Gambia Orders Nigerian Banks, Others to Replace Foreign Staff by December 2026
By Aboki Forex —
The Central Bank of The Gambia has ordered commercial banks, including Access Bank, Guaranty Trust Bank (GTBank), FirstBank, Zenith Bank and Ecobank, to replace non-Gambian employees with suitably qualified Gambian nationals by December 31, 2026. The directive came in a circular dated September 16 and signed by CBG Second Deputy Governor Dr Paul J. Mendy.
The order followed a meeting between the central bank and managing directors of commercial banks on August 27, as well as an industry-wide review of how banks employ foreign personnel. The CBG said the review uncovered a "relatively high number" of non-Gambians working in banks beyond those covered by recognised expatriate arrangements.
Phased replacement, skills transfer
The regulator said the situation violates The Gambia's Labour Act 2023 and is inconsistent with Guideline 9, which governs how banks employ expatriate staff. It directed all banks to adopt a phased approach to replacing existing non-Gambian staff with qualified Gambian nationals.
The CBG said: "Consequently, all banks are required to adopt a phased approach to replacing existing non-Gambian staff with suitably qualified Gambian nationals, with appropriate arrangements for skills transfer and continuity of operations."
Banks must also ensure that as positions are localised, the transition does not cause the loss of critical institutional knowledge or disrupt day-to-day banking services. Each bank is expected to identify suitably qualified Gambian nationals who can fill affected roles as the transition progresses.
Law, quota and penalties
The directive draws on Section 38(1) of the Labour Act, which requires any employer granted an expatriate quota to hire a Gambian understudy for that role. The provision is meant to ensure research, technology and skills are transferred to local workers over time. The law also says the Expatriate Quota Board should not approve an expatriate quota for any role where the required skills already exist within The Gambia.
Employers who bring in foreign workers without the necessary quota clearance, or who fail to renew an existing one, risk a fine of at least 500,000 dalasis upon conviction. The same penalty applies to employers who do not assign a Gambian understudy to an expatriate employee.
The legal framework stops short of banning expatriate employment entirely. Instead, it ties such employment to regulatory approval and places an obligation on employers to build local capacity. The CBG circular did not name any individual bank as being in breach of the rules. It also did not single out Access Bank, GTBank, FirstBank, Ecobank or Zenith Bank for non-compliance. The directive is an industry-wide measure requiring all commercial lenders to align their workforce structures with existing labour laws.
What it means for Nigerian lenders
The affected Nigerian lenders were contacted for comment on the directive but requested additional time to respond. The development comes as Nigerian banks are spending more to attract and retain workers. An analysis of the 2025 audited financial statements of Access Holdings, United Bank for Africa (UBA), Zenith Bank and Wema Bank shows the four lenders increased their combined workforce by 12.75% to 33,675 employees. Their total wages and salaries rose 27.49% to N1.05 trillion. The surge in compensation comes as banks battle inflation and rising living costs.