Resolution No. 28/2026: Approves the National System Strategy for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing 2026-2030 and its Action Plan

Thursday, 16 April 2026 I SERIES — Number 71
OFFICIAL PUBLICATION OF THE REPUBLIC OF MOZAMBIQUE NATIONAL PRESS OF MOZAMBIQUE, E.P.
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SUMMARY
Council of Ministers:
Resolution No. 28/2026:
Approves the Sustainability Strategy of the National System for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction 2026-2030, and its respective Action Plan.

COUNCIL OF MINISTERS
Resolution No. 28/2026 of 16 April

Given the need to equip the Government with a sustainability strategy for the national system for the prevention and combat of money laundering, terrorist financing and proliferation financing of weapons of mass destruction, to protect the integrity of the financial system and comply with international obligations assumed, in order to respond to the challenges of current reality, under the provisions of paragraph f) of number 1 of Article 203 of the Constitution of the Republic, the Council of Ministers determines:

ARTICLE 1
(Approval)
The Sustainability Strategy of the National System for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction, and its respective Action Plan, attached and which are integral parts of this Resolution, are approved.

ARTICLE 2
(Implementation)
The relevant sectors and institutions that make up the National System for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction, must adopt the necessary measures to ensure the implementation of the actions provided for in the Strategy and its respective Action Plan and in the Sectoral Plans, within the scope of their respective attributions and competences.

ARTICLE 3
(Sectoral Implementation Plans)

1. Within 15 days, counted from the date of publication of this Resolution, the relevant sectors and institutions must elaborate and submit to the Executive Coordination Committee (CEC), their respective Sectoral Implementation Plans of the Strategy.
2. The Sectoral Implementation Plans, referred to in the previous number, must in particular, identify:
   a) the activities to be developed; b) the execution deadlines; c) the entities responsible for their implementation; and d) the resources necessary for their execution.

ARTICLE 4
(Coordination, monitoring and evaluation)

1. It is incumbent upon the Minister who superintends the area of Finance, to approve the regulations necessary for the coordination, monitoring and evaluation of the implementation of the Sustainability Strategy of the National System for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction.
2. It is incumbent upon the Executive Coordination Committee (CEC) to ensure the coordination, follow-up, monitoring and evaluation of the implementation of the Sustainability Strategy of the National System for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction and in its respective Action Plan and in the Sectoral Plans, being able, for this purpose, to issue technical guidelines to the institutions involved.

ARTICLE 5
(Entry into force)
This Resolution enters into force on the date of its publication.
Approved by the Council of Ministers, on 10 March 2026.
Publish.
The Prime Minister, Maria Benvinda Delfina Levi.

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Sustainability Strategy of the National System for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction 2026 - 2030

1. Contextualization
   Within the scope of current legislation, matters concerning the Legal Regime and Measures for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction, are dealt with in Law No. 14/2023 of 28 August, which establishes the Legal Regime for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction, amended by Law No. 3/2024, of 22 March; in Law No. 15/2023 of 28 August, which establishes the Legal Regime for the Prevention, Repression and Combat of Terrorism and the Proliferation of Weapons of Mass Destruction, amended by Law No. 4/2024 of 22 March and in Decree No. 53/2023 of 31 August, which Approves the Regulation of the Law that Establishes the Legal Regime and Measures for the Prevention and Combat of Money Laundering and Terrorist Financing, we must also, consider in full the Recommendations of the International Financial Action Task Force (FATF), with regard to International Standards for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction. Having reviewed the Fundamental Law of the Country (CRM), it is verified that the matter regarding the Strategy of Continuity and Sustainability of the National System for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction and its respective National Strategy Implementation Plan, has constitutional consecration in the terms provided for in Articles 17, 18 and 19, Chapter II, of the Constitution of the Republic of Mozambique (CRM). Now, the Strategy of Continuity and Sustainability of the National System for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction (2026-2030), and its respective National Strategy Implementation Plan, aim to ensure the sustainability of technical compliance and effectiveness with the international normative standards established by the FATF, in order to protect the integrity and stability of the national financial system, support the creation of concrete, continuous actions in Law Enforcement Authorities (LEAs), Supervisory Bodies of Financial Institutions and Designated Non-Financial Businesses and Professions (DNFBPs), Non-Profit Organizations (NPOs), Financial Institutions and Obligated Entities, stakeholders and relevant Ministries in the matter, aiming at institutional strengthening, public-private partnerships and engagement with international partners, aiming at the consolidation of reforms, control systems, risk mitigation and improvement of the legal framework. The continuity and sustainability strategy of the national system for the prevention and combat of money laundering, terrorist financing and proliferation financing of weapons of mass destruction (2026-2030), and its respective implementation plan, is clear
   regarding its object, given its objective of supporting Mozambican authorities in the Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF), as well as all natural and legal persons, to implement effectively and coherently under internal law, in order to ensure legal and regulatory compliance for the maintenance of the integrity of their financial system, in accordance with FATF recommendations.

I. Introduction

1. On 22 October 2022, Mozambique was placed on the list of countries under enhanced monitoring (Grey List) of the Financial Action Task Force (FATF), due to strategic deficiencies identified in the implementation of the 40 Recommendations described in the Mutual Evaluation Report (MER).
2. Following this decision, the FATF submitted to the Government of Mozambique an Action Plan (2022 – JAN/2025), containing 26 activities, framed within the 11 Immediate Results of the FATF Assessment Methodology, whose implementation was approved by the Government for a period of two years. Parallel to this, the Government also approved, on 6 December 2022, in the Forty-Second Section of the Council of Ministers, the Strategy for the Removal of Mozambique from the Grey List to ensure the effective execution of the Action Plan.
3. For the effective Implementation of the Action Plan, the Executive Coordination Committee for Policies on the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF) was created, and its mission is to follow up, coordinate the identification, assessment and response to ML/TF/PF risks to which Mozambique may be exposed, contributing to the continuous improvement of technical compliance and the effectiveness of the national system for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF).
4. After the completion of the 26 activities of the FATF Action Plan, an on-site visit to Mozambique by the International Cooperation Review Group (ICRG), Joint Group (JG) was carried out on 8 and 9 September 2025. The conclusions of the visit report confirmed that Mozambique effectively implemented all measures provided for in the Action Plan, demonstrating solid progress in all Immediate Results.
5. Additionally, the Country achieved an excellent level of technical compliance in 31 of the 40 FATF Recommendations. Furthermore, the Joint FATF Group recognized that the reforms are institutionalized, sustained and benefit from high-level political commitment.
6. Given this progress, on 24 October 2025, the FATF Plenary decided on the removal of Mozambique from the Grey List, following positive reports emanating from the "on-site" visit, and the meeting of the International Cooperation Review Group (ICRG).
7. Mozambique's exit from the Grey List does not mark the end of the implementation process of policies for the prevention and combat of ML/TF/PF, but rather the beginning of a new phase. This phase requires continuous actions in the areas of Law Enforcement Authorities (LEAs), Supervisory Bodies of Financial Institutions and Designed Non-Financial Activities and Professions (DNFBPs), Non-Profit Organizations (NPOs), and Obligated Entities, stakeholders and relevant Ministries for the ML/TF/PF prevention and combat system, thus protecting the integrity and stability of the national financial system.
8. Thus, in order to guarantee the sustainability of the ML/TF/PF prevention and combat system, the present Post-Grey List National Strategy for the period 2026 to 2030 is presented. This aims to ensure the continuity of compliance and effectiveness with international standards established by the FATF, thus protecting the integrity and stability of the national and international financial system.
9. To achieve these objectives, it becomes imperative to adopt a comprehensive and sustainable approach, with priority and concrete actions in the following domains: Law Enforcement Authorities, Supervisory Bodies of Financial Institutions and Designated Non-Financial Activities and Professions (DNFBPs), Non-Profit Organizations (NPOs), Obligated Entities, stakeholders and relevant Ministries for the ML/TF/PF prevention and combat system.

II. Justification
Importance of the Strategy of Continuity and Sustainability of the National System for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction.
10. The removal of Mozambique from the Grey List, although representing notable progress, should not be understood as the end of the process, but rather as the beginning of a new phase of consolidation and continuous improvement of robust Compliance practices, aiming at the sustainability of the system for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction.
11. The FATF strongly recommends that countries removed from the Grey List develop and implement a solid and sustainable post-removal strategy, with the objective of ensuring the continuous effectiveness of their ML/TF/PF prevention and combat systems as well as the maintenance of technical compliance and effectiveness, in order to avoid the Country returning to the Grey List.
12. This strategic approach should include the maintenance of various measures including robust legal and regulatory structures, the effective application of current laws, national and international cooperation between public and private entities, the strengthening of risk-based financial supervision and inspection, constant monitoring of activities and financial flows, the use of financial intelligence by competent authorities to investigate, prosecute and judge ML/TF/PF cases, among others.
13. The approval of the Strategy of Continuity and Sustainability of the National System for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction, aims to guarantee continuity in the implementation of FATF recommendations, consolidate the advances obtained and avoid a possible reinclusion of Mozambique in the Grey List.

III. Sustainability
14. The sustainability of the progress achieved requires a continuous commitment by Government entities, Law Enforcement Authorities, Supervisory Bodies of Financial Institutions and Designated Non-Financial Activities and Professions (DNFBPs), Non-Profit Organizations (NPOs), Financial Institutions and Obligated Entities, stakeholders and relevant Ministries for the ML/TF/PF prevention and combat system, with a focus on strategic actions that ensure the maintenance, consolidation and improvement of implemented reforms. In this context, competent entities must guide their activities around the following pillars:
a. Risk-Based Money Laundering and Terrorist Financing Combat:
Awareness and capacity-building actions are fundamental and must be adapted to the evolution of risks and the specificities of each sector. These initiatives must ensure the continuous training of financial institutions, non-financial entities and other obliged subjects, promoting knowledge about new regulations and encouraging the adoption of high standards of financial integrity. b. National Coordination and International Cooperation:
It is equally essential to maintain an active dialogue with national and international bodies, as well as to ensure the exchange of information with foreign entities and Mozambique's participation in initiatives in global forums for the combat of ML/TF/PF. This action strengthens the Country's position in the national and international scenario, promotes the attraction of national and foreign investments, facilitates national and international trade and drives sustainable economic development.
c. Continuous Monitoring and Evaluation Mechanisms:
The Strategy proposes the implementation of permanent monitoring and evaluation systems, with the objective of ensuring the effective application of policies and practices instituted. These mechanisms will allow for the timely identification and correction of any gaps, preventing the recurrence of illicit practices and demonstrating Mozambique's continuous commitment to the integrity and transparency of its financial and international system.
15. This Strategy aims to reinforce the effectiveness of national coordination actions and international cooperation, with the objective of remedying the deficiencies identified in the Mutual Evaluation Report (MER) and the results of Mozambique's National Risk Assessment (NRA). This articulation is essential to ensure a coherent and integrated response to the vulnerabilities of the national system.
16. The National Strategy constitutes a common reference base for all actors involved in the field of Prevention and Combat of (ML/TF/PF). Its scope transcends the exclusive action of public bodies — such as law enforcement authorities, regulators, supervisors, among others — and also covers the private sector, including obligated entities, self-regulatory organizations, professionals subject to specific regulation, as well as other relevant actors of civil society.
17. With this, the Strategy proposes to institute and promote a common vision among all stakeholders, guiding the adoption of coordinated measures for the prevention and combat of ML/TF/PF, in line with national objectives and priorities. Joint action will be especially oriented towards the identified sectors that present higher risk, ensuring a strategic response based on evidence and proportional to the levels of threat.

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IV. Institutions involved in the elaboration of the Strategy
18. This strategy is the result of work by the Executive Coordination Committee with the involvement of the following institutions: Supreme Court (TS); Attorney General's Office (PGR); Ministry of National Defence (MDN); Ministry of Foreign Affairs and Cooperation (MINEC); Ministry of Justice, Constitutional Affairs and Religious Affairs (MJACR); Ministry of Finance (MF); Ministry of the Interior (MINT); Judicial and Legal Training Centre (CFJJ), Mozambique Financial Information Office (GIFiM); Tax Authority (AT); Bank of Mozambique (BdM); Mozambique Insurance Supervision Institute (ISSM); National Criminal Investigation Service (SERNIC); Kimberley Process Management Unit (UGPK); National Administration of Conservation Areas (ANAC) and General Inspection of Games (IGJ).

V. Strategic Guidelines
19. For the pursuit of this Strategy, awareness actions are necessary for the main stakeholders, regarding the risks of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction, regarding the specific vulnerabilities of each sector within their responsibilities, in order to allow better mobilization of bodies and institutions regarding their role in the fight against illicit financial flows and against the use of certain sectors of Designated Non-Financial Activities and Professions (DNFBPs) for purposes of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction, regarding activities to reinforce capacity building and allocation of resources to bodies and institutions for the full exercise of their functions.
20. Therefore, the implementation of a risk-based strategy will allow national authorities to better direct financial, technical and human resources to activities and sectors with the highest degree of exposure to Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction risks, thus seeking to achieve notable and tangible results, it will also allow rationalizing resources in situations of high, medium and low risk identified in the National Risk Assessment (NRA) process and in the Mutual Evaluation Report (MER).
21. To ensure effective and structured coordination of the implementation of the National Strategy for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction, the authorities involved must continue to be organized into three Subcommittees, each led by a key institution, according to their institutional competences:
a) Subcommittee of Law Enforcement Authorities Presidency: Attorney General's Office (PGR).
Composition: Supreme Court (TS), Attorney General's Office (PGR), National Criminal Investigation Service (SERNIC), Tax Authority (AT), Mozambique Financial Information Office (GIFiM), ANAC (National Administration of Conservation Areas). b) Subcommittee of Financial Supervisors Presidency: Bank of Mozambique (BdM). Composition: Mozambique Insurance Supervision Institute (ISSM). c) Subcommittee of Supervisors of Designated Non-Financial Activities and Professions (DNFBPs) Presidency: Mozambique Financial Information Office (GIFiM). Composition: Mozambique Financial Information Office (Supervisor of the vehicle sales and real estate sectors), Kimberley Process Management Unit (UGPK), Order of Accountants and Auditors of Mozambique (OCAM), Order of Lawyers of Mozambique (OAM), Registries and Notaries Conservatories; General Inspection of Games (IGJ);
22. In this context, five strategic objectives were identified to reinforce the effectiveness of the national system for the prevention and combat of ML/TF/PF, namely:

• Strategic Objective 1: Reinforce cooperation, coordination and communication mechanisms at the national and international levels as well as the understanding of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF) risks;
• Strategic Objective 2: Strengthen compliance in matters of prevention and combat of ML/TF/PF and the supervision and inspection of obligated entities.
• Strategic Objective 3: Reinforce transparency measures applicable to natural persons, legal persons and entities without legal personality, as well as mitigate risks associated with economic and financial operations carried out by these entities.
• Strategic Objective 4: Strengthen the prevention, detection, analysis, investigation, prosecution and judgment of ML/TF/PF crimes and measures related to the loss of products and proceeds resulting from the practice of crimes.
• Strategic Objective 5: Ensure the effective implementation of a comprehensive national strategy to combat terrorist financing, in compliance with international standards.

VI. Description of Strategic Objectives, areas of intervention, results and performance indicators oriented
For each of the five (5) strategic objectives, areas of intervention and respective lines of activities for their proper implementation were identified. In addition, this Strategy has its action plan and respective result indicators.

Framework
During the process of Mozambique's removal from the FATF Grey List, with a view to strengthening the national regime for the Prevention and Combat of Money Laundering, Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF), the Country adopted effective mechanisms of cooperation, coordination and inter-institutional communication, which were decisive for the success achieved. Given the demonstrated effectiveness, it is recommended to maintain these mechanisms, preserving the current structure, the adopted reporting model and the creation of technical subcommittees, all under the leadership of the Executive Coordination Committee (CEC), presided over by the National Coordinator under the tutelage of the Minister of Finance.

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In terms of sustainability, this structure will guarantee continuous political commitment, effective articulation with other sovereign bodies, with the High-Level Committee, technical coordination of specialized subcommittees, and maintenance of active communication channels with relevant international bodies. This approach will allow:

• The timely and effective dissemination of information on risks of Combating Money Laundering, Terrorist Financing, and Proliferation Financing of Weapons of Mass Destruction (ML/TF/Proliferation Financing - ML/TF/PF), to reporting entities and obligated entities;
• Strategic and technical alignment on the national risk level, as well as on predicate crimes to Money Laundering, as well as crimes of Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF);
• The strengthening of the coordinated institutional response, in line with international standards and good practices promoted by the FATF.
  The consolidation of these mechanisms is essential to guarantee the sustainability of the progress achieved, prevent setbacks, and reinforce the resilience of the national system for preventing and combating financial crime.
  Strategic Objective 1: Continue to strengthen cooperation, coordination, and communication mechanisms at the national and international levels, as well as the understanding of Money Laundering, Terrorist Financing, and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF) risks
• Intervention Area 1: Periodic review of the Coordination Executive Committee (CEC), with clear attributions and institutional representation at the highest level.
• Formalization of the High-Level Committee and technical subcommittees, namely: the Law Enforcement Authorities (LEAs) subcommittee, Financial Institutions (FIs) subcommittee, and Designated Non-Financial Businesses and Professions (DNFBPs) subcommittee.
• Intervention Area 2: Legislative Reform - Monitor and follow up on legislative and regulatory reforms, conform the legal framework in accordance with changes to FATF recommendations.
• Intervention Area 3: Completeness in Risk-Based Assessment, need to incorporate proportional risk assessment in all financial institutions.
• Intervention Area 4: Adopt measures to ensure that competent authorities and obligated entities adequately understand the Money Laundering, Terrorist Financing, and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF) risks to which they are exposed.
• Intervention Area 5: Promotion of the signing of Memoranda of Understanding (MoUs) between institutions that have not yet formalized their collaboration mechanisms.
  Strategic Objective 2: Strengthen and reinforce the institutional, technical, technological, and human capacity of national authorities in matters of preventing and combating ML/TF/PF, supervision and inspection of obligated entities, ensuring the sustainability, independence, and effectiveness of the system.
• Intervention Area 1: Promote the Conduct of the National Risk Assessment of Proliferation Financing and update the National Risk Assessment of Money Laundering, for application of the risk-based approach.
• Intervention Area 2: Improve and/or refine the manuals, guidelines for Combating Money Laundering, Terrorist Financing, and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF), carry out dissemination activities with Financial Institutions (FIs) and Designated Non-Financial Businesses and Professions (DNFBPs).
• Intervention Area 3: Promote training and capacity-building actions, including preparation of sectoral guidelines for obligated entities most vulnerable to ML/TF/PF.
• Intervention Area 4: Strengthen risk-based supervision and inspection, including the development of adequate tools for inspections (on-site/off-site).
• Create the database on administrative sanctions/persuasive and proportional measures applied for non-compliance with duties provided for in ML/TF/PF legislation.
• Intervention Area 5: Organize the informal sector, the real estate sector, and the vehicle purchase and sale sector.
  Strategic Objective 3: Strengthen transparency measures applicable to individuals, legal entities, and entities without legal personality, as well as mitigate risks associated with economic operations and financial transactions.
• Intervention Area 1: Improve the identification of beneficial owners of legal entities and entities without legal personality, based on risk.
• Intervention Area 2: Establish effective sanctioning mechanisms for the registration of beneficial owners.
  Strategic Objective 4: Strengthen the analysis, detection, investigation, prosecution, and judgment of Money Laundering, Terrorist Financing, and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF) crimes and measures related to the loss of products and proceeds resulting from the commission of crimes.
• Intervention Area 1: Improve the capacity of the Financial Intelligence Unit (FIU) to conduct Suspicious Transaction Reports (STRs) analysis, production, and dissemination of Financial Intelligence Reports (FIRs).
• Intervention Area 2: Strengthen the capacity of law enforcement authorities to conduct effective investigations and prosecutions based on (FIRs) disseminated spontaneously by the FIU or resulting from information requests made by them.
• Intervention Area 3: Continue to Promote international cooperation in matters related to the prevention and combating of ML/TF/PF.
• Intervention Area 4: Adopt measures for Interoperability of the Supreme Court (SC), Attorney General's Office (AGO), National Criminal Investigation Service (NCIS), as a priority, but also for the National Conservation Areas Administration (NCAA), Kimberley Process Management Unit (KPMU), Coordination Executive Committee (CEC), and Mozambique Financial Intelligence Unit (MFIU), for supervision.

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Strategic Objective 5: Ensure the effective implementation of a comprehensive national strategy to combat terrorist financing, in accordance with international standards.

• Intervention Area 1: Ensure the implementation of the comprehensive national strategy against terrorist financing.
• Intervention Area 2: Continue to increase the capacity of the AGO, MFIU, and NCIS to effectively perform their functions and responsibilities for Preventing and Combating ML/TF/PF, according to the risk profile.
• Intervention Area 3: Conduct the categorization and mapping of Non-Profit Organizations (NPOs), focusing on identifying those considered high-risk.
  The implementation and coordination of the Strategy will be carried out by the Coordination Executive Committee (CEC) for preventing and combating ML/TF/PF, and its actions will be implemented by all national actors involved in this Strategy. 23 – Financing and Sustainability
• Financing and cost estimation are crucial for the successful implementation of the National System for Preventing and Combating ML/TF/PF Sustainability and Continuity Strategy - 2026-2030.
• The strategy's financing approach involves mobilizing financial resources from various sources, combining both conventional and innovative methods. This combination of funding sources and strategic allocation are essential to achieve the strategic objectives defined by the Government.
• Efficiency and sustainability in the use of these resources are fundamental to ensure continuous progress and long-term economic stability.
• The Government will ensure that these resources are managed responsibly and transparently, guaranteeing that they are applied effectively to promote confidence among investors and partners, resulting in more sustainable commercial relations and investments.
  Sources of Financing for the Sustainability Strategy of the National System for Combating Money Laundering, Terrorist Financing, and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF), 2026-2030 Indication of the Source and/or sources of financing.
• The investment for implementing the national system's continuity and sustainability strategy for combating ML/TF/PF will respect financing by pillar and/or strategic objective.
• The budget for implementing the activities of this strategy will be the responsibility of each sector, which must manage its sectoral budget to ensure the execution of the aforementioned activities.
  VII. Accountability
  The High-Level Committee will meet monthly to evaluate and decide on the status of the implementation of this strategy and other matters related to the sustainability of the system for preventing and combating money laundering, terrorist financing, and proliferation of weapons of mass destruction. The CEC must monitor and regularly evaluate the effectiveness of the activities to be developed within the strategy in order to present necessary adjustments. The CEC will hold a monthly meeting with the Focal Points Group and submit the activity balance to the High-Level Committee. The CEC will hold a biweekly meeting with Subcommittees. Without prejudice to the above, however, the CEC may convene extraordinary meetings on the implementation of this strategy and/or related matters.
  VIII. Expected Results
  The removal of Mozambique from the Grey List shows successful compliance with a sufficient number of FATF recommendations. The strategic actions presented represent a range of activities to consolidate and increase confidence in the system for preventing and combating Money Laundering, Terrorist Financing, and Proliferation Financing of Weapons of Mass Destruction, as well as improving the country's image. However, Mozambique must ensure the sustainability of its system within the implementation of the effectiveness and technical compliance required by the FATF.
  5.1. Increased confidence in the Mozambican financial system
• As a result of applying the Sustainability Strategy for ML/TF/PF Systems, Mozambique will show commitment to adhering to international standards and its efforts to mitigate financial crimes, in order to contribute to a stable and reliable market environment.
• This situation will increase confidence among investors and partners, resulting in more sustainable commercial relations and investments.
  5.2. Facilitation of international financial transactions in particular
• With a stronger regulatory reputation, Mozambique has the potential to increase its appeal as an exemplary jurisdiction for international banks and financial institutions.
• Consequently, Mozambique may see a reduction in enhanced due diligence required by external parties, thereby reducing transaction costs.
• This reinforced confidence can minimize delays and lead to smoother foreign currency transactions for companies. With reduced perceived risk, loan costs for companies based in Mozambique may also decrease, making financing more accessible.
• This simplified process will not only promote a more efficient business environment but will also increase Mozambique's attractiveness as a respected business center.
  IX. Conclusion
  The implementation of the National System for Preventing and Combating ML/TF/PF Continuity and Sustainability Strategy (2026–2030) constitutes an unequivocal affirmation of the State's political will to consolidate a robust, credible system aligned with the highest international financial integrity standards. This Strategy reflects the recognition that preventing and combating these crimes represents a fundamental pillar of national security, economic stability, and the confidence of citizens and the international community in the Country's institutions. By ensuring the continuity of public policies in this domain, the Strategy aims to preserve the progress achieved, avoid institutional setbacks, and reinforce the resilience of the national system against emerging risks and increasingly complex and transnational threats. In this context, the adoption of this translates into a long-term commitment to good governance, the Rule of Law, and transparency, essential elements for the credibility of the financial system and for the Country's attractiveness in the international economic and financial sphere. The National System for Preventing and Combating ML/TF/PF Continuity and Sustainability Strategy and its respective Implementation Plan also reinforce the highest-level political commitment, promoting permanent and effective articulation between sovereign bodies, the Government, the High-Level Committee, and technical coordination structures, namely specialized Subcommittees. This integrated approach will ensure coherence in policy definition, efficiency in its execution, and a coordinated and consistent response to national and international challenges, while strengthening cooperation and constructive dialogue with international bodies and strategic partners. Additionally, the National System for Preventing and Combating Money Laundering, Terrorist Financing, and Proliferation Financing of Weapons of Mass Destruction Continuity and Sustainability Strategy and its respective Implementation Plan constitute a mobilizing instrument for all bodies and institutions with responsibilities in the system for preventing and combating money laundering, terrorist financing, and proliferation financing of weapons of mass destruction, promoting a clear assumption of responsibilities and the reinforcement of the culture of compliance, integrity, and institutional responsibility. By emphasizing continuous capacity building, modernization of supervision and inspection mechanisms, adequate allocation of human, technical, and financial resources, the Strategy will create the necessary conditions for the effective exercise of functions assigned to each entity, as well as for mitigating the improper use of non-financial activities and professions for illicit purposes. Finally, the implementation of this Strategy reaffirms the State's commitment to full compliance with FATF Recommendations and other relevant international instruments, consolidating the Country's position
  as a responsible and reliable partner in the global fight against ML/TF/PF. It is, thus, a strategic decision that reinforces national sovereignty, protects the national and international financial system, and will contribute to sustainable, inclusive economic development based on integrity and legality. List of Acronyms CML – Combating Money Laundering CML/TF/PF – Combating Money Laundering and Combating Terrorist Financing and Proliferation Financing of Weapons of Mass Destruction CEC – Coordination Executive Committee MA – Mutual Evaluation NCAA – National Conservation Areas Administration NRA – National Risk Assessment DNFBP – Designated Non-Financial Businesses and Professions TA – Tax Authority BM – Bank of Mozambique ML – Money Laundering ML/TF – Money Laundering and Terrorist Financing STR – Suspicious Transaction Report SCUN – United Nations Security Council ESAAMLG – Eastern and Southern Africa Anti-Money Laundering Group TF – Terrorist Financing FATF – Financial Action Task Force CCGC – Central Office for Combating Corruption MFIU – Mozambique Financial Intelligence Unit GCPCD – Central Office for Preventing and Combating Drugs MTG – Multisectoral Technical Group ICRG – International Cooperation Review Group IMF – Microfinance Institutions IGJ – General Inspection of Gaming ISSM – Mozambique Insurance Supervision Institute PF – Proliferation Financing of Weapons of Mass Destruction MF – Ministry of Finance MINEC – Ministry of Foreign Affairs and Cooperation MINT – Ministry of Interior MJACR – Ministry of Justice, Constitutional Affairs, and Religious Affairs OAM – Order of Lawyers of Mozambique OCAM – Order of Accountants and Auditors of Mozambique NPO – Non-Profit Organizations UN – United Nations Organization AGO – Attorney General's Office PEP – Politically Exposed Persons RC – Commercial Registry SA – Anonymous Society NCIS – National Criminal Investigation Service SISE – State Intelligence and Security Service SC – Supreme Court KPMU – Kimberley Process Management Unit

334 I SERIES — NUMBER 71
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Activity Lines Responsible Institution Deadlines Approval of the Decree Creating the Coordination Executive Committee (CEC), which revokes Resolution No. 57/2023, of December 29, which creates the Coordination Executive Committee (CEC), providing, among other aspects, the inclusion of the High-Level Committee and Subcommittees in its composition. MF 15-Apr-26 Formalize the High-Level Committee and technical subcommittees, namely: the Law Enforcement Authorities (LEAs) subcommittee, Financial Institutions (FIs) subcommittee, and Designated Non-Financial Businesses and Professions (DNFBPs) subcommittee. MF 15-Apr-26 Recruitment of Human Resources and establishment of the permanent secretariat for the CEC (6 Technicians, 1 technician per 2 Immediate Results) MF 15-Apr-26 Mobilization of financial resources for the CEC MF 15-May-26 Acquisition of a technological system for control and Monitoring of CEC activities + Web Page MF 15-May-26 Interoperability between inter-sectoral systems and the CEC control and Monitoring system MF December 2026 Activity Lines Responsible Institution Deadlines Periodic Review of ML/TF/PF Law and its respective MFIU Regulation MFIU 30 June 2027 Periodic Review of Terrorism Law and its respective MFIU Regulation MFIU 30 September 2027 Periodic Review of the Law on Mutual Legal Assistance - Law establishing the principles and procedures of International Legal and Judicial Cooperation in Criminal Matters AGO 30 June 2027 Periodic Review of the Penal Code MJACR 30-Jun-27 Approval of the Civil Confiscation Law AGO 30 June 2028 Approval of the Law Regulating NPOs MJACR 30 November 2026 ACTION PLAN - SUSTAINABILITY STRATEGY OF THE NATIONAL SYSTEM FOR PREVENTING AND COMBATING MONEY LAUNDERING, TERRORIST FINANCING, AND PROLIFERATION FINANCING OF WEAPONS OF MASS DESTRUCTION - 2026-2030 Strategic Objective 1: Strengthen cooperation, coordination, and communication mechanisms at the national and international levels, as well as the understanding of Money Laundering, Terrorist Financing, and Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF) risks Intervention Area 1: Formalization of the Coordination Executive Committee (CEC), with clear attributions and high-level institutional representation Intervention Area 2: Legislative Reform - Conform the legal framework in accordance with the revised recommendations 1, 2, 4, 8, 15, 16, 24, 25, 30, 31, 38, 40 of the FATF Methodology

16 DE ABRIL DE 2026 335
Proof
Periodic Review of the CREL Regulation to include only the mandatory registration of companies with higher ML/TF/PF risk MJACR 30 March 2026 Periodic Review of the Commercial Code to eliminate the existence or alteration of the denomination of anonymous societies MJACR 30 March 2026 Regulate the activity of virtual assets and their service providers (it is suggested to extend deadlines to adjust regulations, given the complexity of the matter, however it refers to the review of Banking Legislation and Civil Procedure Code etc. BdM 30 March 2027 Activity Lines Responsible Institution Deadlines Ensure the update of the current legal framework, taking into account FATF recommendations that have undergone significant changes, which may impact the currency of the national legal framework for preventing and combating ML/TF/PF CEC Permanent Review internal guidelines for risk-based approach CEC December 2026 Capacitate Financial Institutions on proportionality in simplified measures within the risk-based approach CEC 15 March 2027 Implement simplified measures for low-risk clients CEC December 2028 Conduct the Risk Assessment of Proliferation Financing of Weapons of Mass Destruction (ML/TF/PF), with specific indicators to evaluate this matter CEC December 2028 Activity Lines Responsible Institution Deadlines Conduct National Risk Assessment of ML/TF/PF - 2027-2032 CEC December 2026 Disseminate NRA results to sectors identified as most vulnerable to ML/TF/PF on Web Pages CEC 15 March 2027 Coordinate the conduct of the National Risk Assessment of TF/PF 2029-2034 CEC December 2028 Coordinate the conduct of sectoral risk assessments - NPOs 2029-2034 CEC December 2028 Conduct sectoral risk assessments for sectors supervised by MFIU, OAM, OCAM, KPMU, NCAA, ISSM, IGJ, BdM MFIU, OAM, OCAM, KPMU, NCAA, ISSM, IGJ, BdM December 2028 Strengthen interaction with the ESAAMLG Secretariat for understanding ML/TF/PF risks in the region. MFIU Permanent Activity Lines Responsible Institution Deadlines Celebration and review of MoUs between entities and strengthen inter-institutional cooperation CEC Permanent Strengthen coordination and International Cooperation mechanisms between Financial Intelligence Units (FIUs), Law Enforcement Authorities, and Supervisors SC, AGO, NCIS, MRA, NCAA, MFIU, BM, ISSM, IGJ Permanent Intervention Area 3: Completeness in Risk-Based Assessment - Need to incorporate proportional risk assessment in all financial institutions Intervention Area 4: Risk Understanding for Competent Authorities and Obligated Entities Intervention Area 5: Promotion of the signing of Memoranda of Understanding (MoUs)

336 SERIES — NUMBER 71
Proof

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Ensure the existence and availability of adequate financial, human, and technological resources on the part of supervisors, especially the sectors identified as high risk | GIFiM, OAM, OCAM, UGPK, ANAC, ISSM, IGJ, BdM | December 2027

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Review the Guidelines and Manuals of supervisors to conform to existing risk | GIFiM, OAM, OCAM, UGPK, ANAC, ISSM, IGJ, BdM | December 2027 Ensure the updating of the current legal framework, taking into account the recommendations of the FATF that have undergone significant changes, which may have a major impact on the currency of the national legal framework for the prevention and combating of ML/FT/CPF | GIFiM, OAM, OCAM, UGPK, ANAC, ISSM, IGJ, BdM | December 2027

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Conduct off-site and on-site inspections of high-risk sectors Conduct monitoring and evaluation to assess the degree of execution and effectiveness Application of persuasive and proportional counter-measures for non-compliance with the duties provided for obligated entities in case of infringement Create the database on administrative sanctions/persuasive and proportional measures applied for non-compliance with the law Acquisition of regulatory technology to assist in inspection and data analysis activity (Software)

Intervention Area 5: Organize the informal sector, the real estate sector, and vehicle purchase and sale

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Create regulatory and supervisory entities for the real estate and vehicle purchase and sale sectors | MF | 30 June 2026 Register all entities in the real estate sector (intermediation), vehicle purchase and sale | GIFiM | 30 June 2026 GIFiM, OAM, OCAM, UGPK, ANAC | Permanent

Intervention Area 1: Promote the application of the risk-based approach to the activities of obligated entities Intervention Area 3: Promote training and capacity-building actions, including the preparation of sectoral guidelines for obligated entities most vulnerable to ML/FT/CPF Continue with adequate training for obligated entities, prioritizing high-risk sectors Promote adequate training for supervisors to better perform supervisory and inspection functions; Intervention Area 4: Strengthen risk-based supervision and inspection, including the development of adequate tools for inspections (on-site/off-site);

STRATEGIC OBJECTIVE 2: Strengthen and reinforce the institutional, technical, technological, and human capacity of national authorities in matters of prevention and combating of ML/FT/CPF, supervision and inspection of obligated entities Intervention Area 2: Improve and/or perfect AML/CFT/CPF manuals, guidelines, and carry out dissemination activities with Financial Institutions (FIs) and Designated Non-Financial Businesses and Professions (DNFBPs) GIFiM, OAM, OCAM, UGPK, ANAC, ISSM, IGJ, BdM CEC/Supervisors

16 APRIL 2026 337
Proof

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Provide adequate financial, technological, and human resources to CREL for the continuous updating of Beneficial Owner (BO) information of legal persons | MJCR | December 2026 Ensure that CREL is more diligent regarding the duty to verify, identify information (valid) provided by entities and also regarding trust funds (Beneficial Owners) | MJCR | December 2026 Improve the identification of beneficial owners of legal persons and entities without legal personality, based on risk | MJCR | December 2026 Ensure rapid access to Beneficial Owner (BO) information by competent authorities | MJCR | December 2026 Review the sectoral risk assessment of legal persons and entities without legal personality | MJCR | December 2026 Inclusion of the List of United Nations sanctions and National designated Lists in the CREL System | MJCR | December 2026

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Increase human, financial, and technological resources | MF | March 2026 Acquire technological means to improve the analysis of STRs and dissemination of RIFs | GIFiM | Permanent Ensure continuous training in the field of analysis | GIFiM | Permanent Improve the capacity for monitoring and analysis of STRs | GIFiM | November 2026 Strengthen, standardize the quality and quantity of suspicious transaction reports by obligated entities | GIFiM | Permanent Improve the quantity, quality of RIFs and RAEs and timeliness in their dissemination | GIFiM | Permanent Access more national databases remotely | GIFiM | Permanent Improve the capacity for feedback with obligated entities | GIFiM | Permanent

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Ensure continuous training in the use of RIFs for crime prevention and combating of ML/FT/CPF investigations | GIFIM | Permanent Prioritization of the use of RIFs in investigations of ML/FT/CPF crimes | PGR, SERNIC, ANAC, AT, GIFiM | Permanent

STRATEGIC OBJECTIVE 3: Strengthen transparency measures applicable to individuals, legal persons, and entities without legal personality, to mitigate risks associated with financial operations and transactions Intervention Area 1: Improve the identification of beneficial owners of legal persons and entities without legal personality, based on risk

STRATEGIC OBJECTIVE 4: Strengthen the analysis, prevention, detection, investigation, prosecution, and judgment of ML/FT/CPF crimes, and asset recovery Intervention Area 1:
Intervention Area 2: Strengthen the capacity of law enforcement authorities to conduct effective investigations based on Financial Intelligence Reports (RIFs) Improve GIFIM's capacity to conduct STR analyses

338 SERIES — NUMBER 71
Proof

Intervention Area 3: Promote international cooperation (AML) in AML/CFT/CPF prevention and combating activities

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Promote technical and specialized training of competent authorities in matters of mutual legal assistance | TS, SERNIC and GIFiM | December 2026 Strengthen legal and institutional mechanisms that allow for the identification, seizure, confiscation, and repatriation of illicit assets, both within national territory and abroad. PGR December 2026 Strengthen specialized asset recovery and management units in human, technological, and financial means. | PGR | December 2026 Facilitate the exchange of information between countries and the execution of confiscation and repatriation requests (through the signing of agreements, memorandums). | PGR | December 2026 Update bilateral/multilateral treaties and protocols in matters of mutual legal assistance. | PGR | December 2026 Improve the request and response system for the freezing and confiscation of assets in other countries. | PGR | December 2026

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Ensure the existence and functioning of statistical systems of Law Enforcement Authorities | TS | June 2026 Ensure the Interoperability of statistical systems of law enforcement authorities | TS | December 2026 Formalize and strengthen its comprehensive statistics system on the number and nature of ML/FT/CPF investigations, prosecutions, and trials, including various types of crimes and predicate crimes TS June 2026

STRATEGIC OBJECTIVE 5: Ensure the implementation of a national strategy to combat terrorist financing, in compliance with international standards

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Finalize the implementation of the terrorist financing and weapons of mass destruction financing strategy | GIFiM | December 2026 Ensure training and training actions on the legal and institutional structure for the implementation of Targeted Financial Sanctions (TFS) | GIFiM | Permanent Provide written guidance and dissemination to FIs and DNFBPs on the implementation of Targeted Financial Sanctions (TFS) Continue to develop and implement Awareness Plans on TF and CPF TFS | GIFiM | Permanent Include VASPs (brokers, crypto-asset platforms, etc.) in the legal framework for the prevention of TF/CPF | BM | November 2026 Request the extension of deadlines regarding the inclusion of VASPs (brokers, crypto-asset platforms, etc.) in the legal framework for the prevention of TF/CPF, as this matter involves the revision of other legal instruments (e.g., Civil Procedure Code, Banking Legislation) BM Extension of Deadline Conduct the National Risk Assessment of financing the Proliferation of Weapons of Mass Destruction | CEC December 2027

Intervention Area 4: Adopt measures for the Interoperability of Law Enforcement Systems Intervention Area 1: Ensure the implementation of the national strategy to combat terrorist financing and Financing of the Proliferation of Weapons of Mass Destruction

16 APRIL 2026 339
Proof

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Mobilize human, financial, and technological resources for GIFiM, SERNIC, and PGR | MF | December 2026 Improve institutional coordination between PGR, SISE, GIFiM, and SERNIC | PGR | December 2026 Demonstrate through case studies and statistics the capacity to conduct TF/CPF investigations and pursue processes according to Mozambique's TF/CPF risk profile | PGR | December 2026

Lines of Activity | Responsible Institution | Deadlines --- | --- | --- Categorize and Map NPOs according to FATF Recommendation 8 | MINEC, MJCR, and CEC | June 2026 Promote awareness only among high-risk NPOs | MINEC, MJCR, and CEC | Permanent Hold regular meetings with NPOs | CEC | Permanent

Intervention Area 2: Continue to increase the capacity of GIFiM, SERNIC, and PGR in the prevention and combating of TF/CPF Intervention Area 3: Categorization and risk mapping of Non-Profit Organizations (NPOs)

Price — 70.00 MT
NATIONAL PRESS OF MOZAMBIQUE, E.P.