Liberia’s FIA Slaps Record Fines on Oceano Casino and Citi Trust Over AML Failures

In a landmark move underscoring its renewed vigilance in protecting Liberia’s financial system, the Financial Intelligence Agency of Liberia (FIA) announced on May 5, 2025, that it had imposed L$15 million in civil penalties against two major financial entities—Oceano Casino and Citi Trust Savings and Loans Liberia, Inc. The fines, amounting to L$10 million for Oceano Casino and L$5 million for Citi Trust, represent the largest enforcement actions since the AML/CFT Act of 2021 came into force. These sanctions, detailed in reports published by FrontPage Africa, reflect the FIA’s heightened stance on anti-money laundering and countering terrorist financing (AML/CFT) enforcement across the country.

Oceano Casino found itself in the regulatory crosshairs after a rigorous, risk-based inspection carried out from October 2024 to March 2025 uncovered a web of serious compliance violations. At the heart of the findings was the casino’s total absence of a formal risk-assessment program. According to the FIA, Oceano failed to evaluate AML/CFT exposure across its customer base, new product offerings, and delivery channels. This lack of assessment directly contravened Section 15.3.1(2) of the AML/CFT Act, which mandates that all financial institutions conduct comprehensive, tailored risk profiling to identify potential vulnerabilities, including those posed by Politically Exposed Persons (PEPs) and high-risk jurisdictions.

Even more alarming, Oceano Casino operated without a dedicated AML/CFT compliance officer or even an internal compliance function, a clear breach of Section 15.3.12(1) of the Act. This structural void meant there was no framework for enforcing policies or for escalating suspicious activity reports internally. Moreover, the casino’s policy manual was reportedly outdated, non-compliant with global best practices, and failed to include critical elements such as customer screening and due diligence procedures. The institution also lacked any form of automated transaction-monitoring system, leaving it incapable of identifying or responding to unusual financial behavior in real time—an operational blind spot that left it wide open to abuse.

Meanwhile, Citi Trust Savings and Loans Liberia, Inc. came under scrutiny during a separate FIA compliance review conducted between December 2024 and March 2025. The agency found that Citi Trust had failed to carry out essential inherent-risk assessments, again violating Section 15.3.1(2–3) of the AML/CFT Act. This omission left the institution’s board without a crucial oversight mechanism and constituted a violation of Liberia’s Corporate Governance Regulations. According to FrontPage Africa, the deficiencies at Citi Trust extended further: the institution’s AML/CFT policy manual inappropriately referenced Nigeria’s regulatory environment rather than Liberia’s own 2021 legislation, a blatant mismatch that placed it in breach of Section 15.3.12(2.c). This misalignment effectively crippled the firm’s ability to implement Liberia-specific due diligence and enhanced risk mitigation procedures for high-risk clientele.

In addition, Citi Trust’s appointment process for its Head of Compliance was found to be non-compliant with the statutory corporate governance norms outlined under Liberian law. The FIA noted that without a properly selected compliance lead, the institution lacked the leadership necessary to implement and enforce critical AML/CFT controls.

To correct these institutional failures, the FIA has mandated that both entities submit comprehensive corrective action plans by May 12, 2025. These plans must include the appointment of independent compliance officers, revisions to policy manuals to reflect Liberian law, and the integration of robust transaction-monitoring systems. Citi Trust is expected to complete all required reforms by July 1, 2025, while Oceano Casino has until July 9, 2025 to bring its operations into compliance. The fines must be deposited into a designated government escrow account by May 16, 2025. The FIA warned that failure to comply with either the financial or operational mandates could lead to further sanctions, including possible license suspension.

This sweeping enforcement action arrives at a pivotal moment for Liberia’s AML/CFT framework, as the country continues efforts to align its domestic regime with international expectations laid out by the Financial Action Task Force (FATF) and the Inter-Governmental Action Group Against Money Laundering in West Africa (GIABA). The FIA’s moves are aimed not only at domestic enforcement but also at securing Liberia’s position in global finance, particularly as the country looks to preserve correspondent banking relationships and attract foreign investment.

The FIA’s statement carried a broader message for Liberia’s financial sector: non-compliance is no longer a tolerable risk. Institutions are now under considerable pressure to modernize their AML/CFT operations—through training programs, investment in monitoring technologies, and the implementation of risk-based governance frameworks. By making clear the financial and reputational costs of regulatory negligence, the FIA seeks to instill a national culture of compliance and operational accountability.

As the FIA drives home the point that the AML/CFT Act of 2021 is “more than just legislation on paper,” these enforcement actions against Oceano Casino and Citi Trust establish a clear precedent. The unprecedented scale of the penalties and the transparency surrounding the enforcement timeline send a powerful signal to Liberia’s financial institutions: elevate compliance standards or face significant repercussions.

By fLEXI tEAM