The Central Bank of The Gambia (CBG) has directed commercial banks to replace non-Gambian employees who are not covered by approved expatriate quotas, giving lenders until December 31, 2026, to comply with the directive.
The order has sparked debate over its potential implications for regional banking operations and the free movement of African workers within West Africa.
The directive applies to all commercial banks operating in The Gambia, including Nigerian-owned lenders such as Access Bank, FirstBank, Guaranty Trust Bank and Zenith Bank, as well as other regional institutions including Ecobank.
The CBG said the directive followed an industry-wide review that identified a “relatively high number” of non-Gambian employees working in the banking sector in addition to those formally recognised as expatriates.
According to the regulator, the practice contravenes provisions of The Gambia’s Labour Act 2023 and Guideline 9 governing expatriate employment in the banking industry.
Under the directive, banks are required to identify qualified Gambian nationals to take over the affected positions, develop succession plans and ensure the transfer of relevant skills and institutional knowledge.
The banks have also been instructed to ensure that the transition does not disrupt their operations.
However, the decision has attracted criticism from some commentators and analysts who questioned its potential impact on regional labour mobility, banking efficiency and the cost of replacing experienced workers.
Gambian commentator Alpha Bah questioned what he described as the inconsistency between African countries advocating greater freedom of movement for Africans abroad while imposing restrictions on African workers within the continent.
Bah argued that the treatment of African migrants should be considered under the same principles, regardless of whether restrictions are imposed by Western countries or African governments.
A Nigeria-based financial analyst and economist, Chukwunonso Ihuoma, questioned whether The Gambia had enough qualified professionals to fill the affected positions without affecting banking efficiency.
“Does The Gambia have enough qualified local talent to replace the affected workers without reducing banks’ efficiency?” he asked.
Ihuoma said a rushed localisation process could increase costs, disrupt operations and affect regional financial integration if sufficient local replacements were not immediately available.
“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 also raised concerns about the potential loss of specialised expertise, particularly in areas such as treasury management, cybersecurity, risk management, technology and regulatory compliance.
“If qualified local replacements are unavailable, forcing rapid replacement may weaken operational capacity,” he said.
Ibeabuchi noted that Nigerian banks and other pan-African financial institutions routinely deploy experienced employees across their subsidiaries as part of their regional operations.
“Restricting that flexibility could make regional operations more expensive and less efficient,” he said.
He also warned that increased competition among banks for a limited pool of qualified Gambian professionals could drive up salaries for specialised 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 said.
Ibeabuchi further argued that uncertainty over employment regulations could influence investment decisions by multinational and regional financial institutions.
“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,” he said.
The directive comes against the backdrop of regional efforts to promote economic integration and facilitate the movement of people and businesses across West Africa, while governments continue to pursue policies aimed at increasing employment opportunities for their citizens.



