Angola AML & Sanctions Compliance

Key Legislation

Angola's AML/CFT framework is primarily anchored by Law No. 5/20 on Combating Money Laundering and Terrorism Financing. This comprehensive law establishes the core obligations for obliged entities, defines offenses, outlines preventative measures, and sets out the powers of competent authorities in the fight against financial crime.

Supervisory & Regulatory Authorities

Several key bodies oversee the implementation and enforcement of Angola's AML/CFT regime, each with specific mandates:

• Financial Intelligence Unit (UIF - Unidade de Informação Financeira): Angola's central national agency responsible for receiving, requesting, analyzing, and disseminating financial intelligence (including Suspicious Transaction Reports - STRs) to competent authorities to combat ML/TF and associated predicate offenses.

  Key Focus: Central agency for receiving, analyzing, and disseminating Suspicious Transaction Reports (STRs) to combat ML/TF.

• National Bank of Angola (BNA - Banco Nacional de Angola): The central bank and primary prudential supervisor for banks, non-bank financial institutions, and payment service providers. It issues AML/CFT regulations and conducts off-site and on-site supervision for these entities to ensure compliance.

  Key Focus: Issues AML/CFT regulations and conducts off-site and on-site supervision for banks and NBFIs to ensure compliance with Law No. 5/20.

• Capital Market Commission (CMC - Comissão do Mercado de Capitais): Regulates and supervises the Angolan securities market. The CMC is responsible for establishing AML/CFT rules for, and supervising, participants in the capital markets, including brokerage firms and asset managers.
• Angolan Agency for Insurance Regulation and Supervision (ARSEG - Agência Angolana de Regulação e Supervisão de Seguros): The regulatory and supervisory authority for the insurance sector. ARSEG oversees AML/CFT compliance for insurance companies, pension fund managers, and insurance intermediaries.

FATF Status & Engagement

As of June 2025, Angola remains on the FATF's list of "Jurisdictions under Increased Monitoring," commonly known as the "grey list."

Angola made a high-level political commitment to work with the FATF and ESAAMLG to strengthen its AML/CFT regime. Key deficiencies remain in areas such as improving risk-based supervision, ensuring timely access to beneficial ownership information, and increasing ML/TF investigations and prosecutions in line with the country's risk profile.

Being on the grey list means Angola is under increased scrutiny. Businesses may experience heightened due diligence requirements from international financial institutions, potential impacts on correspondent banking relationships, and closer examination of transactions involving Angolan entities.

Core AML/CFT Obligations

Obliged entities in Angola must adhere to a range of AML/CFT obligations designed to prevent, detect, and report financial crime. Key requirements include:

• Risk-Based Approach (RBA): Implementing a comprehensive RBA across all AML/CFT efforts, ensuring that compliance measures are proportionate to the identified risks.
• Customer Due Diligence (CDD/KYC): Conducting thorough, risk-based CDD at onboarding and on an ongoing basis. This includes applying Enhanced Due Diligence (EDD) for high-risk customers, such as Politically Exposed Persons (PEPs), and for relationships/transactions linked to high-risk sectors like oil and diamonds, given their inherent vulnerabilities.
• Beneficial Ownership (BO) Identification: Identifying and taking reasonable measures to verify the identity of beneficial owners, typically at a 25% ownership/control threshold, or through other means of control. Efforts to improve access to accurate BO information, including through registries, are ongoing.
• Transaction Monitoring: Implementing systems and processes to monitor customer transactions for unusual or suspicious activity inconsistent with the customer's profile or known legitimate business. Particular focus is needed on transactions involving high-risk sectors and jurisdictions.
• Record Keeping: Maintaining all necessary records on customer identification, transactions, and AML/CFT compliance efforts for a minimum of 10 years after the business relationship ends or the transaction is completed, ensuring they are readily available to competent authorities.
• Reporting Obligations: Promptly filing Suspicious Transaction Reports (STRs) with Angola's Financial Intelligence Unit (UIF) for any transaction suspected of being linked to ML/TF. Cash Transaction Reports (CTRs) are also required for transactions exceeding defined thresholds (e.g., 15 million kwanzas).

Key Compliance Challenges

Despite the legal framework, businesses operating in or with Angola may face several practical challenges in meeting their AML/CFT obligations effectively:

• Resource Dependency & Associated Risks: The economy's significant reliance on oil and diamonds creates heightened vulnerabilities to corruption, illicit financial flows, and money laundering, demanding more intensive scrutiny from obliged entities.
• Identifying and Managing PEP Relationships: Navigating complex ownership structures, identifying PEPs and their associates, and managing the risks associated with these relationships, particularly where state involvement in the economy is high.
• Navigating Currency Controls: Stringent foreign exchange controls can lead to the development of parallel markets and attempts to circumvent official channels, creating ML risks that require careful monitoring.
• Ensuring Consistent Implementation: Addressing potential gaps or inconsistencies in the application and enforcement of AML/CFT requirements across different types of financial institutions and DNFBPs.
• Resource Constraints in Supervision & Enforcement: While the legal framework has been strengthened, the capacity for comprehensive supervision and consistent enforcement across all sectors remains an area of development, placing more onus on entities' internal controls.
• Data Quality and Access for CDD: Obtaining reliable and verifiable information for CDD purposes can sometimes be challenging, requiring robust verification processes.