On 26th July, Mmegi Online reported that a fresh review assessing Botswana’s vulnerability to money laundering has noted improvements in 32 out of 40 areas of concern that caused the country’s blacklisting by global groups.  FATF grey-listed Botswana in October citing institutional and structural deficiencies in the country’s AML defences, and the EU blacklisted Botswana in February, citing weak systems.  The article says that FATF-style regional body ESAAMLG, whose adverse 2017 assessment of Botswana resulted in the negative listings, recently finalised an update showing an improvement – Botswana has until 2020 to rectify the deficiencies involved.  Botswana is said to have improved in the majority of the 40 concerns and recommendations made in 2017, with improvements elsewhere that nevertheless did not justify a rerating.  It is said that the best improvement was in respect of FATF  Recommendation 5, where evaluators had originally noted weaknesses in the local laws around criminalising terrorism financing.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

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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