localisation with skills transfer and continuity requirements.

 The objective, as reflected in the directive, is not simply to replace one category of employee with another. It is to create a process through which expertise accumulated by foreign personnel can increasingly become part of the domestic workforce.

  The banks’ response

 The affected institutions have yet to publicly provide detailed responses to the directive. Most of the banks concerned have requested additional time to respond on their views.

 Their eventual responses could provide greater clarity on the scale of the affected workforce, the number of positions that may be subject to localisation and how individual banks intend to meet the December deadline.

 For now, the direction from the CBG is clear: banks operating in The Gambia are expected to progressively increase the participation of qualified Gambian nationals in positions currently held by non-Gambian personnel, while maintaining operational stability and ensuring the transfer of skills.

 The December 31 deadline gives the industry only a limited window to complete that transition.

 What happens over the coming months will determine how smoothly the banking sector can balance two sometimes competing objectives — access to international expertise and the development of a stronger, more self-sufficient local professional workforce.