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.
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