The Central Bank of The Gambia has directed commercial banks, including subsidiaries of major Nigerian lenders, to begin replacing non-Gambian employees who are not covered by approved expatriate quotas with qualified Gambian nationals.
The directive affects banks including First Bank, Access Bank, Zenith Bank, Ecobank and Guaranty Trust Bank, alongside other financial institutions operating in the West African country.
The Central Bank of The Gambia (CBG) gave the banks until the end of the year to comply, directing them to implement the localisation process in phases while ensuring uninterrupted banking operations.
The regulator said the affected banks must develop succession plans, transfer skills and institutional knowledge to Gambian employees and identify qualified locals capable of taking over positions currently occupied by non-Gambian workers outside approved expatriate arrangements.
The directive is contained in a letter addressed to managing directors of commercial banks in The Gambia and signed by the CBG’s Second Deputy Governor, Ousman Mendy.
The regulator said the directive follows discussions with bank managing directors in August concerning the employment of non-Gambian workers in the country’s banking sector.
It subsequently conducted an industry-wide assessment, which it said revealed a relatively high number of non-Gambian employees working in banks in addition to workers formally recognised as expatriate staff.
The CBG said the practice was inconsistent with provisions of The Gambia’s Labour Act 2023 and Guideline 9 governing the employment of expatriate personnel in the banking industry.
“A recent industry study conducted by the Bank revealed that a relatively high number of non-Gambians are employed by banks, in addition to recognised expatriate staff,” the regulator said.
It added that the practice violated provisions of the Labour Act 2023 and was not in line with Guideline 9 on expatriate staff.
Under the directive, banks are required to review their existing workforce structures and identify positions occupied by non-Gambian employees who do not fall under approved expatriate arrangements.
They are then expected to progressively transfer those positions to qualified Gambian nationals while providing the necessary training and skills transfer.
The CBG stressed that the process must be carefully managed to prevent disruption to banking services and avoid the loss of critical institutional knowledge.
The directive does not amount to a blanket ban on expatriate workers in The Gambia.
Instead, expatriate employment remains permissible where it is covered by the appropriate regulatory approval and quota arrangements.
The country’s labour framework allows employers to engage expatriates where specialised expertise is not sufficiently available locally, while requiring approved expatriate positions to support the development of Gambian understudies.
The framework is aimed at promoting the transfer of knowledge, technology and skills to local employees and gradually increasing the number of qualified Gambians capable of occupying positions that may initially require expatriate expertise.
Employers that engage expatriates without the required quota clearance or fail to comply with prescribed requirements relating to local understudies may face sanctions under the country’s legal framework.
For Nigerian banking groups with operations in The Gambia, the directive could require changes to staffing structures, expatriate arrangements and succession plans.
Nigerian lenders have established subsidiaries and operations across several African countries, with some relying on personnel and technical expertise from their Nigerian parent institutions.
The new requirement could therefore increase pressure on affected banks to accelerate the development and deployment of Gambian professionals in roles currently occupied by non-Gambian employees.
However, the CBG did not specifically accuse First Bank, Access Bank, Zenith Bank, Ecobank or Guaranty Trust Bank of violating the law.
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Rather, the directive applies broadly to commercial banks operating in The Gambia and requires them to bring their employment practices into line with the country’s labour laws and expatriate-staff regulations.
Banks are also expected to ensure that the transition does not affect the stability or day-to-day delivery of banking services.
The development comes amid efforts by regulators across African markets to promote local employment, capacity development and the transfer of skills in sectors where multinational and regional companies employ expatriate personnel.
For the affected banks, compliance with the CBG directive will involve reviewing expatriate quotas, identifying non-Gambian workers outside approved arrangements, assessing available local talent and implementing structured training and succession programmes before the year-end deadline.



