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As evidenced in the mutual evaluation findings of the FSRBs, Sub Sahara African countries scored lower-level effectiveness in the field of AML/CFT/CPF. As of 24th February 2023, among the 23 jurisdictions under FATF’s increased monitoring (commonly known as grey list), 10 (about 43.48%) were African countries and 7 (30.43%) are from the ESCAY (Eastern, Central and Southern Africa and Yemen) region.

The FATF, in its Recommendation 40 and Immediate Outcome 2, encourages FIUs to cooperate and coordinate their responses to effectively mitigate risk of ML/TF/PF. In this regard, the EU and AML/CFT ESCAY Project, in collaboration with the Financial Intelligence Unit (FIU) of Zimbabwe, organized a forum on 9th and 10th October 2023 in Harare, Zimbabwe for delegates from different FIUs to share expertise, promote effective regional, interregional and international cooperation in the fight against illicit financial flows (IFFs) and money laundering linked to Transnational organised crime (TOC) and terrorist groups.

In our effort to support the region and promote exchange of information and expertise, an officer from the Financial Investigative Analysis Division was nominated to represent FIU Mauritius in the forum.

During the forum, the delegates from 34 countries:

i. Deliberated on selected thematic areas about FATF standards on effectiveness and the challenges of national AML/CFT/CPF system to comply with the international standards;

ii. discussed on the one-year accomplishments of the AML/CFT ESCAY Project, challenges encountered and way forward;

iii. outlined the way forward on capacity building support areas in order to strengthen national AML/CFT/CPF systems, deter TOC and IFFs and

iv. participated in bilateral discussions which focused on signing of memorandum of understandings (MoUs) and enhancing exchange of information between FIUs.

Based on the discussions, it was noted that most of the countries in the ESCAY region were grey listed due to:

  1. Very poor compliance with the FATF standards
    • 20 or more NC/PC ratings for technical compliance;
    • NC/PC on 3 or more of the following Recommendations: I. R.3 – Criminalisation of Money Laundering II. R.5 – Criminalisation of the financing of terrorism III. R.6 – targeted financial sanctions on terrorism and terrorist financing IV R.10 – Customer due diligence V. R.11 – Record Keeping; VI. R.20 – Suspicious Transaction Reporting
  2. Low or Moderate level of effectiveness for 9 or more of the 11 Immediate Outcomes, with a minimum of two low level ratings.

Moreover, it was concluded that countries fail to exit the ICRG process due to the following:

  1. the lack of political commitment and institutional capacity;
  2. lack of coordination among competent authorities and their inability to mobilise and provide the requisite information in a timely manner;
  3. lack of understanding of the requirements of the ICRG process and the information needed;
  4. shortcomings in supranational legal and institutional frameworks;
  5. lack of prioritisation of the action plan items, particularly those not requiring interventions from supranational authorities; and
  6. Low level of engagement with the FSRBs, namely ESAAMLG, GIABA and GABAC.

During the bilateral discussions, the representative of FIU Mauritius engaged with the delegates from FIU Comoros, Uganda, Sierra Leone, Democratic Republic of the Congo, Malawi and Central African Republic whereby topics such as domestic information sharing, GoAML software, standard operating procedures and memorandum of understandings were discussed.

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