While luxury buildings rise across urban areas, many Gambians on regular salaries struggle to pay rent or dream of owning a home.
Teacher Aminata Njie pays about US$76 a month in rent from a salary of roughly US$153. She said rental prices have continued to soar, making it difficult for teachers like her to afford a decent house.
John Njie, a former civil servant who initially paid about US$34 a month in rent in 2018, now pays approximately US$68 after a third party who resides abroad acquired his house. Consequently, when John searched for another property, he encountered estate agents who demanded commissions. Some landlords and agents asked for six months or even a year’s rent upfront—payments he said many ordinary tenants cannot afford.
An image of Aminata Njie’s rented apartment. Photo Credit: DUBAWA.
As demand and investment in real estate advance, the public has raised eyebrows at the financial dealings linked to the real estate business in The Gambia. Many suspect that illicit funds are driving up property prices and making apartments less accessible to ordinary Gambians.
DUBAWA’s investigation into The Gambia’s real estate market identified massive cash flows in property transactions, unclear ownership arrangements, and loopholes in enacted laws meant to curb money laundering.
This investigation explores why rents and mortgages have become unbearable by examining court cases involving suspected proceeds of crime, property transactions, and the systems meant to ensure buyers and sources of funds are properly verified.
Gambia’s courts, real estate and money laundering charges
Since 2020, almost all major drug-related trials in The Gambia have been linked to money laundering that involved the purchase of vehicles and properties.
In September 2022, the Drug Law Enforcement Agency, The Gambia (DLEAG), seized a total of 734 blocks of cocaine weighing more than 800 kilograms. It was the second-biggest inland seizure of cocaine in The Gambia. According to DLEAG, the bulk of the cocaine was found on a property belonging to one Omar Fofana, a Gambian national and a tourist taxi driver in the Senegambia tourism area.
The case of Banta Keita highlights the challenges authorities face in tracing property and establishing the source of funds used in high-value transactions. The case involved a property linked to alleged criminal proceeds. Although the State has appealed the case after the High Court dismissed it, the circumstances of how the property was purchased beg for fuller inquiry.
Again, the ongoing Paulo Djabi case also highlights the difficulty of tracing ownership and payment flows. Court evidence shows that some properties allegedly linked to Djabi and his associates were purchased through third parties and other arrangements rather than directly in Djabi’s name.
Meanwhile, a 46-year-old Braima Seidi Bá, a Bissau-Guinean national, dubbed the country’s most notorious criminal entrepreneur, fled Bissau in late 2019 for sanctuary in The Gambia. He was eventually tried and convicted in absentia for allegedly orchestrating the importation of 1,869 kilograms of cocaine in Bissau.
A report by the Global Initiative Against Transnational Organised Crime (GI-TOC) indicates that Seidi Ba made himself inconspicuous in The Gambia by investing in properties, including a hotel and another luxurious holiday apartment in the Senegambia area, Kololi.
Gambia’s Real Estate and the Regulatory Framework
First, Article 20 of the United Nations Convention against Corruption (UNCAC) criminalises illicit enrichment, and state parties like The Gambia are encouraged to adopt such a provision to fight corruption and money laundering. The African Union Convention on Preventing and Combating Corruption also prescribes it as an offence.
The Gambia’s Anti-Money Laundering and Combating of Terrorist Financing Act, 2012, requires real estate businesses to conduct customer due diligence before doing business with them. This includes verifying the customer’s identity, contact details, national identification card, and tax identification number.
Due diligence is central to The Gambia’s Anti-Money Laundering and Combating of Terrorist Financing Act, 2012. The law requires real estate agents, lawyers, and related professionals to properly identify and verify every client before carrying out any property transaction. Section 3.6.10 of the Act also requires these professionals to keep detailed records of all customer checks and transactions for at least five years.
The 2016 Guidelines build on this by requiring strict customer due diligence for all property transactions, especially those above GMD 200,000, and by outlining extra checks for high-risk clients or unusual transactions. The Guidelines also highlight warning signs such as rapid resale, use of false names, or unexplained sources of funds that should prompt professionals to investigate further and report any suspicious activity.
Additional requirements apply to foreign nationals, such as proof of residence, valid foreign identification documents, and a bank statement or passbook showing the current address. Gambians living abroad may also be required to provide their country and address of residence, foreign contact details, and proof of address.
Anyone interested in buying a property must also disclose the source of their funds, under certain circumstances because of the risk involved.
Our investigations reveal that these laws are not always applied, including by some of the most high-profile real estate owners.
Due Diligence Gap
During the investigation, DUBAWA attempted to assess whether real estate companies in The Gambia conduct due diligence on prospective buyers.
To do this, our reporter posed as a prospective foreign buyer using a European name. She emailed several real estate companies and said she intended to purchase property. The companies include Blue Ocean Properties, GamRealty Real Estate, Global Properties, Songhai Properties Company Limited, TAF Africa Global, Swami India International Limited, and Leigh Properties.
Our reporter also worked with Gambians living in the diaspora who acted as prospective buyers and expressed interest in purchasing property from the companies. She also posed as a third party to buy land from one of the estate agencies. The goal was to examine the companies’ documentation process and the background checks they conduct on prospective buyers.
The findings were mind-boggling.
Although all seven real estate companies requested identification documents, it stopped at basic identification.
Using the pseudonym “Alexander Muller”—a foreign buyer who posed as a prospective buyer— initiated a transaction with Swami India International Limited. The company requested only his full name, a copy of an ID or passport, residential address, contact number, and email address.
For a buyer living abroad, these requirements are basic identification. Other requirements include scrutinising non-financial businesses and adopting extra measures to conduct background checks where the circumstances require it.
For certain higher-risk relationships and transactions, the guidelines require businesses to establish the source of funds and source of wealth. The guidelines also require adequate identity verification and, where applicable, the identification and verification of beneficial owners and persons acting on behalf of customers.
Meanwhile, the company never asked the prospective buyers to explain the sources of their funds. Both were interested in buying a two-bedroom luxury property at the company’s Airport Complex for US$79,500.
Blue Ocean Properties shared a registration form that included a payment plan and buyer information. Under the buyer details, the company requested the buyer’s name, address, country, postcode, identification number, contact number, email address and occupation. It also requested next-of-kin details, including name, address, contact number and relationship. Furthermore, the company requested the buyer’s solicitor’s business details, including the firm’s name, address, contact number and email address.
These requests covered several elements of customer identification and verification expected under the Anti-Money Laundering and Combating the Financing of Terrorism framework. But the form did not request information establishing the source of the funds or wealth being used for the proposed purchase. The prospective buyer expressed interest in purchasing a two-bedroom property at Waterfront Views, priced at US$125,000.
In a WhatsApp conversation with a Gambian in the diaspora who also posed as a prospective buyer alongside a foreign woman, TAF Africa Global requested the buyer’s name and his companion’s name, a copy of a passport or ID, a home address, and an email address. In a separate exchange with the reporter posing as the foreign buyer “Alexander Muller”, the company requested only a copy of his passport and address.
While the identification requests were consistent with basic customer due diligence, neither exchange included a request for information establishing the source of funds for the intended purchase. In the case involving two prospective buyers, the company failed to ask for information that clarifies the ownership arrangement beyond their names; the prospective buyers expressed interest in a two-bedroom luxury apartment at TAF City Gunjur, priced at US$98,600.
In an email, GamRealty real estate stated that for the initial reservation and purchasing process, it normally requires a clear copy of a valid passport, the prospective buyer’s current residential address and contact details, preferred ownership names, and any additional identification or compliance documents requested by the developer, seller, bank, or legal representative. The agency subsequently provided a sale agreement for a prospective purchase of a two-bedroom Fajara View apartment priced at US$224,500. The agreement was comprehensive and involved the developer, buyer, and agency.
However, during the exchange, the company did not ask the buyer for information about the source of funds or other financial details before proceeding with the prospective purchase. The identification requirements addressed part of the customer due diligence process, but failing to inquire about the source of the proposed US$224,500 largely indicated a flaw in the process.
In a WhatsApp conversation, Leigh Properties requested our reporter to tender only a copy of her passport. Under the Act guidelines, identification and verification requirements extend beyond simply obtaining an identity document. When a person acts on behalf of another, the authority of that person and the relevant parties must also be adequately verified.
The guidelines specifically require adequate verification of power of attorney and third-party mandates, where applicable. While interacting with Leigh Properties, the company requested only the prospective buyer’s passport and never asked for the source of funds, documentation establishing authority, or the third party’s underlying ownership arrangement. The prospective buyer expressed interest in purchasing one of the vacant plots at Yuna Estate Phase 2, priced at D650,000, approximately US$8,777.
Global Properties also requested only a copy of the buyer’s identification document and Tax Identification Number when our reporter posed as a prospective buyer interested in purchasing a two-bedroom luxury apartment at Seaview in Fajara, priced at US$224,500. The request provided basic identification and tax information, but the company did not ask the prospective buyer for information establishing the source of funds for the proposed purchase.
The Act framework requires real estate companies and agents to conduct customer due diligence and maintain information necessary to understand their customers and transactions, with enhanced measures required where higher risks are identified.
Songhai Properties Company Limited, meanwhile, requested only a copy of an identification document or passport from a prospective buyer interested in purchasing a property in Bijilo. The company quoted a construction cost of D6,000,250 (six million, two hundred and fifty dalasis), approximately US$85,600; meanwhile, an empty plot of land in a Seaview location in Bijilo was priced at D6.8 million (six million, eight hundred thousand dalasis), approximately US$97,000. The request for identification addressed only the most basic part of customer due diligence. The company did not request information establishing the source of funds for either proposed transaction, despite the properties’ value. The Act guidelines require real estate businesses to conduct appropriate customer due diligence and, where circumstances warrant enhanced due diligence, establish the source of funds and source of wealth.
The companies’ failure to go beyond basic identification in these transactions raises compliance concerns under The Gambia’s anti-money laundering and combating the financing of terrorism (AML/CFT) framework. The law requires real estate companies to conduct customer due diligence and document the information obtained. Meanwhile, the Financial Intelligence Unit guidelines require enhanced due diligence when higher risks are identified.
Failure to comply with the Act’s requirements can attract penalties and, depending on the offence, criminal charges. The guidelines also provide for sanctions against real estate companies that fail to comply with their obligations. These requirements are intended to prevent real estate businesses from being used to conceal the source or ownership of illicit funds.
However, a separate property owner near Palma Rima Junction argued that the source of funds was not important, only the person making the purchase and their preferred method. The property was listed at $400,000.
In almost all the companies DUBAWA interacted with, property prices were quoted in foreign currencies.
According to Central Bank Governor Buah Saidy, the Gambian Dalasi remains the sole legal tender of The Gambia. Under the Central Bank of The Gambia Act’s regulatory oversight, demanding, forcing, or contractually enforcing payments in foreign currencies for local transactions is explicitly illegal and punishable by law.
The Central Bank of The Gambia has issued strict warnings targeting real estate agencies, property developers, and landlords who quote prices or demand rent payments in U.S. Dollars, Euros, or CFA Francs. Saidy said foreign currency should be reserved for international trade, and forcing local consumers to source foreign exchange for domestic assets undermines the dalasi and threatens The Gambia’s monetary sovereignty.
Real Estate AML Requirements
An image showing the Act’s requirements and the criteria each real estate company met. Photo Source: DUBAWA
The above table shows what The Gambia Anti-Money Laundering Law requires real estate companies to do when dealing with property buyers. From the table, 100 per cent of the companies DUBAWA contacted requested basic identification (valid passport or ID card); 57 per cent asked for the prospective buyer’s residential address; and 57 per cent asked for contact details. Only one company (14%) asked for the buyer’s TIN and employment details. None of the companies asked for proof of address, source of funds, bank statement, or even a driving licence.
Removing The Veil
After receiving responses from all the companies undercover, DUBAWA decided to remove the veil as part of our ethical obligations by asking the companies upfront why they did not comply with the regulatory framework as set out in the laws of The Gambia.
Following the investigation’s findings, seven real estate companies were allowed to respond and explain their customer identification procedures and due diligence practices under the Act.
Seven companies- Leigh Properties Plus, TAF Africa Global, Blue Ocean Properties, Swami India International Limited, Global Properties, GamRealty and Songhai Properties responded, outlining the additional checks they said they conduct as property transactions progress.
The Chief Operating Officer of Leigh Properties Plus Ebou Jaw, admitted to the DUBAWA that the company does not investigate the exact source of a buyer’s funds because that responsibility rests with the banks, which are the channels of payment. He said these banks conduct their own anti-money laundering checks before paying. He was quick to add that they verify identification details before executing any binding sales agreement or land transfer document.
TAF Africa Global, on their part, said it is normal practice for them to collect identification documents or passports at the initial stage. The company’s Deputy Managing Director, Ya Bajen Njie, said the company also addresses additional source-of-funds or source-of-wealth documentation as transactions progress, in accordance with applicable requirements and legal advice. She added that the company consults its lawyers on legal and regulatory matters, particularly transaction documentation.
Blue Ocean Properties said the registration form provided during the inquiry was an initial document used to collect buyers’ particulars, proposed purchase details and solicitor information.
Its Managing Director, Abubakar Bensouda, said the company has a written anti-money laundering and counter-terrorist financing policy, as well as a standard legal questionnaire sent to buyers’ solicitors after the reservation form and passport copies have been submitted and a reservation fee paid.
He said source-of-funds checks are conducted through the due diligence questionnaire before the sale agreement is signed, with supporting documents requested where required by the buyer’s risk profile.
Like Leigh Properties Plus, the Sales and Marketing Manager of Swami India International Limited said property payments are made through bank-to-bank transfers, with the relevant banks responsible for carrying out the required verification.
Hardik H. Joshi, said that at some stage of a transaction, both the sender’s and receiver’s banks may request a copy of the sales agreement showing the purpose of the payment.
On background checks, Joshi said the company follows The Gambia’s rules and regulations.
Global Properties said it conducts property transactions in stages, with the required information and documentation depending on the nature and stage of the proposed transaction.
Its General Manager, Nyillan Fye, said prospective purchasers are ordinarily asked at the preliminary enquiry stage to provide basic identification information and documentation, including a valid form of identification and Tax Identification Number (TIN). She said this allows the prospective transaction to be documented and relevant sale documentation to be prepared, but added that an initial discussion with a sales representative does not complete the company’s due diligence or transaction process.
Fye said that before a transaction is concluded, the relevant contractual documentation must be completed and executed, and payments must be made through recognised banking channels and are therefore subject to applicable compliance and anti-money laundering requirements of the financial institutions involved. She said these banking controls form part of, but do not replace, the company’s own procedures.
GamRealty also responded, saying it acted solely as a real estate agent in the enquiry involving The View Fajara and was not the developer or seller of the property.
The company’s CEO, Joop Logger, said the enquiry was at a preliminary stage and that GamRealty did not handle the prospective buyer’s funds or complete the transaction. He said that after the prospective buyer requested a draft sale agreement, GamRealty forwarded the request to EHF Ventures, the developer, which then dealt directly with the prospective buyer.
Songhai Properties said it does not have an internal system or specialised process to independently verify the ultimate source of a buyer’s funds beyond the documentation and banking processes involved in a transaction.
The company’s CEO, Sulayman Keita, said international customers generally do not transfer funds directly to Songhai Properties from overseas. Instead, he said, many customers transfer funds into their own local bank accounts in The Gambia before making payment for the property. He said sales agreements are normally used by customers when dealing with their banks as supporting documents to verify that the funds are intended for the purchase of property.
So what does the regulator think about all this?
DUBAWA’s investigation prompted the Financial Intelligence Unit (FIU) to provide information regarding the real estate sector. The FIU stated that real estate companies and agents in The Gambia are designated non-financial businesses and professions (DNFBPs) and are subject to the country’s anti-money laundering and combating the financing of terrorism (AML/CFT) requirements.
The FIU said customer due diligence goes beyond collecting a passport or national identification document. Depending on the nature and risk of a transaction, real estate businesses are expected to obtain sufficient information to understand the customer, the purpose and nature of the transaction, ownership and control, and the circumstances surrounding it.
The unit said the absence of a source-of-funds question during an initial interaction does not, by itself, establish a breach of the law. However, Section 25(4) of the Anti-Money Laundering and Combating of Terrorist Financing Act, 2012 requires reporting entities to take reasonable measures to establish the purpose, origin and ultimate destination of cash transactions exceeding US$10,000 or its equivalent in Gambian dalasis.
The FIU also said businesses must pay particular attention to complex, unusual, or large transactions and unusual patterns with no apparent economic or lawful purpose, and examine their background and purpose.
Regarding the seven real estate companies examined, the FIU said it would treat the information provided as relevant to its supervisory and compliance functions and may undertake further enquiries or compliance action where appropriate.
Stakeholders Perspective
Abubacar Darboe, proprietor of BB Consultancy and Secretary General of the Association of Real Estate Companies of The Gambia, said the rapid growth and increasing value of land have made real estate one of the country’s largest investment sectors, but also vulnerable to illicit financial flows.
“Real estate is one of the safest avenues for laundering proceeds of crime,” he said, explaining that property can serve as a long-term investment that conceals the origin of illicit funds.
Picture of Abubacar B.B Darboe, Secretary General of the Association of Real Estate Companies of The Gambia. Photo Credit: DUBAWA.
Darboe said individuals seeking to launder illicit wealth may buy multiple properties in a short period or acquire shares in existing real estate companies. He said hotels, apartment complexes and other large property developments are particularly attractive because they involve substantial investments while attracting less public attention than luxury vehicles.
He added that cash transactions remain common in the sector, as many buyers prefer face-to-face payments and physical receipts. This practice goes against The Gambia’s anti-money laundering rules, which require lawyers and real estate companies to verify a buyer’s identity and source of funds, report anything suspicious, and be careful with large cash payments.
While estate agencies are expected to conduct due diligence on property buyers, banks also serve as a key checkpoint in tracking the flow of funds linked to real estate transactions.
Alieu Ndow, Executive Secretary of the Gambia Bankers Association (GBA), said banks play a frontline role in detecting and preventing money laundering because many financial transactions pass through the banking system. He explained that banks rely on Know Your Customer (KYC) procedures to understand customers’ identities, occupations, businesses, expected income, and sources of funds.
“Businesses that rely heavily on cash transactions, including real estate, petroleum and motor vehicle sales, are generally considered higher risk because they are more vulnerable to money laundering,” Ndow said.
A Picture of Alieu Ndow, Executive Secretary of the Gambia Bankers Association. Photo Credit: DUBAWA
Ndow stated that banks compare customers’ transactions against their public financial profiles. If major inconsistencies arise, customers must provide explanations and supporting documents. In property transactions, he said banks examine documents such as sale agreements and transfer records to verify the legitimacy of funds. Meanwhile, large cash deposits face additional scrutiny because they are harder to trace.
The GBA Executive Secretary further stated that suspicious transactions are reported to the Financial Intelligence Unit (FIU) for further investigation. However, he noted that “The Gambia remains a largely cash-based economy,” which makes tracking financial transactions and verifying the source of funds more challenging.
Conclusion
The findings of this investigation show a gap between The Gambia’s anti-money laundering requirements and the due diligence practices encountered by prospective property buyers. While the law requires real estate businesses to identify and verify customers and, where necessary, establish the source of funds, several companies approached during the investigation did not ask prospective buyers about the origin of the money they intended to use. Cases involving properties linked to alleged proceeds of crime also show why property transactions require closer scrutiny.
The responsibility extends beyond individual estate agencies. The Financial Intelligence Unit, law enforcement agencies, banks, lawyers and other relevant institutions all have roles in ensuring that anti-money laundering requirements are followed. Without effective monitoring and enforcement, the real estate sector remains vulnerable to illicit financial flows and unclear property ownership.