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On 13th June, regional FATF-style body, ESAAMLG, though its Council of Ministers of ESAAMLG adopted this report on 4th June.  The on-site visit by the evaluation team took place in June/July 2018.  As with many other jurisdictions, the report notes that the number of money laundering investigations and prosecutions relative to the predicate offences reported and processed, is low, and it also says that the penalties imposed in successful cases are not effective, dissuasive, and proportionate and the number of confiscations of criminal proceeds, instrumentalities and property of corresponding value are low and is not done as a policy objective.  It says that there is no adequate legal and regulatory framework to obtain and maintain beneficial ownership information on legal arrangements neither has there been a comprehensive money laundering/terrorism financing risk assessment on all forms of legal persons.  Zambia needs to expedite completion and implementation of a National AML/CFT Strategy involving both the public and private sector, and provide adequate resources to regulators etc.  It is said that it needs a national policy which ensures confiscations of criminal proceeds, instrumentalities and property of corresponding value are executed as a priority for the relevant law enforcement agencies and that efforts are focused on the predicate crimes which are identified as high-risk in the national risk assessment, notably as well as cases where the proceeds of crime have moved to foreign countries.

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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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