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The Central Bank of The Gambia (CBG) has directed commercial banks to replace non-Gambian employees who are not covered by approved expatriate quotas, triggering debate over the implications of the policy for regional labour mobility and West Africa’s financial sector.
The regulator has given affected banks until December 31, 2026, to replace the employees with qualified Gambian nationals.
The directive applies to all commercial banks operating in the country, including Nigerian-owned institutions such as Access Bank, FirstBank, Guaranty Trust Bank and Zenith Bank, as well as regional lenders including Ecobank.
According to the CBG, the directive followed an industry-wide review that identified a “relatively high number” of non-Gambian employees working in banks in addition to those formally recognised under expatriate employment quotas.
The central bank said the practice is inconsistent with The Gambia’s Labour Act 2023 and Guideline 9 governing expatriate employment within the banking industry.
Banks have been instructed to identify qualified Gambians capable of taking over the affected positions, develop succession plans and transfer the relevant skills and institutional knowledge needed to support the transition.
The CBG also directed banks to ensure the process does not disrupt their operations or the delivery of financial services.
Directive raises regional labour mobility concerns
While the central bank has framed the directive around compliance with existing employment rules and the development of local capacity, the move has attracted criticism from commentators who question its potential impact on regional labour mobility.
Gambian commentator Alpha Bah questioned the tension between African countries advocating greater freedom of movement for Africans outside the continent while introducing restrictions on the movement of African professionals within Africa.
Bah argued that the treatment of African migrants should be assessed according to the same principle regardless of whether restrictions are imposed by a Western government or an African government.
The debate comes against the backdrop of increasing regional integration across Africa, with banks and other financial institutions operating across multiple markets and frequently deploying employees between subsidiaries.
Concerns over local talent and banking efficiency
Nigeria-based financial analyst and economist Chukwunonso Ihuoma questioned whether The Gambia has sufficient qualified professionals to replace all the affected workers without affecting banking efficiency.
“Does The Gambia have enough qualified local talent to replace the affected workers without reducing banks’ efficiency?” Ihuoma asked.
He argued that where suitable local replacements are unavailable, a rapid localisation process could increase costs, disrupt operations and affect regional financial integration.
“This kind of order can raise banks’ transition costs. Clearly, replacing experienced employees within a short period of time requires recruitment, training, compensation changes and knowledge transfer programmes. Those costs may outweigh any savings from reducing expatriate employment,” he said.
Emerging markets analyst Ike Ibeabuchi similarly raised concerns about the possible loss of specialised expertise, particularly in areas requiring significant technical and industry experience.
He identified treasury, cybersecurity, risk management, technology and compliance among banking functions where specialised expertise can be critical to operations.
“If qualified local replacements are unavailable, forcing rapid replacement may weaken operational capacity,” Ibeabuchi said.
Regional banks face potential adjustment costs
Ibeabuchi also pointed to the potential implications for pan-African banking models, where financial institutions routinely move experienced employees between subsidiaries to support operations and transfer expertise.
“Nigerian banks and other pan-African lenders commonly move experienced employees between subsidiaries,” he said, adding that restricting such flexibility could make regional operations more expensive and less efficient.
He also warned that competition among banks for a limited pool of qualified Gambian professionals could increase recruitment costs and put upward pressure on salaries for scarce skills.
“If several banks compete for the same pool of qualified Gambian professionals, salaries for scarce skills could rise. That could offset some of the expected savings from localisation,” he argued.
Beyond immediate staffing costs, Ibeabuchi said the policy could also influence how multinational and regional banks assess regulatory conditions when considering future investments.
“Again, if multinational and regional banks perceive employment rules as unpredictable or excessively restrictive, they may factor that regulatory risk into future investment and expansion decisions.”
The CBG’s December 2026 deadline now gives banks a defined period to identify local replacements, implement succession arrangements and transfer institutional knowledge while maintaining continuity across the banking sector.
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