Political will and the implementation of anti-money laundering measures: the Zambian experience, 2004 to 2006

The document examines Zambia's anti-money laundering efforts from 2004 to 2006, focusing on the Prohibition and Prevention of Money Laundering Act 2001 (PPMLA). It identifies a significant gap between legislation and implementation, noting that while the Bank of Zambia has issued directives and conducted inspections, other supervisory authorities like the Securities and Exchange Commission and the Pensions and Insurance Authority have not. The paper highlights the Anti-Money Laundering Investigations Unit's (AMLIU) role in prosecution and the impact of political will on corruption and money laundering cases. It also discusses the shift of money laundering activities from the banking sector to non-bank financial institutions and designated non-financial businesses and professions, such as real estate, lawyers, and accountants.

• The Prohibition and Prevention of Money Laundering Act 2001 (PPMLA) was delayed in its enactment due to a lack of political will, resulting in the law being outdated upon adoption as it was based on 1996 Financial Action Task Force (FATF) Recommendations that were already being revised.
• There is a systemic failure in the implementation of AML directives across various supervisory authorities; as of September 30, 2006, the Bank of Zambia (BoZ) was the only authority to issue directives, while others, including the Securities and Exchange Commission (SEC) and the Pensions and Insurance Authority (PIA), had not.
• Financial institutions have under-reported suspicious transactions to the Anti-Money Laundering Investigations Unit (AMLIU) because the unit is perceived as focusing on prosecution rather than analysis, and because the AMLIU has prematurely frozen bank accounts.
• Money launderers are increasingly shifting away from the banking sector toward non-bank financial institutions and designated non-financial businesses and professions, specifically real estate, lawyers, and accountants, where regulation is weaker.
• The AMLIU's capacity to enforce AML laws has been constrained by an inability to replace staff lost to resignations, dismissals, and death, despite a threefold increase in prosecuted cases between 2004 and 2006.
• Political will is described as 'fickle' and subject to the interests of politicians, as illustrated by the case of Dr Kashiwa Bulaya, whose corruption case was withdrawn by the Director of Public Prosecutions without justifiable reasons, only to be reopened after public outcry.
• Zambia's international AML efforts are supported by membership in the Eastern and Southern African Anti-Money Laundering Group (ESAAMLG), though the country lagged in developing a national AML strategy by the July 2006 deadline.

APA

Munyoro, J. (2007). Political will and the implementation of anti-money laundering measures: the Zambian experience, 2004 to 2006. Institute for Security Studies. https://issafrica.org/topics/organised-crime/01-may-2007-monograph-no-132-confronting-the-proceeds-of-crime-in-southern-africa-an-introspection-edited-by-charles-goredema/chapter-2-political-will-and-the-implementation-of-anti-money-laundering-measures-the-zambian-experience-2

Chicago

Munyoro, Joseph. Political will and the implementation of anti-money laundering measures: the Zambian experience, 2004 to 2006. Institute for Security Studies, 2007. https://issafrica.org/topics/organised-crime/01-may-2007-monograph-no-132-confronting-the-proceeds-of-crime-in-southern-africa-an-introspection-edited-by-charles-goredema/chapter-2-political-will-and-the-implementation-of-anti-money-laundering-measures-the-zambian-experience-2.

Wikipedia

{{cite report |last1=Munyoro |first1=Joseph |title=Political will and the implementation of anti-money laundering measures: the Zambian experience, 2004 to 2006 |publisher=Institute for Security Studies |date=May 2007 |url=https://issafrica.org/topics/organised-crime/01-may-2007-monograph-no-132-confronting-the-proceeds-of-crime-in-southern-africa-an-introspection-edited-by-charles-goredema/chapter-2-political-will-and-the-implementation-of-anti-money-laundering-measures-the-zambian-experience-2 |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{munyoro2007political, author = {Munyoro, Joseph}, title = {{Political will and the implementation of anti-money laundering measures: the Zambian experience, 2004 to 2006}}, institution = {Institute for Security Studies}, year = {2007}, month = may, url = {https://issafrica.org/topics/organised-crime/01-may-2007-monograph-no-132-confronting-the-proceeds-of-crime-in-southern-africa-an-introspection-edited-by-charles-goredema/chapter-2-political-will-and-the-implementation-of-anti-money-laundering-measures-the-zambian-experience-2}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }