The European Union funded AML-CFT Project in Eastern, Southern and Central Africa and Yemen (AML-CFT ESCAY) Project has been providing needs-based technical assistance to different countries of the region. As reported in the last two issues of our newsletter, issue 2 and Issue 3,  the AML-CFT ESCAY Project has been providing tailored technical assistance to multiple jurisdictions based on their prioritised demands. The Project has given priority to jurisdictions that are currently under the Financial Action Task Force (FATF)’s International Cooperation Review Group (ICRG) process or those highly likely to fall to the ICRG process. To this effect, the Project has extended its support to Namibia, Rwanda, South Africa and South Sudan, in partnership with the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG).

Here’s a summary of the actions undertaken by the Project in support of the selected countries:

NAMIBIA

On 23 February 2024, the FATF placed Namibia under the Grey List, for its shortcomings in compliance with international Anti-Money laundering (AML), Combating the Financing of Terrorism (CFT), and Combatting Proliferation Financing (CPF) standards. Substantial recommended actions have been so far implemented; however, Namibia has important remaining areas of its action plan that should be implemented to address the limitations and comply with the FATF standards. The Financial Intelligence Centre (FIC) of Namibia requested the European Union Delegation (EUD) in Windhoek for technical assistance.

Following Namibia’s request, and after a series of consultations, the AML-CFT ESCAY Project agreed to provide limited TA on areas covering Immediate Outcomes (IO) 6, 7, 9 and elements of IO8 to which the Namibia FIC agreed.

The overall objective of this limited technical assistance was to reinforce Namibia’s operational and practical capacity in financial intelligence analysis, effective use of financial intelligence, and effective investigation and prosecution of money laundering, terrorist financing and related crimes as well as tracing and recovery of proceeds of crime. 

The Project, in partnership with ESAAMLG and FIC Namibia, organised two mutually reinforcing training courses:

• Financial intelligence analysis and effective utilisation of financial intelligence, on 8-12 July 2024 in Windhoek. This training was attended by officers drawn from the FIC, Police Force, prosecution, anti-corruption, revenue agency, Bank of Namibia, Financial Institutions Supervisory Authority and other relevant agencies.

• Investigation and prosecution of ML/TF and asset recovery, scheduled for 09 – 13 September 2024. Also jointly organized with the FIC and ESAAMLG, the training is expected to bring together about 40 trainees drawn from the FIC, law enforcement agencies, national prosecution, anti-corruption and other competent authorities. 

RWANDA

Rwanda was recently assessed on its AML/CFT system, and its Mutual Evaluation Report (MER) endorsed by the ESAAMLG in April 2024. Among others, the MER identified several deficiencies concerning risk-based AML/CFT supervision (IO3) and preventive measures (IO4) that Rwanda needs to address.

In its effort to implement the key recommended actions outlined by the MER, the Central Bank of Rwanda, requested the AML/CFT ESCAY Project for technical assistance to strengthen its risk-based AML/CFT supervision of the financial sector. The bank supervises wide range of institutions in addition to the new demand to inspect Virtual Assets Service Providers, VASPs.

In response, the AML/CFT ESCAY Project carried out a scoping mission and agreed to provide limited technical assistance to Rwanda to strengthen its risk-based supervision of the financial sector. The scope of the assistance includes:

• Develop necessary manuals, models and guidelines: The project developed and submitted

1. A comprehensive risk-based AML/CFT supervision manual 2). A Risk mapping tool (model) 3). Risk mapping tool guidance 4). off-site inspection guideline handbook? 5. onsite inspection guidance and 5) related templates and tools. Almost all documents have been reviewed and accepted by the team of experts at the Central Bank of Rwanda.

• Organise training on risk-based AML/CFT supervision

We hosted a users’ training on the risk mapping matrix/model has been virtually in an interactive session to guide the Bank’s officials on how to flexibly use the model to assess risks. A comprehensive training on risk-based AML/CFT supervision has been scheduled for 16 – 20 September 2024 in which about fifty trainees are expected to attend.  

South Africa

South Africa has been on the grey list since February 2023. Among others, the FATF statement noted that South Africa needed to “demonstrate sustained increase in investigations and prosecutions of serious and complex money laundering and the full range of Terrorist Financing activities”. South Africa’s FIC expressed interest to receive trainings on converting intelligence to evidence, investigating complex ML and TF, and the effective use of beneficial ownership data for ML/TF investigation and prosecution 

In response, the Project agreed to organise a training on investigating and prosecuting complex ML cases in which the other areas of interest would also be included. This training is scheduled for 23-27 September 2024 in Johannesburg or Pretoria. This training will be organised in partnership with ESAAMLG and in line with the FATF action plan and findings of the MER.

SOUTH SUDAN

South Sudan is still under the grey list for- multiple strategic deficiencies. The Project provided technical assistance to South Sudan to support operationalization of its FIU, including training newly recruited officers on financial intelligence. This contributed to the FIU starting to receive and analyzing suspicious transaction reports and disseminating financial intelligence reports to competent authorities. South Sudan’s FIU further requested for support in conducting a national training for in-country assessors.

In response, the Project, in partnership with ESAAMLG Secretariat, agreed to organise and deliver the training on 16 – 20 September 2024 in Juba. The training will be fully facilitated by authorised ESAAMLG trainers who can provide assessors’ training based on FATF standards. The training is expected to bring together 40 officers drawn from multiple relevant agencies.