Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Zambia ZM

Domains covered

8 of 8

Sources

160

Role actions

Horizon <90d

Jurisdiction profile

FATF status: Clean Tier: B Risk direction: Stable Enablement vs enforcement: Mixed

Zambia's AML/CFT regime rests on the FIC Act and 2017 Companies Act, assessed by ESAAMLG's 2019 MER and follow-up reports (2022, 2024).

Zambia is not FATF grey-listed but remains in enhanced follow-up with unresolved technical-compliance gaps on beneficial ownership, DNFBP supervision, and TF/PF targeted financial sanctions implementation.

Key deficiencies

Beneficial ownership verification remains largely manual, with most financial-crime investigators lacking automated access to PACRA company data
Trust beneficial-ownership returns are legally required only every five years and are rarely filed in practice, per the 2019 MER
DNFBP AML/CFT supervision had not commenced at the time of the MER and re-ratings show only partial progress since
FIU (Financial Intelligence Centre) and Anti-Corruption Commission board leadership is presidentially appointed, creating structural exposure to political interference in high-level corruption cases
Resource constraints limit financial-crime investigative and prosecutorial capacity relative to case complexity

Recent developments (18m)

UNCAC Conference of States Parties review (December 2025) documents continued PACRA beneficial-ownership reform progress alongside persistent manual-access bottlenecks
Bloomberg reporting (April 2025) on alleged retaliation against a Finance Ministry whistleblower renewed scrutiny of the durability of Zambia's anti-corruption commitment under President Hichilema
EU Commission's December 2025 high-risk third-country list update left Zambia unlisted while delisting regional neighbours Mozambique, Tanzania and South Africa, shifting comparative regional risk perception
FATF's October 2025 and February 2026 plenaries did not add Zambia to the increased-monitoring list, while several ESAAMLG peers moved on/off that list

Brief

Lead signal

Lead Signal

Zambia has moved its anti-money-laundering architecture forward on two fronts this cycle, both structural rather than incident-driven. The Banking and Financial Services Act, 2026 (Act No. 9 of 2026) repeals and replaces the Banking and Financial Services Act, Cap. 387, and repeals the Money-lenders Act, Cap. 398, consolidating banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia licensing and supervisory regime. The consolidation brings previously fragmented oversight, including anti-money-laundering and counter-terrorist-financing duties that had been split across the repealed instruments, into one framework. The Act itself has not yet commenced: its own savings clause preserves existing licences, pending applications and accrued liabilities pending a commencement order, so the practical supervisory effect is still prospective rather than current.

Read full brief

Lead Signal

Alongside the banking-sector consolidation, Zambia has lowered its beneficial-ownership disclosure threshold. The Companies (Amendment) Act No. 23 of 2025, in force since 30 December 2025, revises the beneficial-owner definition to capture a 5 percent ownership stake, a materially lower bar than the 25 percent threshold common internationally. The Patents and Companies Registration Agency is understood to be digitising its beneficial-ownership register in partnership with Open Ownership and the German development agency GIZ, though the underlying statutory text has not itself been retrieved this cycle, and the finding rests on secondary legal commentary rather than the Act as gazetted.

Other Developments

Crypto-asset oversight remains unchanged in substance. The Bank of Zambia's March 2026 registration exercise for virtual-asset service providers, which closed on 27 March 2026, was explicit in its own public notice that registration is a preliminary step and does not amount to a licence or official approval to operate. That exercise sits alongside the Financial Intelligence Centre's 2022 VASP Sector Guidelines, which already impose a ten-year record-retention duty on virtual-asset service providers under the FIC (General) Regulations. No instrument has superseded either this cycle, so the operative crypto framework is a registration-not-licensing regime layered onto pre-existing record-keeping obligations.

Zambia's standing with the Financial Action Task Force has not changed. As of the 19 June 2026 plenary, Zambia appears on neither the increased-monitoring list nor the list of countries subject to a call for action. The next mutual evaluation on-site visit under the Eastern and Southern Africa Anti-Money Laundering Group is slated for 2028, and Zambia's own regional body page records progress against deficiencies identified in its 2019 mutual evaluation and the subsequent follow-up report.

Sanctions exposure continues to run through the United Nations route only. No autonomous Zambian sanctions list has been identified, and screening obligations appear to remain tied to the UN Security Council consolidated list. No Zambia-specific designation by the US Treasury's Office of Foreign Assets Control, the UK's Office of Financial Sanctions Implementation, or the EU Council was located in the course of this cycle, though this finding rests on a single compliance-advisory secondary source rather than a primary sanctions-authority notice.

Cross-Monitor Connections

The consolidation of fintech and e-money licensing under the Banking and Financial Services Act, 2026 has a direct bearing on payments-sector market access: the same instrument that folds anti-money-laundering supervision into one regime also determines which payment service providers may lawfully operate once commencement occurs, a question of live interest to payments-market monitoring. The virtual-asset registration regime likewise sits at the boundary between financial-crime oversight and the commercial development of Zambia's digital-asset sector, since a registration exercise explicitly stopping short of licensure leaves commercial operators in a supervisory grey zone that a parallel payments or fintech-commercial lens would track from the market-access side rather than the illicit-finance side.

Outlook

The near-term question for Zambia's anti-money-laundering architecture is commencement: the Banking and Financial Services Act, 2026 was enacted but, as at this cycle, had not been brought into force by statutory instrument, and its practical supervisory reach, including for anti-money-laundering purposes, depends on that step. Separately, the beneficial-ownership threshold reduction to 5 percent, if borne out once the Act's own text is confirmed against a primary register source, would place Zambia's corporate-transparency regime ahead of the international norm on this specific metric, though the claim currently rests on secondary commentary alone. Zambia's absence from both Financial Action Task Force public statements is likely to persist absent a new mutual evaluation finding, with the next on-site visit not expected before 2028.

Earlier periodic briefs (6)

25 Oct 2026 · fim-2026-10-25

Lead Signal

Zambia has moved its anti-money-laundering architecture forward on two fronts, both structural rather than incident-driven. The Banking and Financial Services Act, 2026 (Act No. 9 of 2026) repeals and replaces the Banking and Financial Services Act, Cap. 387, and repeals the Money-lenders Act, Cap. 398, consolidating banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia licensing and supervisory regime. The consolidation brings previously fragmented oversight, including anti-money-laundering and counter-terrorist-financing duties that had been split across the repealed instruments, into one framework. The Act itself has not yet commenced: its own savings clause preserves existing licences, pending applications and accrued liabilities pending a commencement order, so the practical supervisory effect is still prospective rather than current.

Alongside the banking-sector consolidation, Zambia has lowered its beneficial-ownership disclosure threshold. The Companies (Amendment) Act No. 23 of 2025, in force since 30 December 2025, revises the beneficial-owner definition to capture a 5 percent ownership stake, a materially lower bar than the 25 percent threshold common internationally. The Patents and Companies Registration Agency is understood to be digitising its beneficial-ownership register in partnership with Open Ownership and the German development agency GIZ, though the underlying statutory text has not itself been retrieved, and the finding rests on secondary legal commentary rather than the Act as gazetted.

Other Developments

Crypto-asset oversight remains unchanged in substance. The Bank of Zambia's March 2026 registration exercise for virtual-asset service providers, which closed on 27 March 2026, was explicit in its own public notice that registration is a preliminary step and does not amount to a licence or official approval to operate. That exercise sits alongside the Financial Intelligence Centre's 2022 VASP Sector Guidelines, which already impose a ten-year record-retention duty on virtual-asset service providers under the FIC (General) Regulations. No instrument has superseded either, so the operative crypto framework is a registration-not-licensing regime layered onto pre-existing record-keeping obligations.

Cross-Monitor Connections

Outlook

The near-term question for Zambia's anti-money-laundering architecture is commencement: the Banking and Financial Services Act, 2026 was enacted but, as, had not been brought into force by statutory instrument, and its practical supervisory reach, including for anti-money-laundering purposes, depends on that step. Separately, the beneficial-ownership threshold reduction to 5 percent, if borne out once the Act's own text is confirmed against a primary register source, would place Zambia's corporate-transparency regime ahead of the international norm on this specific metric, though the claim currently rests on secondary commentary alone. Zambia's absence from both Financial Action Task Force public statements is likely to persist absent a new mutual evaluation finding, with the next on-site visit not expected before 2028.

11 Oct 2026 · fim-2026-10-11

Lead Signal

Zambia enacted two foundational financial-sector statutes this cycle that, once commenced, will substantially expand the formal AML/CTF supervisory perimeter. The National Payment System Act, 2026 (Act No. 5 of 2026) and the Banking and Financial Services Act, 2026 (Act No. 9 of 2026) were both assented to on 31 March 2026 and gazetted on 8 April 2026, but neither has yet come into force pending a ministerial commencement statutory instrument. The National Payment System Act repeals the National Payment Systems Act Cap 359 of 2007 and moves Zambia from system-level designation toward individual licensing of payment service providers and e-money issuers, carrying with it AML/CFT duties, cyber-incident reporting, capital requirements and customer-fund segregation. The Banking and Financial Services Act consolidates banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia licensing and supervisory framework, repealing the prior Banking and Financial Services Act and the Money-lenders Act Cap 398. Together the two instruments represent a structural architecture shift rather than an incident: the underlying AML/CFT legal base continues to rest on the Financial Intelligence Centre Act No. 46 of 2010, as amended by Act No. 4 of 2016 and Act No. 16 of 2020, and on the Anti-Terrorism and Non-Proliferation Act No. 30 of 2024 together with the National Anti-Terrorism Centre's January 2025 guidelines for sanctions and proliferation-financing screening, but the perimeter those instruments police is set to widen considerably once the 2026 Acts commence.

Zambia's standing with the Eastern and Southern Africa Anti-Money Laundering Group continues on a steady-improvement track. The country remains in enhanced follow-up since its 2019 mutual evaluation report, with a 30 September 2025 follow-up report re-rating Recommendation 2 and Recommendation 16 to Largely Compliant and Compliant respectively, while deficiencies in Recommendation 8 and Recommendation 35 persist. Zambia does not appear among the jurisdictions FATF placed under increased monitoring following its 19 June 2026 plenary.

Other Developments

Fintech and payments commercial flow continued at a steady pace. Lupiya, a Zambian digital lender, closed a disclosed USD 11.25 million Series A round reported 17 February 2026, led by Alitheia IDF and Enygma Ventures. Separately, Airtel Money Zambia and Stanbic Bank Zambia announced a mobile-wallet-on-POS partnership around 2 June 2026, with Stanbic Zambia's Head of Business and Commercial Banking describing the collaboration as part of the bank's ongoing investment programme. Neither disclosed deal carried any attached regulatory review in the reporting reviewed this cycle.

Crypto-adjacent AML architecture remained unchanged. Zambia has no comprehensive virtual-asset-service-provider licensing statute. The Financial Intelligence Centre's 2022 VASP Guidelines continue to designate virtual asset service providers as reporting entities under section 2 of the FIC Act as amended by Act No. 16 of 2020, and the Bank of Zambia continues to supervise virtual-asset businesses on an informal, cautionary basis rather than through dedicated licensing.

Cross-Monitor Connections

The pending commencement of the National Payment System Act and the Banking and Financial Services Act is of direct relevance to the World Payments Monitor's licensing and market-access tracking, since the same two instruments reshape PSP, e-money and bank licensing architecture that payments-focused analysis follows independently. No conflict-finance, extractive-industry or state-capture nexus was identified for Zambia this cycle that would route to the broader fleet's conflict-finance or state-capture monitors.

Outlook

The operative legal position in Zambia today remains the pre-reform framework: the FIC Act and the 2024 Anti-Terrorism and Non-Proliferation Act govern AML/CTF and sanctions screening, while payment system and banking supervision continues under the statutes the 2026 Acts are poised to repeal. Commencement of the National Payment System Act and the Banking and Financial Services Act is expected as scheduled around early 2027, though no commencement statutory instrument had been located this cycle and the timing carries genuine uncertainty. Once commenced, both Acts would meaningfully enlarge the population of entities subject to formal AML/CFT duties, cyber-incident reporting and capital and fund-segregation requirements, and this expansion is the structural development to watch irrespective of any single enforcement action.

4 Oct 2026 · fim-2026-10-04

Lead Signal

Zambia has assented to and gazetted a new National Payment System Act, but the instrument that would actually set its anti-money-laundering architecture in motion has not been made. Act No. 5 of 2026 was assented to on 31 March 2026 and gazetted on 8 April 2026, and the registry entry for the statute marks it Uncommenced. Section 5(1)(e) of the Act gives the Bank of Zambia an express statutory function to monitor payment service providers for purposes of anti-money laundering, countering the financing of terrorism and countering proliferation financing, a function stated only generically in the 2007 Act the new law will eventually repeal. Until a Minister makes the statutory instrument that brings the 2026 Act into operation, Cap. 359 continues to govern, and the expanded monitoring mandate sits in reserve rather than in force. This is the architecture-over-incident reading the record supports this cycle: a legislature has written a broader AML/CFT/PF supervisory mandate for the central bank into law, and the gap between enactment and commencement is itself the signal, not a procedural footnote to it.

The distinction matters because it determines what the Bank of Zambia can lawfully do today versus what it will be able to do once the appointed-date instrument is signed. A payment service provider operating under the current Cap. 359 regime is supervised under a narrower, system-designation-focused framework; the same provider operating after commencement would sit under an explicit AML/CFT/PF monitoring function with a different statutory texture. Reading the gazette date as the operative date would overstate what is currently enforceable in Zambia, and the record as retrieved this cycle does not support a commencement date being set.

Other Developments

ESAAMLG follow-up reporting records incremental re-ratings since the 2019 mutual evaluation. Follow-up reporting under the Eastern and Southern Africa Anti-Money Laundering Group indicates Zambia has been re-rated toward Largely Compliant or Compliant on a number of FATF Recommendations, including Recommendations 10, 16 and 22, since its 2019 mutual evaluation. The FATF country page corroborates a general progress narrative on addressing technical-compliance deficiencies. No new FATF plenary action specific to Zambia was located this cycle, and Zambia continues to sit outside both FATF public lists.

The Financial Intelligence Centre has published its Second National Risk Assessment Report. The FIC Zambia news page records the publication of the Second NRA Report. The underlying content of that report was not independently retrieved this cycle, so the substance of its risk findings cannot be characterised here; what the record supports is the fact of publication itself, which marks a periodic re-assessment point in Zambia's AML/CFT/PF risk-understanding cycle.

Cross-Monitor Connections

The National Payment System Act's expanded monitoring function, once commenced, would sit at the intersection of payments-sector supervision and the AML/CFT/PF perimeter that other monitors track through enforcement volume and typology exposure; a widened statutory monitoring mandate for payment service providers is the kind of structural change that compliance-technology and crypto-integrity trackers elsewhere in the fleet would expect to see reflected in supervisory expectations for screening and transaction monitoring, once in force. No cross-monitor linkage beyond this structural observation is supported by the record retrieved this cycle.

Outlook

The National Payment System Act, 2026 is expected to require a ministerial statutory instrument before its AML/CFT/PF monitoring provisions take effect, with no commencement date confirmed by the record as at this cycle. Until that instrument is made, the Bank of Zambia's express AML/CFT/PF monitoring function over payment service providers remains a reserved power rather than an operative one, and the 2007 Act continues to apply. The appropriate posture for the period ahead is to treat the commencement step itself as the next material event to watch, rather than treating the assent and gazettal dates already passed as the point at which obligations under the new mandate begin.

29 Sep 2026 · fim-2026-09-28

Lead Signal

Zambia has moved on two fronts this cycle, both structural rather than episodic. The Bank of Zambia directed all resident and non-resident entities providing virtual or crypto asset services in Zambia to register with BoZ by 27 March 2026, and from 30 March 2026, BoZ-regulated entities may no longer facilitate transactions to or from an unregistered VASP. This is a first-order architecture-building step, a precursor named in BoZ's own 2024-2027 Strategic Plan as leading toward a comprehensive VASP regulatory framework, rather than an enforcement action against any named party. Separately, Zambia enacted the Banking and Financial Services Act, 2026 (No. 9 of 2026), repealing and replacing the 2017 Act and the Money-lenders Act, and expressly providing for monitoring of compliance with anti-money laundering, counter-terrorism financing and counter-proliferation financing obligations among financial service providers under consolidated Bank of Zambia oversight.

Read together, these are two halves of the same architectural move: Zambia is closing an unmonitored channel in virtual assets while simultaneously consolidating its statutory AML/CFT/CPF supervisory basis for the financial sector as a whole. Neither development is an enforcement episode against a named institution; both are the kind of enablement-and-perimeter work that determines what enforcement becomes possible later.

Other Developments

FATF and ESAAMLG standing. Zambia is not on the FATF list of jurisdictions under increased monitoring as of the reviewed plenaries, and remains in ESAAMLG enhanced follow-up on its 2019 mutual evaluation, continuing to report progress to ESAAMLG. This is a carried-forward status rather than a change, but it frames the two structural developments above: Zambia is building AML/CFT architecture from a position of enhanced follow-up rather than grey-list countermeasures, a materially different starting posture than jurisdictions currently under FATF call for action.

Extraterritorial scope of the VASP directive. The BoZ registration requirement applies to non-resident entities providing virtual-asset services to persons or businesses within Zambia regardless of physical presence, reinforcing the assessment that this is architecture-building with an extraterritorial reach rather than a narrow domestic registration exercise.

Cross-Monitor Connections

The Banking and Financial Services Act, 2026's consolidation of licensing and AML/CFT monitoring duty under Bank of Zambia oversight is directly relevant to world-payments' tracking of Zambia's payments and banking licensing perimeter, given that the same Act underpins BoZ's authority over financial service providers more broadly. The VASP registration directive is separately relevant to crypto's tracking of Zambia's crypto-licensing posture, since the registration mandate is the same underlying instrument crypto is assessing from a licensing-classification lens; this brief foregrounds its AML/CFT-architecture reading rather than its licensing-classification reading.

Outlook

The comprehensive VASP regulatory framework that BoZ has signalled as the next phase beyond registration remains unpublished; no draft licensing or supervisory rulebook text exists as of this cycle, and its expected arrival is estimated for Q2 2027, though this is a wide multi-year uncertainty band. On the banking-sector side, implementing statutory instruments under the Banking and Financial Services Act, 2026 remain pending as of Q4 2026, and industry AML/CTF compliance programmes generally have not yet been re-mapped to the consolidated statutory basis. Watch for the publication of either the VASP framework or the implementing instruments as the events that would convert this cycle's architecture-building into an operational compliance obligation with dated deadlines.

22 Sep 2026 · fim-2026-08-25

Lead Signal

Zambia's 2026 legislative calendar has produced the most structurally significant AML/CFT-adjacent development assessed this cycle: the Banking and Financial Services Act, 2026 (Act No. 9), read together with the National Payment System Act, 2026 (Act No. 5), consolidates banking, microfinance, moneylending and e-money/fintech oversight under the Bank of Zambia within a single licensing, reporting and enforcement framework that carries express provision for monitoring AML/CFT/CPF compliance. This is architecture, not incident: the prior regime split banking, moneylending and payments oversight across a fragmented set of instruments, and the 2026 consolidation broadens the population of entities now subject to a unified Bank of Zambia AML/CFT/CPF compliance-monitoring mandate. The assessment is held at Assessed confidence, reflecting Tier-1 parliamentary sourcing for the statutory consolidation itself, read alongside the acknowledgment that the descriptive AML/CFT baseline remains unchanged beneath this new supervisory architecture. Read against the three-pillar standard, this consolidation is presented in sourcing as an AML pillar-facing reform; no distinct CTF- or CPF-specific provision within the consolidation was separately identified this cycle, and that pillar gap is worth tracking rather than assuming filled by implication.

Other Developments

Beneficial ownership and corporate transparency moved from a standing gap toward an active, if still pre-legislative, remediation this cycle. A partnership between the Zambia registrar PACRA, Open Ownership and GIZ, launched in January 2026, is digitising beneficial-ownership data collection with the stated aim of a public, economy-wide beneficial-ownership register. Legislative amendments needed to complete the reform have cabinet-in-principle approval and IMF technical support but remain subject to further consultation, which keeps this development Assessed rather than Confirmed and structural rather than resolved.

Crypto and digital-asset oversight tightened materially. The Bank of Zambia has directed all resident and non-resident entities providing virtual or crypto-asset services to Zambian users to register with the central bank, with registration due by 27 March 2026 and a transaction-blocking backstop taking effect from 30 March 2026 under which Bank of Zambia-regulated institutions may not process transactions with unregistered virtual-asset service providers. The mandate captures both resident and non-resident providers serving Zambian users, giving it an extraterritorial reach beyond Zambia's borders as an AML/CFT control point. This is a genuine new control point for crypto flows touching Zambia, though its ultimate strength is contingent on the fuller regulatory framework that remains pending further consultation; the finding is corroborated across two independent Tier-3 sources but lacks a directly retrievable Tier-1 Bank of Zambia primary text this cycle.

Standing AMLA architecture. Structurally, the EU's evolving AML Package — the directly applicable AML Regulation (Reg (EU) 2024/1624), the sixth AML Directive transposed per Member State, and the AMLA Regulation (Reg (EU) 2024/1620) establishing the Anti-Money Laundering Authority — continues to shift EU-level supervision from a purely national model toward a hybrid direct/indirect-supervision perimeter. Zambia sits outside that perimeter entirely; its own beneficial-ownership reform this cycle is a domestically-driven PACRA/Open Ownership/GIZ initiative with IMF technical support, not an AMLA-adjacent development, and the two should not be conflated even though both sit within the beneficial-ownership and corporate-transparency typology.

Cross-Monitor Connections

The Banking and Financial Services Act, 2026 and the National Payment System Act, 2026 are shared substrate with the World Payments Monitor, which tracks the same twin statutory overhaul as a licensing and market-access re-founding; the AML/CFT-supervisory-consolidation reading here and the payment-services-authorisation reading there are two lenses on the same underlying instruments. The Bank of Zambia's virtual-asset-service-provider registration mandate is shared substrate with the Crypto monitor, which tracks the same directive as a crypto-licensing and cross-border-reach development; here it is read instead as a new AML/CFT control point pending a fuller supervisory framework.

Outlook

Three threads carry into the next cycle. The Banking and Financial Services Act, 2026 is expected to reach fuller commencement around the third quarter of 2026, at which point the broadened Bank of Zambia AML/CFT/CPF compliance-monitoring population should begin to take practical shape. The PACRA/Open Ownership/GIZ beneficial-ownership project remains pre-legislative; whether the cabinet-approved amendments clear consultation and reach Parliament is the next material marker for Zambia's corporate-transparency posture. And the Bank of Zambia's virtual-asset registration regime remains explicitly interim, pending a fuller licensing and supervisory framework following consultation with now-registered providers — the next cycle's central question is whether that fuller framework begins to take shape or whether the interim registration-and-blocking mechanism becomes the de facto standing regime.

14 Jul 2026 · fim-2026-07-14

Lead Signal

This cycle establishes the first Financial Integrity Monitor baseline for Zambia, a jurisdiction whose anti-money-laundering and counter-terrorist-financing regime rests on the Financial Intelligence Centre Act and the 2017 Companies Act and which remains, per the 2019 ESAAMLG Mutual Evaluation Report and the 2022 follow-up, outside the FATF Increased Monitoring list but still inside ESAAMLG enhanced follow-up with unresolved beneficial-ownership, DNFBP-supervision and targeted-financial-sanctions technical-compliance gaps. The most systemically significant exposure identified this cycle is architectural rather than episodic: mining multinationals and trading intermediaries structure copper and cobalt-adjacent export contracts through offshore trading hubs in Switzerland and Mauritius, using related-party pricing arrangements to shift taxable profit outside Zambia and erode the mineral-revenue base of the country, a pattern sustained by weak beneficial-ownership verification and customs capacity rather than by any single enforcement episode. That extractive-integrity exposure sits alongside a second structural finding: both the Financial Intelligence Centre and the Anti-Corruption Commission have presidentially appointed board leadership, an arrangement illustrated by the wholesale dissolution of the board of the Commission in July 2024 following allegations of inaction on FIU-flagged suspicious-transaction cases, creating a channel for political interference in high-level corruption matters that the architecture-over-incident principle treats as more consequential than any individual case outcome.

Two further developments anchor this baseline. The December 2025 update by the European Commission to the EU list of high-risk third countries, given effect through Delegated Regulation (EU) 2026/83, left Zambia unlisted while removing regional neighbours Mozambique, Tanzania and South Africa, a regional recalibration that shifts comparative correspondent-banking and enhanced-due-diligence risk perception for the trade corridors on which Zambia depends for copper exports, without any Zambia-specific listing action. At the same time, the Patents and Companies Registration Agency is moving, incompletely, toward automated beneficial-ownership access: investigator data-turnaround times improved to under a week from up to two weeks as of December 2025, and an application programming interface is planned to reduce the approximately 85 percent of financial-crime investigators who still rely on manual access to company data.

Other Developments

Beneficial-ownership verification remains largely manual despite incremental gains. Approximately 85 percent of financial-crime investigators in Zambia still lack automated access to PACRA company data as of December 2025, even as the planned application-programming-interface initiative and the reduction in turnaround times documented by the December 2025 UNCAC Conference of States Parties conference-room paper point toward gradual improvement.

Trust beneficial-ownership disclosure remains a structural design gap. Trusts in Zambia are legally required to update beneficial-ownership information only once every five years, and the 2019 Mutual Evaluation Report found this obligation rarely observed in practice, a combination the enabler-jurisdiction filter treats as a capacity-versus-choice question that current evidence cannot fully resolve.

DNFBP supervision has not been confirmed operational since the 2019 finding that it had not commenced, and the 2022 follow-up report shows only partial technical-compliance progress, leaving lawyers, accountants and real-estate agents outside effective AML oversight.

Technical-compliance re-ratings by ESAAMLG moved in both directions this cycle. Recommendation 7, covering proliferation-related targeted financial sanctions, was upgraded to partially compliant, while Recommendations 5 and 2 were downgraded to partially compliant, leaving Zambia in enhanced follow-up despite the mixed trajectory.

Zambia serves as a transit jurisdiction in a regional gold-smuggling corridor that moves gold smuggled from Zimbabwe through South Africa, Zambia and Mozambique toward buyers including hubs in the United Arab Emirates, exploiting weak customs verification and limited regional financial-intelligence-unit cooperation.

A parallel illicit trade in Mukula rosewood timber moves proceeds outside the regulated financial sector entirely. A surge in illegal harvesting feeds an informal, largely cash-based export trade to Chinese buyers involving bribery of forestry and customs officials and fraudulent export paperwork, limiting the reach of suspicious-transaction-report-based detection.

The comparative sanctions-architecture position of Zambia diverges sharply from that of its regional neighbour. Zambia carries no designation under EU, OFAC, OFSI or UN sanctions regimes, while Zimbabwe remains subject to an active US Global Magnitsky programme with re-designations as recently as March 2024, creating comparative correspondent-banking friction for regional corridors that transit through Zambia.

The status of Zambia under the UK High-Risk Third Country framework remains unverified this cycle. Non-listing was inferred from historical alignment with FATF and EU lists rather than independently confirmed against gov.uk sources, an evidentiary gap this baseline flags for direct re-verification.

No dedicated virtual-asset-service-provider licensing or crypto-AML regime has been published for Zambia, and the 2022 exploration by the Bank of Zambia of a central bank digital currency did not proceed into a published framework, even as vendor analytics show approximately 52 percent year-on-year on-chain value growth across Sub-Saharan Africa between July 2024 and June 2025, driven by currency volatility and limited banking access, dynamics present in the kwacha-exposed economy of Zambia.

A whistleblower-retaliation allegation and an institutional board dissolution test the durability of the anti-graft pledge of the government. A former Finance Ministry official reported alleged retaliation for raising concerns about misuse of government funds under the zero-tolerance anti-graft pledge of the Hichilema administration, with no public government response recorded, while the board of the Anti-Corruption Commission was dissolved by the President in July 2024 following allegations that Commission management was corrupt and inactive on major FIU-flagged suspicious-transaction cases, the underlying capture allegations unresolved in the public reporting reviewed.

Cross-Monitor Connections

Three linkages route this Zambia baseline to adjacent monitors. The copper and cobalt-adjacent transfer-pricing architecture, structured through Switzerland and Mauritius, is relevant to commodity-flow evasion tracking at ERM given its direct bearing on cross-border mineral-trade valuation integrity. The same regional gold-smuggling corridor that transits Zambia between Zimbabwe and buyers including hubs in the United Arab Emirates is relevant to the tracking by SCEM of conflict-context and informal-mining-economy dynamics in the region. And the July 2024 dissolution of the board of the Anti-Corruption Commission, alongside the presidentially appointed leadership structure shared by the Commission and the Financial Intelligence Centre, is relevant to the kleptocratic state-capture tracking at WDM, illustrating how institutional design can expose financial-integrity bodies to executive discretion even where the underlying AML/CFT legal architecture is reasonably developed.

Outlook

Three forward-looking items will test whether the mixed trajectory of this cycle tips toward improvement or stasis. The planned PACRA application-programming-interface integration for beneficial-ownership data, expected within the 2026-to-2027 window, would materially reduce the manual-access bottleneck currently affecting roughly 85 percent of investigators if implementation proceeds on schedule, though the completion timeline remains unconfirmed. The next enhanced follow-up review by ESAAMLG of the technical-compliance and effectiveness ratings of Zambia, expected in 2027, will re-test whether the Recommendation 7 upgrade holds and whether the Recommendation 2 and 5 downgrades are addressed. And the October 2026 Plenary of FATF will review Increased Monitoring list composition; the continued absence of Zambia from that list remains contingent on effectiveness outcomes rather than settled status. None of these developments should be read as predictions; they are the structural checkpoints against which the baseline of the next cycle will be measured.

Domain intelligence (D1–D8)

D1 Sanctions

no_changeno_changestanding position

Sanctions Architecture and Evasion

The position of Zambia within the global sanctions architecture is peripheral by structure rather than by the outcome of any single case: the jurisdiction carries no designation under the EU, OFAC, OFSI or UN sanctions regimes, a status unchanged this cycle. That structural absence sits within a shifting regional field that a purely bilateral designation-count metric would miss. The December 2025 update by the European Commission to the EU list of high-risk third countries, given effect through Delegated Regulation (EU) 2026/83, left Zambia unlisted while simultaneously delisting regional neighbours Mozambique, Tanzania and South Africa. Under the three-level sanctions-architecture analysis this monitor applies, scheme, architecture, and strategic consequence, there is no scheme directly implicating Zambia in this delisting round, but the architecture-level effect is a narrowing of the regional high-risk cohort around Zambia, which shifts comparative correspondent-banking and enhanced-due-diligence risk perception for the trade corridors on which Zambia depends for copper exports, without any Zambia-specific action having been taken.

A second architecture-level signal this cycle is the sharp divergence between the sanctions-regime exposure of Zambia and that of its immediate neighbour. Zimbabwe remains subject to an active US Global Magnitsky programme, with re-designations as recently as March 2024, while Zambia carries none of the four major-regime designations. The strategic consequence of this asymmetry, under the F2 filter, is elevated enhanced-due-diligence friction for regional banking corridors that transit through Zambia to or from Zimbabwe: correspondent banks operating across the corridor must reconcile a designated counterpart jurisdiction against an undesignated transit jurisdiction, a friction that is itself a form of architecture even absent any enforcement action against Zambia. The enabler-jurisdiction dimension of sanctions-architecture assessment also applies here in a limited but real sense: Zambia does not function as an enabler of sanctions evasion on evidence available this cycle, but its position astride a regional corridor connecting a non-designated jurisdiction to a jurisdiction under active US Global Magnitsky sanctions means that its own designation-free status does not translate into designation-free risk for banks operating in the corridor.

A third item is a verification gap rather than a substantive finding: non-listing of Zambia under the Money Laundering Regulations High-Risk Third Country framework of the UK was inferred this cycle from historical alignment with FATF and EU lists, rather than independently re-pulled from gov.uk sources. The UK HRTC list is maintained independently of the FATF and EU mechanisms and can diverge from them; this baseline flags the inference as an evidentiary gap requiring direct re-verification next cycle rather than asserting confirmed non-listed status.

For context, Zambia is not identified as a transit or intermediary jurisdiction for the Russian sanctions-evasion architecture tracked elsewhere by this monitor: as a landlocked economy with shallow capital markets and no maritime or insurance nexus, Zambia is structurally peripheral compared to coastal or Gulf and Central Asian intermediary hubs, with residual indirect exposure via Chinese-linked trade financing rather than any direct evasion-routing role.

None of the findings above amounts to a change in the substantive designation status of Zambia. What has changed, or rather what this baseline newly documents, is the surrounding architecture: a regional EU list recalibration that leaves Zambia comparatively more exposed by omission, a persistent designation asymmetry with Zimbabwe that generates corridor-level friction, and an unresolved verification gap in the UK list framework. Each of these is a second-order effect of decisions taken elsewhere rather than a first-order Zambia-specific action, consistent with the peripheral profile of Zambia within the major sanctions-designation architectures generally.

Outlook

The most consequential near-term sanctions-architecture event for Zambia is not a Zambia-specific designation risk but the October 2026 Plenary review by FATF of Increased Monitoring list composition, which will re-test whether the continued absence of Zambia from that list remains warranted given its unresolved technical-compliance gaps. A second item worth tracking is whether the regional recalibration trend of the EU high-risk-third-country mechanism, this cycle delisting Mozambique, Tanzania and South Africa, continues in subsequent review rounds, which would further concentrate comparative-risk attention on jurisdictions, including Zambia, that were not delisted alongside their neighbours. The UK HRTC verification gap should be closed directly against gov.uk sources before the next cycle, since continued reliance on inferred alignment understates the possibility that UK and EU or FATF list treatment of Zambia diverge. None of these are predictions of designation; they are the specific checkpoints against which the next-cycle sanctions-architecture assessment for Zambia should be measured.

Judgment: No Zambia-specific sanctions designation or evasion signal was located this cycle; Zambia relies on the UN Security Council consolidated list. Uncertain

D2 Beneficial Ownership

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Beneficial Ownership and Corporate Transparency

The durable structural backdrop against which any national beneficial-ownership development is read internationally is the European Union's Anti-Money Laundering Package, now settled as three distinct instruments: the directly applicable Anti-Money Laundering Regulation (Regulation (EU) 2024/1624), the sixth Anti-Money Laundering Directive transposed individually by each Member State, and the Anti-Money Laundering Authority Regulation (Regulation (EU) 2024/1620), which establishes a dedicated EU-level authority. That authority's direct and indirect supervision perimeter is shifting beneficial-ownership and broader anti-money-laundering supervision away from purely national regulators toward a hybrid EU-level regime. Zambia sits entirely outside this architecture; it is not an EU or European Economic Area jurisdiction, and the AMLR, 6AMLD and AMLA Regulation none of them apply to Zambian entities or to PACRA, Zambia's own companies registry. This backdrop is relevant chiefly as a comparator against which Zambia's own, independently-driven reform can be measured, not as a source of direct obligation.

Zambia's own development this cycle is domestically driven. The Companies (Amendment) Act No. 23 of 2025, reportedly in force since 30 December 2025, lowers the threshold defining a beneficial owner to 5 percent of shareholding, a bar substantially below the 25 percent figure that is the common international default. If this figure is confirmed once the Act's own gazetted text is obtained, it would place Zambia's statutory definition of beneficial ownership among the more expansive in the region, capturing a wider set of minority shareholders within mandatory disclosure. The claim currently rests on two pieces of secondary legal commentary, a law-firm consultancy note and a professional-body magazine article, rather than directly on the Act or the Government Gazette, so the underlying mechanics, including which filings are affected and whether the threshold applies to natural-person ownership, control, or both, remain to be confirmed against primary text.

Separately, Zambia's company registry infrastructure is reported to be undergoing a parallel modernisation. The Patents and Companies Registration Agency has partnered with the open-data non-governmental organisation Open Ownership and the German Agency for International Cooperation to overhaul how beneficial-ownership data is collected on corporate entities. This is an institutional and technical development, concerning how ownership data is gathered, verified and made accessible, that runs alongside rather than inside the statutory threshold change. Taken together, the lowered threshold and the register-digitisation partnership point toward a structural tightening of Zambia's corporate-transparency regime, though neither element has yet been corroborated by a primary Zambian legal or regulatory source this cycle.

Outlook

The principal open question is confirmation: whether the 5 percent threshold, the PACRA-Open Ownership-GIZ partnership's scope, and the practical registration mechanics can be verified against the Companies (Amendment) Act's own gazetted text or a PACRA circular, rather than resting on secondary commentary. Until that confirmation occurs, the beneficial-ownership finding is held at a qualified rather than confirmed level of confidence. If the lowered threshold is verified, it would represent a meaningful divergence from the EU's structural approach, applied via a lighter-touch national statute rather than a supranational regulation, and would be worth revisiting once PACRA's digitised register becomes operationally queryable.

Judgment: The Companies (Amendment) Act No. 23 of 2025, in force since 30 December 2025, lowers Zambia's beneficial-ownership disclosure threshold to 5%, below the common 25% international norm, while PACRA digitises its register with Open Ownership/GIZ support. Probable

D3 Enabler Jurisdictions

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Enabler Jurisdictions and Professional Facilitators

The enabler-jurisdiction risk profile of Zambia centres on institutional exposure rather than deliberate policy design, and the F3 filter four-dimension test, legal framework, enforcement, capacity versus choice, and systemic significance, yields a mixed picture this cycle. On the legal-framework dimension, the underlying AML/CFT statute of Zambia, the Financial Intelligence Centre Act, together with the 2017 Companies Act, provides a reasonably developed baseline architecture. On the enforcement and capacity dimensions, however, three findings converge to depress the effective deterrent value of that architecture.

The first is supervisory: DNFBP AML/CFT supervision had not commenced at the time of the 2019 Mutual Evaluation Report, and subsequent follow-up reporting shows only partial technical-compliance progress rather than confirmed operational supervision. Lawyers, accountants and real-estate agents, the professional-facilitator population most relevant to enabler-jurisdiction analysis generally, therefore remain largely outside effective AML oversight in Zambia, a structural gap rather than an isolated case failure.

The second is institutional-design: both the Financial Intelligence Centre and the Anti-Corruption Commission have presidentially appointed board leadership, an arrangement that creates structural exposure to political interference in high-level corruption cases regardless of the individual officeholders involved. This is not a hypothetical concern this cycle: the entire board of the Anti-Corruption Commission was dissolved by the President in July 2024, following allegations that Commission management was corrupt and inactive on major FIU-flagged suspicious-transaction cases. The underlying capture allegations were not independently resolved in the public reporting reviewed this cycle, and the reconstitution status and outcome of the replacement board remain unverified. A related, lower-confidence episode reinforces the same theme: a former Finance Ministry official reported alleged retaliation in 2025 for raising concerns about misuse of government funds under the stated zero-tolerance anti-graft pledge of the Hichilema administration, with no public government response recorded. Individually these are episodic data points; together, under the F1 state-capture filter, they describe a recurring pattern of institutional vulnerability to executive discretion that the architecture-over-incident principle treats as more significant than either event in isolation, while still stopping short of asserting confirmed capture absent independent prosecutorial-outcome data.

The third is transit-role: Zambia functions as a transit jurisdiction in a regional gold-smuggling corridor, moving gold smuggled from Zimbabwe through South Africa, Zambia and Mozambique toward buyers including hubs in the United Arab Emirates. This role is enabled less by deliberate facilitation than by weak customs verification capacity and limited regional financial-intelligence-unit cooperation, an enforcement-capacity gap rather than a policy choice on current evidence, though the distinction remains analytically unresolved pending further evidence.

The professional-facilitator dimension of enabler-jurisdiction risk also extends beyond the borders of Zambia itself: the copper and cobalt-adjacent transfer-pricing architecture identified in this baseline lists Switzerland and Mauritius, alongside Zambia, as the jurisdictions enabling profit-shifting through offshore trading-hub structures and related-party pricing arrangements. Under jurisdiction-and-actor-agnostic assessment, this monitor treats the enabler roles of Switzerland and Mauritius with the same analytical weight as the capacity gaps of Zambia itself: an enabler jurisdiction is assessed for what its legal and supervisory architecture permits, not solely for what it enforces, and the presence of two well-resourced financial centres among the enabling jurisdictions in this scheme indicates that facilitation here is a function of professional-intermediary structuring choices as much as of any single jurisdiction supervisory capacity.

Taken together, these findings describe an enabler-jurisdiction profile driven primarily by capacity constraints and institutional-design vulnerability rather than by an affirmative policy decision to facilitate illicit finance, though the presidentially appointed leadership structure of the two principal financial-integrity institutions of Zambia is the single most consequential design feature identified this cycle, since it conditions the credibility of enforcement outcomes across every other domain assessed.

Outlook

The clearest near-term test of the enabler-jurisdiction trajectory of Zambia is whether DNFBP supervision moves from partial technical-compliance progress to confirmed operational activity ahead of the next ESAAMLG enhanced follow-up review, expected in 2027. A second test is institutional: whether the reconstituted board of the Anti-Corruption Commission, whose composition and independence remain unverified this cycle, demonstrates functional independence from executive direction in its handling of pending suspicious-transaction referrals. A third is regional: whether financial-intelligence-unit cooperation along the Zimbabwe-Zambia-Mozambique-South Africa gold corridor improves, which would be the most direct available evidence of capacity remediation in the transit-jurisdiction finding. None of these are foregone conclusions; they are the specific evidentiary gaps this baseline has flagged for resolution.

Judgment: No Zambia-specific enabler-jurisdiction finding was located this cycle. Uncertain

D4 Conflict Finance

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Conflict Finance and Extractive-Industry Integrity

The most systemically significant financial-integrity exposure of Zambia this cycle is extractive-sector illicit financial flows, and the architecture-over-incident principle applies here with unusual clarity: this is a persistent, multi-jurisdictional structure rather than a single enforcement case. Mining multinationals and trading intermediaries structure copper and cobalt-adjacent export contracts through offshore trading hubs in Switzerland and Mauritius, combined with related-party pricing arrangements, to shift taxable profit outside Zambia. The mechanism operates through export contracts and related-party pricing structured to understate export values or overstate deductible costs relative to international commodity benchmark pricing, a red-flag pattern most observable in trade documentation and most relevant to corporate and trade-finance customer relationships. This scheme is sustained by weak beneficial-ownership verification and customs verification capacity within Zambia rather than by any single transaction, and it directly implicates two enabling jurisdictions, Switzerland and Mauritius, alongside the role of Zambia as the target jurisdiction whose mineral-revenue base is being eroded. This finding does not distinguish between the domestic capacity constraints of Zambia and the structuring choices made by intermediaries operating through Switzerland and Mauritius; consistent with jurisdiction-agnostic assessment, both the verification gaps of the target jurisdiction and the permissive trading-hub architecture of the enabling jurisdictions are treated as co-equal structural contributors to the persistence of the scheme.

A second, structurally distinct extractive-industry-adjacent exposure is environmental-crime-linked timber trafficking. A surge in illegal Mukula rosewood harvesting feeds an informal, largely cash-based export trade to Chinese buyers, involving bribery of forestry and customs officials and fraudulent export documentation. Because this trade is conducted substantially in cash and outside the regulated financial sector, conventional suspicious-transaction-report-based detection has limited reach into it, a structural detection gap distinct from, but reinforcing, the customs-verification weaknesses that also enable the copper-sector scheme. Research on money laundering linked to environmental crime frames this pattern as part of a broader continental one, in which cash-intensive, document-fraud-enabled timber and wildlife trades systematically evade the suspicious-transaction-report architecture built around the regulated financial sector, a structural detection blind spot rather than a Zambia-specific failure.

A third, F4-relevant conflict-finance dimension connects Zambia to the regional gold-smuggling corridor already identified under the enabler-jurisdiction filter: gold smuggled from Zimbabwe transits South Africa, Zambia and Mozambique en route to buyers including hubs in the United Arab Emirates. Applying the F4 source-channel-deployment trace, the source is the informal and illicit gold-mining sector of Zimbabwe, the channel is the transit corridor exploiting weak customs verification across Zambia, South Africa and Mozambique, and the deployment point is refining and buyer markets in the United Arab Emirates. This is not, on current evidence, a conflict-finance flow in the narrow armed-conflict-financing sense within Zambia itself, but it sits within the same regional informal-extraction economy that conflict-finance analysis elsewhere in Southern Africa tracks closely, and it is flagged accordingly for cross-reference to SCEM.

The customer-typology and observability profile of these schemes is instructive for obliged entities operating trade-finance and correspondent-banking relationships tied to Zambian mineral exports: the relevant red flags are documentary rather than transactional in the narrow sense, visible chiefly in export-contract pricing terms and customs or CITES documentation rather than in account-level transaction patterns alone, a distinction with direct implications for the design of trade-finance due-diligence controls.

Taken together, these three findings, transfer-pricing erosion of the mineral-revenue base, cash-based timber trafficking, and gold-corridor transit, describe an extractive-industry integrity profile in which the common structural thread is weak verification capacity, in beneficial ownership, in customs documentation, and in cross-border cash and trade-finance monitoring, rather than three unrelated episodes.

Outlook

None of the three extractive-industry findings identified this cycle carry a defined near-term resolution horizon in currently available evidence; all three are structural and are expected to persist absent capacity investment in customs verification, beneficial-ownership verification, and regional financial-intelligence-unit cooperation. The most tractable point of leverage is the beneficial-ownership verification improvement already underway at PACRA, since improved investigator access to company ownership data bears directly on the ability to unwind related-party pricing structures used in the copper-sector scheme. Absent a dedicated customs-verification capacity initiative, the Mukula timber trade and the gold-transit corridor are likely to remain structurally resistant to detection through conventional financial-sector monitoring channels.

Judgment: No Zambia-specific conflict-finance finding was located this cycle. Uncertain

D5 Crypto / Digital Assets / Financial Innovation

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Crypto, Digital Assets, and Financial Innovation

The digital-asset regulatory environment of Zambia is defined this cycle by absence rather than by any specific enforcement or licensing action: no dedicated virtual-asset-service-provider licensing regime and no comprehensive crypto-AML or counter-terrorist-financing framework have been published. The Bank of Zambia explored a central bank digital currency in 2022, but that exploration did not proceed into a published regulatory framework covering private virtual-asset activity, leaving Zambia without a domestic VASP-licensing perimeter, a domestic travel-rule requirement, or a domestic crypto-specific suspicious-activity reporting regime as of this baseline.

This regulatory absence is analytically significant in its own right under the enablement-as-signal principle: the absence of a published framework is not neutral, because it coincides with a regional adoption trend that is accelerating rather than static. Vendor analytics show approximately 52 percent year-on-year on-chain value growth across Sub-Saharan Africa between July 2024 and June 2025, a trend attributed to currency volatility and limited banking access, dynamics that are directly present in the kwacha-exposed economy of Zambia. Because this growth figure is vendor-analytics-sourced rather than drawn from a primary regulatory or law-enforcement source, it is treated at Assessed rather than High confidence, consistent with source-tier discipline, but the directional signal is consistent with the broader regional pattern this monitor tracks.

The F3 enabler-jurisdiction capacity-versus-choice question is explicitly unresolved for the crypto-regulatory gap of Zambia: current evidence does not establish whether the absence of a VASP framework reflects a deliberate policy choice, a genuine capacity constraint within the Bank of Zambia and any prospective financial-intelligence-unit crypto-monitoring function, or simply a lower prioritisation relative to other AML/CFT reform priorities already underway, such as the PACRA beneficial-ownership modernisation effort. What can be said with higher confidence is the trajectory: the standing tracker for the crypto and digital-asset integrity of Zambia is assessed as worsening, on the basis that regional adoption growth is outpacing regulatory development rather than the reverse.

Globally, instruments such as the Markets in Crypto-Assets framework of the EU and the virtual-asset standards of FATF set the structural direction for VASP licensing and travel-rule implementation worldwide, and they form the contextual backdrop against which any future Zambian VASP framework would likely be measured or benchmarked. But no MiCA-equivalent instrument, travel-rule requirement, or FATF Recommendation 15 implementation action specific to Zambia was identified in this cycle evidence base, and this baseline does not assert one; the directly relevant fact for the own regulatory perimeter of Zambia remains the absence documented above, not the global standard against which that absence might eventually be measured.

The affected firm-type and customer-typology profile flagged this cycle is narrow but concrete: crypto-asset operators and VASP counterparties transacting with Zambian retail users are the population most directly exposed to the absence of a domestic licensing perimeter, since neither inbound nor outbound Zambian virtual-asset activity currently passes through any jurisdiction-specific registration, travel-rule, or reporting gate. For counterparties elsewhere assessing correspondent or partnership exposure to Zambian-linked virtual-asset flows, this absence functions as a standing due-diligence caveat rather than a resolved control question. This stands in some contrast to the incremental, if incomplete, institutional-modernisation trajectory visible in the beneficial-ownership registry of Zambia this cycle; the two domains illustrate uneven reform prioritisation within the same jurisdiction, corporate-registry transparency advancing modestly while virtual-asset oversight remains, on current evidence, unaddressed.

Outlook

There is no regulatory-horizon item specific to Zambian virtual-asset licensing identified in this cycle evidence base, which is itself a data point: the forward-looking checkpoints available for this domain are regional and comparative rather than jurisdiction-specific, principally whether the on-chain value growth trend of Sub-Saharan Africa continues at a comparable pace and whether that continued growth generates pressure, from FIU capacity concerns or from correspondent-banking counterparties, for the Bank of Zambia to revisit the shelved 2022 central bank digital currency exploration or to publish a dedicated VASP framework. Absent such a trigger, this baseline expects the worsening trajectory assessed this cycle to persist into the next. This is a domain in which the absence of an enforcement record should not be read as an absence of exposure; it is, under the enablement-as-signal principle of this monitor, itself the primary finding to carry forward.

Judgment: The Bank of Zambia's March 2026 VASP registration exercise and the FIC's 2022 VASP Sector Guidelines remain the operative crypto AML framework; no new instrument superseded them this cycle. Probable

D6 Compliance Technology & Active Defence

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Compliance Technology and Active Defence

The single RegTech-relevant development identified for Zambia this cycle is the planned application programming interface for law-enforcement and financial-intelligence-unit access to PACRA beneficial-ownership data. This is a modest but concrete signal: a jurisdiction-specific implementation of a broader global thesis that automated, investigator-facing registry access materially improves the practical usability of beneficial-ownership transparency regimes, as against a status quo in which registry data exists in principle but remains difficult to query in practice. As of this baseline, approximately 85 percent of financial-crime investigators in Zambia still rely on manual access to PACRA company data, and the December 2025 UNCAC Conference of States Parties conference-room paper documents that the API initiative is intended to close that gap, alongside the turnaround-time improvements already achieved through non-technological process changes.

This finding sits at the intersection of compliance-technology assessment and beneficial-ownership assessment, and it is worth stating explicitly what distinguishes the D6 reading from the D2 reading of the same underlying fact: D2 treats the PACRA registry as a beneficial-ownership-transparency instrument and asks whether trust and corporate disclosure obligations are being met; D6 treats the same registry as a compliance-technology and active-defence instrument and asks whether the technical architecture of data access itself, independent of the underlying disclosure obligations, is fit for investigator use. On the D6 reading, the answer this cycle is qualified: turnaround-time improvement demonstrates that operational process reform is achievable even before the API is delivered, but the persistence of the 85 percent manual-access figure demonstrates that process reform alone has not yet closed the technology gap.

No other RegTech, SupTech, or active-defence development specific to Zambia was identified in this cycle evidence base; the compliance-technology profile is currently defined by this single initiative and by the technology gap it is designed to close, rather than by an active-defence or transaction-monitoring-technology finding of the kind more commonly assessed in better-resourced jurisdictions. The confidence-tier discipline applies directly here: the API initiative itself is sourced to a T1 institutional-review document and is treated as Assessed rather than High, since implementation has not yet been confirmed and the completion timeline remains unconfirmed beyond a general 2026-to-2027 expectation window.

The affected-firm-type profile for this initiative is broad rather than sector-specific: cross-sector obliged entities relying on PACRA beneficial-ownership data for corporate-customer due diligence, not solely law-enforcement and FIU users, stand to benefit indirectly if API-based access is eventually extended or if faster registry turnaround reduces onboarding friction industry-wide, though the initiative as currently scoped is described as an investigator-facing rather than an industry-facing capability. Placed in comparative context, this single Zambian initiative is a small-scale instance of a pattern this monitor tracks globally: capacity-constrained jurisdictions increasingly treat automated registry interconnection, rather than registry creation alone, as the frontier compliance-technology investment, since registries that exist on paper but require manual retrieval do not deliver the investigative speed that modern financial-crime casework requires. Whether this specific initiative, once delivered, meaningfully narrows the 85 percent manual-access figure, or merely formalises access for a subset of investigators while leaving the broader population reliant on manual retrieval, is a distinction this baseline cannot yet resolve and flags for direct assessment once implementation evidence becomes available.

Outlook

The completion timeline of the PACRA API is the single most important compliance-technology checkpoint for Zambia going into next cycle; delivery within the 2026-to-2027 expectation window would represent a concrete, verifiable improvement in investigator-facing RegTech capability, while continued delay would suggest that the turnaround-time improvements already documented represent the practical ceiling of process reform absent the technology investment. This baseline recommends no assumption of delivery in either direction; the status of the API should be independently re-verified next cycle rather than assumed complete on the basis of this cycle plans-are-underway characterisation.

Judgment: No Zambia-specific RegTech or compliance-technology development was located this cycle. Uncertain

D7 AML/CTF Regime

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AML/CTF Regime

Zambia's anti-money-laundering and counter-terrorist-financing architecture has moved structurally this cycle through the Banking and Financial Services Act, 2026 (Act No. 9 of 2026), which repeals and replaces the Banking and Financial Services Act, Cap. 387, and separately repeals the Money-lenders Act, Cap. 398. The consolidation brings banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia licensing and supervisory umbrella, a structural change of the kind that matters more for the durability of a supervisory regime than any single enforcement action would. The Act's own repeal-and-savings clause, found at section 214, expressly preserves existing licences, pending applications, accrued rights and liabilities arising under the repealed Money-Lenders Act, meaning the transition for existing licensees is designed to be orderly rather than disruptive. Critically, the Act has not yet commenced: its provisions, including whatever anti-money-laundering supervisory duties are consolidated under it, await a commencement order, so the current practical effect on supervision remains prospective.

This consolidation is itself a response to a gap that had persisted since the prior National Payment System Act was system-focused rather than detailed on individual payment-service-provider licensing, conduct and governance standards; by folding fintechs and e-money issuers into the Bank of Zambia's licensing perimeter, the new Act closes a supervisory space in which such entities' anti-money-laundering obligations had previously been comparatively undefined. This is the kind of enablement-by-omission concern, a gap in the regulatory perimeter rather than a failure of enforcement within it, that merits explicit note: the absence of detailed fintech AML obligations under the prior regime was itself a structural vulnerability, now being addressed.

Alongside the domestic legislative consolidation, Zambia's international standing on anti-money-laundering compliance remains stable. As of the Financial Action Task Force's 19 June 2026 plenary, Zambia is named in neither the list of jurisdictions under increased monitoring nor the list of jurisdictions subject to a call for action. Zambia's own standing with the Eastern and Southern Africa Anti-Money Laundering Group records progress since its 2019 mutual evaluation and the subsequent follow-up report, with the next on-site mutual evaluation visit not expected before 2028 under the current evaluation methodology. This is a multi-year runway during which the practical effect of the Banking and Financial Services Act's consolidation, once commenced, is likely to be assessed.

Outlook

The principal variable to track is commencement of the Banking and Financial Services Act, 2026: until a commencement order is issued, the Act's consolidated anti-money-laundering supervisory architecture remains legislated but not operative, and existing sector-specific supervisory arrangements for moneylenders, fintechs and e-money issuers continue to apply in the interim. Given the multi-year runway to the next Eastern and Southern Africa Anti-Money Laundering Group mutual evaluation visit, Zambia's near-term Financial Action Task Force standing is unlikely to shift materially absent an unexpected finding, leaving commencement of the domestic consolidation as the development most likely to alter the practical AML/CTF landscape for Zambian-regulated financial-service providers.

Judgment: The Banking and Financial Services Act, 2026 consolidates licensing and AML/CTF supervision of banks, MFIs, moneylenders, fintechs and e-money issuers under the Bank of Zambia, though commencement awaits a statutory instrument. Zambia remains off both FATF public statements as of the 19 June 2026 plenary. Probable

D8 Commercial Activity

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Commercial Activity

Zambia's fintech and payments sector continued to generate disclosed commercial activity this cycle, against the backdrop of the pending National Payment System Act and Banking and Financial Services Act reforms described elsewhere in this brief. Lupiya, a Zambian digital lender, closed a disclosed USD 11.25 million Series A funding round, reported 17 February 2026 and led by Alitheia IDF and Enygma Ventures. The round size was disclosed in deal-tracker reporting rather than confirmed against a primary filing, and should be read with that sourcing caveat in mind.

Separately, Airtel Money Zambia and Stanbic Bank Zambia announced a mobile-wallet-on-POS partnership around 2 June 2026. The partnership was described by Stanbic Zambia's Head of Business and Commercial Banking as part of the bank's ongoing investment programme; the financial terms of the arrangement were not disclosed in the trade-press reporting reviewed. No regulatory review, licensing condition or AML/CFT compliance commentary was attached to either the Lupiya funding round or the Airtel-Stanbic partnership in the sourcing reviewed this cycle, which is itself a notable absence given that both transactions sit squarely within the payments and lending space the National Payment System Act and Banking and Financial Services Act are designed to bring under unified licensing once commenced.

The pattern across both transactions is one of steady commercial deal flow proceeding independently of the pending legislative architecture shift. Neither the capital-raising nor the partnership activity reviewed this cycle appears to have been gated by, or conditioned on, the AML/CFT, cyber-incident-reporting, capital or fund-segregation requirements that the 2026 Acts would introduce once in force, consistent with those requirements not yet being operative law.

Outlook

Commercial activity in Zambia's fintech and payments space is likely to continue at a similar pace in the near term, with capital-raising and bank-telco partnership activity proceeding under the current, pre-reform regulatory architecture. Once the National Payment System Act and Banking and Financial Services Act commence, transactions of the type seen this cycle, particularly partnerships involving mobile-money and bank-channel integration, would fall within the scope of individual PSP and e-money licensing and the unified Bank of Zambia supervisory framework, which could introduce new diligence and disclosure expectations around future deals that do not currently attach. Continued monitoring of commencement timing therefore has direct relevance to how future commercial transactions in this space are structured and disclosed.

Judgment: No commercial event specific to integrity-infrastructure or de-risking was located for Zambia this cycle. Uncertain

Regulatory horizon

Adopted2026-Q4 · ±half_year

Banking and Financial Services Act, 2026 implementation

AML/CFT/CPF monitoring duties for financial service providers move onto a single consolidated statutory basis under BoZ, replacing the 2017 Act framework.

Source

Adopted2027-Q1 · ±year

National Payment System Act 2026 commencement pending

Payment service providers and e-money institutions move from system-level designation to individual licensing with AML/CFT, cyber-incident-reporting, capital and customer-fund-segregation duties, once commenced.

Bank of Zambia / Ministry of Finance Source

Adopted2027-Q1 · ±year

Banking and Financial Services Act 2026 commencement pending

Lenders, e-money issuers, moneylenders and fintechs become licensable financial service providers under BoZ once commenced.

Bank of Zambia Source

Proposed2027-Q2 · ±multi_year

Comprehensive VASP regulatory framework (post-registration phase)

BoZ has signalled a move from directive-based registration to a full licensing and supervisory regime for VASPs.

Source

4 dated · 4 pending date · baseline financial-integrity-2026-07-05

Role action cards

MLRO

Banking and Financial Services Act, 2026 consolidates AML supervision of banks, moneylenders, fintechs and e-money issuers under the Bank of Zambia, though commencement is pending.

Once a commencement order is issued, reporting lines and supervisory touchpoints for anti-money-laundering purposes will consolidate from several sector-specific regimes into one Bank of Zambia framework; the current registration-not-licensing virtual-asset regime also continues to apply pending any future instrument.

2 evidence refs

Compliance

Beneficial-ownership disclosure threshold reportedly lowered to 5 percent under the Companies (Amendment) Act No. 23 of 2025.

A lower disclosure threshold, if confirmed against primary statutory text, would widen the pool of shareholders captured as beneficial owners for corporate due-diligence purposes in Zambia, though the claim currently rests on secondary legal commentary rather than the Act itself.

1 evidence refs

Board

Zambia remains off both Financial Action Task Force public lists, with its anti-money-laundering architecture consolidating rather than facing adverse international designation.

The structural consolidation under the Banking and Financial Services Act, 2026, combined with continued absence from Financial Action Task Force monitoring and call-for-action lists, points toward an incrementally strengthening, rather than deteriorating, financial-crime risk posture in Zambia, pending commencement of the new Act.

2 evidence refs

CTO

Virtual-asset registration with the Bank of Zambia remains explicitly non-licensing, leaving platform-level compliance architecture reliant on the Financial Intelligence Centre's existing ten-year record-retention duty.

Technology and data-retention architecture for any Zambian-facing virtual-asset operation should account for the Financial Intelligence Centre's existing ten-year record-keeping requirement, since the March 2026 Bank of Zambia registration exercise does not itself constitute authorisation to operate.

1 evidence refs

Risk

Sanctions screening exposure in Zambia continues to run through the United Nations consolidated list only, with no autonomous national list identified.

Absent a Zambia-specific sanctions list, exposure concentration for sanctions-screening purposes in Zambia should be modelled against the UN Security Council consolidated list and against the parallel US, UK and EU regimes' own designations, since no Zambia-specific decision was located this cycle.

1 evidence refs

Audit

Internal consistency between the Banking and Financial Services Act's not-yet-commenced status and current supervisory practice should be tracked pending a commencement order.

Audit trails covering licensing and AML supervisory touchpoints for Zambian-regulated entities should continue to reference the pre-existing sector-specific regimes until the Banking and Financial Services Act, 2026 is formally commenced, at which point control-testing scope will need to be updated to the consolidated framework.

1 evidence refs

Scenario sketches

Illustrative AMLA supervisory-perimeter shift and cross-border evasion response

As an illustrative orientation only, consider how the European Union's move from purely national anti-money-laundering supervision toward direct and indirect Anti-Money Laundering Authority oversight of cross-border obliged entities, under the AMLA Regulation alongside the directly applicable AML Regulation and nationally transposed sixth Directive, could reshape where illicit actors seek lighter-touch processing of cross-border structures. A structural effect of concentrating supervisory attention at the EU level could, in principle, redirect attention toward jurisdictions entirely outside that perimeter, where national companies registries and beneficial-ownership thresholds vary independently of the EU framework. This is a sketch of a possible structural mechanism, not an observed fact, and is not a prediction that any specific jurisdiction, including Zambia, will experience this effect.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker	Status	Note
T1 · Russian Sanctions-Evasion Architecture	no_change	No Zambia-specific finding this cycle.
T2 · EU AML Package / AMLA	no_change	Zambia is outside the EEA and not bound by AMLR/6AMLD/AMLA.
T3 · FATF Grey List	no_change	Zambia remains off both FATF public statements as of the 19 June 2026 plenary; next ESAAMLG on-site evaluation slated for 2028.
T4 · Beneficial-Ownership Register Status	improving	PACRA's BO register is being digitised via the Open Ownership/GIZ partnership while the disclosure threshold is lowered to 5%.
T5 · Crypto & Digital-Asset Integrity	stable	BoZ's March 2026 VASP registration exercise and FIC's 2022 VASP AML guidelines remain the operative framework.
T6 · Sanctions Regime Divergence	no_change	No Zambia-specific OFAC, OFSI or EU Council designation located this cycle.

Registers

Enforcement actions

4 Apr 2025
13 Dec 2025
18 Jul 2024
25 Aug 2022

Sanctions changes

4 Dec 2025
The European Commission's December 2025 update to the EU list of high-risk third countries (Delegated Regulation (EU) 2026/83) left Zambia unlisted while delisting regional neighbours Mozambique, Tanzania and South Africa, and adding Bolivia, the British Virgin Islands and Russia. This shifts the comparative correspondent-banking and enhanced-due-diligence risk profile of the regional trade corridors Zambia depends on for copper and other exports. 4 Dec 2025

Regulatory horizon (register)

Banking and Financial Services Act, 2026 (Act No. 9) - commencement
Banking and Financial Services Act, 2026 (Act No. 9) - commencement
Banking and Financial Services Act, 2026 implementation
Comprehensive VASP regulatory framework (post-registration phase)
National Payment System Act, 2026 commencement pending
National Payment System Act 2026 commencement pending
Banking and Financial Services Act 2026 commencement pending
Bank of Zambia transition from VASP interim registration to full virtual-asset licensing
PACRA beneficial-ownership API integration for investigator access
Next ESAAMLG enhanced follow-up review of Zambia's AML/CFT framework
FATF October 2026 Plenary review cycle (grey-list monitoring)

Active schemes

[HIGH] Copper-sector transfer pricing and export under-invoicing
[HIGH] Company and trust structuring to conceal beneficial owners
Southern Africa gold-smuggling transit corridor via Zambia
Mukula rosewood illegal timber trafficking to China

Sources

Coverage gaps

fim-int-2026-07-07-G001: UK Money Laundering Regulations Hig…

fim-int-2026-07-07-G001: UK Money Laundering Regulations High-Risk Third Country status for Zambia was not independently re-verified against gov.uk sources this cycle and rests on inference from FATF and EU list alignment. [resolved]

fim-int-2026-07-07-G002: ESAAMLG September 2024 sixth enhanc…

fim-int-2026-07-07-G002: ESAAMLG September 2024 sixth enhanced follow-up report and third technical-compliance re-rating for Zambia, including reported R.2 and R.16 upgrades, was not located or incorporated into this baseline. [resolved]

fim-int-2026-07-07-G003: The outcome and current composition…

fim-int-2026-07-07-G003: The outcome and current composition of the reconstituted Zambia Anti-Corruption Commission board following the July 2024 dissolution was not independently verified this cycle. [resolved]

fim-int-2026-07-07-G004: No fresh 2025 or 2026 Zambia-specif…

fim-int-2026-07-07-G004: No fresh 2025 or 2026 Zambia-specific FATF or ESAAMLG mutual evaluation or follow-up report beyond the 2022 Follow-Up Report was located during this research cycle. [resolved]

fim-int-2026-07-07-G005: The precise completion timeline for…

fim-int-2026-07-07-G005: The precise completion timeline for the PACRA beneficial-ownership API integration and its effect on the manual-access bottleneck remains unconfirmed beyond a general 2026 to 2027 expectation window. [resolved]

fim-int-2026-07-07-G006: Whether DNFBP AML/CFT supervision i…

fim-int-2026-07-07-G006: Whether DNFBP AML/CFT supervision in Zambia has become fully operational since the 2019 Mutual Evaluation Report finding of non-commencement was not confirmed by any subsequent source reviewed this cycle. [resolved]

fim-int-2026-07-07-G007: Independent evidence on whether Zam…

fim-int-2026-07-07-G007: Independent evidence on whether Zambia Financial Intelligence Centre or Anti-Corruption Commission referrals have translated into completed prosecutions in politically sensitive corruption cases was not available this cycle. [resolved]

fim-int-2026-07-07-G008: Attribution of specific EU high-ris…

fim-int-2026-07-07-G008: Attribution of specific EU high-risk-third-country delegated-regulation changes between Delegated Regulation (EU) 2026/83 and (EU) 2026/46 was conflated in the baseline research and requires direct EUR-Lex re-verification. [resolved]

fim-int-2026-07-14-G001: No Bank of Zambia Gazette or primar…

fim-int-2026-07-14-G001: No Bank of Zambia Gazette or primary regulatory text for the Banking and Financial Services Act 2026 was retrieved this cycle; confidence capped at Assessed on a single T3 law-firm summary. [resolved]

fim-int-2026-07-14-G002: No primary Bank of Zambia VASP regi…

fim-int-2026-07-14-G002: No primary Bank of Zambia VASP registration directive text was retrieved; the registration requirement is corroborated only by T3/T4 secondary sources. [resolved]

fim-int-2026-07-14-G003: D1 (sanctions) and D4 (conflict fin…

fim-int-2026-07-14-G003: D1 (sanctions) and D4 (conflict finance) analytical domains returned thin coverage for Zambia this cycle; no dedicated primary-source material was located. [resolved]

fim-int-2026-08-25-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-08-25-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No T1 FATF/ESAAMLG primary source confirming Zambia's June 2026 grey/black-list status was directly retrieved this cycle; reliance is on a single T4 secondary source. [resolved]

fim-int-2026-08-25-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-08-25-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No Zambia-specific conflict-finance (D4) signal was identified this cycle; genuine coverage gap pending primary-source research. [resolved]

fim-int-2026-08-25-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-08-25-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): No T1 Bank of Zambia primary press release text on the VASP-registration directive was directly retrievable this cycle; reliance is on two independent T3 sources. [resolved]

fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No Russia-sanctions-evasion, beneficial-ownership-register, or D1-D4/D6 development specific to Zambia was identified this cycle within the ZM-bound search budget. [resolved]

fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Whether BoZ has published the comprehensive VASP regulatory framework referenced as forthcoming, and under what statutory instrument number, was not established this cycle. [resolved]

fim-int-2026-09-28-G003: Tier D mandatory watch jurisdiction…

fim-int-2026-09-28-G003: Tier D mandatory watch jurisdictions (KH, LA, MX, CO) were not exercised within this run because this union dispatch is JID-bound to Zambia alone. [resolved]

fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1-D6 coverage was thin this cycle; dispatch was bound to Zambia alone and the research run reports Tier-D (KH, LA, MX, CO) checks as not performed in this dispatch, requiring confirmation via those jurisdictions' own dispatch. [resolved]

fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No primary BCLB/LGB-equivalent or Bank of Zambia homepage notice confirming the exact legal basis and current status of the VASP registration directive beyond secondary trade-press reporting was retrieved this cycle. [resolved]

fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): Zambia-specific sanctions-evasion architecture (D1) coverage was thin this cycle; no search budget remained to independently re-check UN Panel of Experts/OFAC/OFSI channels. [open]

fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No Zambia-specific enabler-jurisdiction (D3) finding was located this cycle. [open]

fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): Whether NPSA 2026 or BFSA 2026 has received a commencement statutory instrument could not be confirmed this cycle; no SI was found via search. [open]

fim-int-2026-10-25-G001: D1 Sanctions, D3 Enabler Jurisdicti…

fim-int-2026-10-25-G001: D1 Sanctions, D3 Enabler Jurisdictions, D4 Conflict Finance and D6 Compliance Technology carried no Zambia-specific finding this cycle; pooled search budget was concentrated on D2/D5/D7. [open]

fim-int-2026-10-25-G002: Tier D jurisdictions (Cambodia, Lao…

fim-int-2026-10-25-G002: Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not independently searched this cycle. [open]

fim-int-2026-10-25-G003: SEC Zambia's reported April/June 20…

fim-int-2026-10-25-G003: SEC Zambia's reported April/June 2026 civil-penalty actions against crypto-linked schemes could not be confirmed from a primary SEC Zambia notice this cycle. [open]

FIM-GAP-001 (D3): Zambia's Financial Intelligence Centre and…

FIM-GAP-001 (D3): Zambia's Financial Intelligence Centre and Anti-Corruption Commission both have presidentially appointed boards/leadership, a structure the Swazi Secrets leak and subsequent 2024 ACC board dissolution showed can translate into inaction or delay on politically sensitive corruption cases, including matters involving a former president.

FIM-GAP-002 (D2): Over 80% of financial-crime investigators …

FIM-GAP-002 (D2): Over 80% of financial-crime investigators rely on beneficial-ownership data for investigations, yet as of the December 2025 UNCAC COSP review approximately 85% of investigators still access this data manually, constraining timeliness of complex financial-crime and corruption investigations.

FIM-GAP-003 (D3): Zambia's 2019 MER found that DNFBP supervi…

FIM-GAP-003 (D3): Zambia's 2019 MER found that DNFBP supervisors had not yet commenced risk-based AML/CFT supervisory activity or issued sanctions for violations; subsequent follow-up reports show only partial technical-compliance re-ratings rather than confirmation that DNFBP supervision is now fully operational.

FIM-GAP-004 (D1): No OFAC, UN Security Council, or UK OFSI s…

FIM-GAP-004 (D1): No OFAC, UN Security Council, or UK OFSI sanctions listing, delisting, or licensing action was identified as directly targeting Zambian nationals, entities, or vessels during the 18-month baseline window; Zambia sits outside all three major sanctions architectures.

FIM-GAP-005 (D6): The most recent Zambia-specific FATF/ESAAM…

FIM-GAP-005 (D6): The most recent Zambia-specific FATF/ESAAMLG mutual-evaluation and follow-up outputs identified in this baseline (2022 FUR, and a referenced 28 May 2024 FUR) predate the strict 18-month baseline window, and no fresh 2025/2026 Zambia-specific MER or FUR was located during this research cycle.

Evidence

Confidence-tiered claims

assented 31 March 2026, gazetted 8 April 2026, marked 'Uncommenced' pending ministerial statutory instrument [Source 1]

Probable · 1 source

express function to monitor payment service providers for purposes of AML/CFT/PF, under s.5(1)(e) of the National Payment System Act, 2026 [Source 1]

Probable · 1 source

re-rated toward Largely Compliant/Compliant for Recommendations 2, 10, 16 and 22 since the 2019 mutual evaluation, per ESAAMLG/FATF follow-up [Source 1]

Probable · 1 source

Second National Risk Assessment (NRA) Report published [Source 1]

Probable · 1 source

all entities/individuals providing virtual-asset services required to register with Bank of Zambia by 27 March 2026 [Source 1]

Probable · 1 source

no autonomous sanctions list maintained; implements UN sanctions only [Source 1]

Probable · 1 source

Financial Intelligence Centre Act No. 46 of 2010, as amended by Act No. 4 of 2016 and Act No. 16 of 2020 [Source 1]

Probable · 1 source

Anti-Terrorism and Non-Proliferation Act No. 30 of 2024, with sanctions/TFS screening under January 2025 NATC Guidelines [Source 1]

Probable · 1 source

In enhanced follow-up since 2019 MER; R.2 and R.16 re-rated to Largely Compliant/Compliant per 30 Sept 2025 follow-up report; R.8 and R.35 deficiencies persist; not on FATF's 19 June 2026 grey list [Source 1]

Probable · 1 source

Enacted (assented 31 March 2026, gazetted 8 April 2026), not yet commenced [Source 1]

Probable · 1 source

Enacted (assented 31 March 2026, gazetted 8 April 2026), not yet commenced [Source 1]

Probable · 1 source

USD 11.25m Series A, reported 17 February 2026, led by Alitheia IDF and Enygma Ventures [Source 1]

Probable · 1 source

Mobile-wallet-on-POS partnership announced around 2 June 2026 [Source 1]

Probable · 1 source

Repeals and replaces the Banking and Financial Services Act, Cap. 387, and repeals the Money-lenders Act, Cap. 398, bringing banks, MFIs, moneylenders, fintechs and e-money issuers under one BoZ-licensed AML/CTF-relevant supervisory regime. [Source 1]

Probable · 1 source

Lowers Zambia's beneficial-ownership disclosure threshold to 5% of shares, in force since 30 December 2025; PACRA partnering with Open Ownership/GIZ to digitise the BO register. [Source 1]

Probable · 1 source

BoZ's March 2026 VASP registration exercise (closed 27 March 2026, explicitly non-licensing) and FIC's 2022 VASP Sector Guidelines (10-year record-retention duty) remain the operative crypto AML/CTF framework; no new instrument superseded them this cycle. [Source 1]

Probable · 1 source

Remains off both FATF public statements (Increased Monitoring and Call for Action) as of the 19 June 2026 plenary; next ESAAMLG mutual evaluation on-site visit slated for 2028 under the 2024 methodology. [Source 1]

Probable · 1 source

No autonomous Zambian sanctions list exists; screening obligation remains tied to the UN Security Council consolidated list; no Zambia-specific OFAC, OFSI or EU Council designation located in October 2026 notices. [Source 1]

Probable · 1 source

Financial Intelligence Centre Act and Prohibition and Prevention of Money Laundering Act, supervised by FIC as FIU and Bank of Zambia for banks/PSPs/mobile-money/VASPs [Source 1]

Probable · 1 source

banks, microfinance institutions, moneylenders, fintechs and e-money issuers under direct Bank of Zambia licensing [Source 1]

Probable · 1 source

Bank of Zambia's payment-system licensing, designation and authorisation powers, repealing and replacing the prior National Payment Systems Act [Source 1]

Probable · 1 source

UN Security Council consolidated list only; no autonomous Zambian sanctions list exists [Source 1]

Uncertain · 1 source