Compliance Guide 2026
Mozambique AML & Sanctions Compliance Guide
Expert guide to navigating Mozambique's AML/CFT and sanctions compliance landscape. Essential reading for financial institutions, compliance officers, and regulatory professionals operating in Mozambique.
Mozambique Compliance Overview
Mozambique Country Profile
Mozambique operates a developing financial sector regulated under a 2022 AML/CFT legislative framework. Mozambique exited the FATF grey list in October 2025 after completing its action plan. Elevated terrorism financing risk in Cabo Delgado requires heightened due diligence for northern Mozambique operations.
- GIFiM (Gabinete de Informação Financeira de Moçambique) — Mozambique's FIU
- Banco de Moçambique — Central bank and primary financial supervisor
- Insurance supervisor — verify current supervisory authority with GIFiM; sector oversight arrangements have evolved with AML/CFT reform
Regulatory Framework
- Law No. 14/2013 — primary AML/CFT legislation
- 2022 AML/CFT reforms — updated obligations addressing FATF action plan
- UN Security Council sanctions implemented domestically
Core obligations:
- Customer due diligence (CDD) — risk-based approach
- STR filing with GIFiM for suspected ML/TF transactions
- Screening against UN, EU, and applicable sanctions lists
- Enhanced due diligence for Cabo Delgado exposure
FATF Status & Terrorism Financing Risk
FATF Grey List Exit — October 2025
Mozambique was removed from FATF Increased Monitoring at the October 2025 Plenary following substantial completion of its action plan. Grey list entry was in June 2022. Post-exit, domestic supervision remains active and reporting entities should maintain elevated compliance standards.
- Grey list entry: June 2022
- Grey list exit: October 2025
- No EU high-risk listing — EU EDD requirements normalised
- Post-exit supervisory expectations remain elevated
Terrorism Financing Risk — Cabo Delgado
The ongoing Islamist insurgency in Cabo Delgado province creates material terrorism financing risk for northern Mozambique operations. Financial institutions and businesses with Cabo Delgado exposure must apply enhanced TF-specific due diligence, including screening against designated terrorist entities and monitoring for transaction patterns consistent with TF typologies.
- Apply TF-specific EDD for Cabo Delgado counterparties
- Screen against UN Al-Qaida and ISIL sanctions lists
- Monitor for unusual cash flows or NGO-linked transactions in conflict zones
- Document TF risk rationale in customer risk assessments
Risk Environment & Typologies
Key Money Laundering Typologies
- Terrorism financing linked to Cabo Delgado insurgency
- Trade-based money laundering through informal cross-border trade
- Corruption — natural resource extraction (gas, minerals)
- Real estate investment by politically exposed persons
- Cash-intensive transactions in informal economy
High-Risk Sectors
- Natural resources (LNG, minerals) — high-value, opacity risk
- Real estate — PEP and cash investment risk
- Banking and MFIs — informal economy interfaces
- Mobile money — widespread, limited CDD controls
- NGO/NPO sector — TF misuse risk in conflict-affected areas
Compliance Requirements
STR Reporting & Obligations
- File STRs with GIFiM for suspected ML or TF transactions
- TF STRs require immediate filing — do not delay pending further investigation
- Tipping off is prohibited
- Verify current thresholds and deadlines with GIFiM directly
Sanctions Compliance
- UN Security Council consolidated list — mandatory screening
- UN Al-Qaida and ISIL lists — critical for Cabo Delgado exposure
- No autonomous EU or US OFAC high-risk designation — standard screening applies
- Monitor for newly designated individuals linked to Mozambican insurgency
Regulatory Resources
Key Red Flags — Mozambique
- Payments to or from Cabo Delgado without clear legitimate business purpose
- Large cash transactions inconsistent with customer profile
- LNG or mineral transactions with undisclosed beneficial owners
- NGO accounts with unusual fund flows in northern provinces
- PEP-linked real estate transactions without source of wealth documentation