Resolution No. 56/2023: Approves the National Strategy to Combat Terrorist Financing, 2024-2029

Proof
SUMMARY
NOTICE
The matter to be published in the "Boletim da República" must be submitted in a duly authenticated copy, one for each subject, which must contain, in addition to the necessary indications for this purpose, the following endorsement, signed and authenticated: For publication in the "Boletim da República". NATIONAL PRESS OF MOZAMBIQUE, E.P. 6th SUPPLEMENT Council of Ministers:
Resolution No. 55/2023:
Approves the Report on the National Risk Assessment of Terrorist Financing.
Resolution No. 56/2023:
Approves the National Strategy to Combat Terrorist Financing, 2024-2029.
Resolution No. 57/2023:
Creates the Executive Committee for the Coordination of Policies on the Prevention and Combating of Money Laundering and Terrorist Financing.
Friday, 29 December 2023 I SERIES — Number 250 COUNCIL OF MINISTERS Resolution No. 55/2023 of 29 December Given the need to approve the Report on the National Risk Assessment of Terrorist Financing, under paragraph 6 of Article 57 of Law No. 14/2023, of 28 August, which establishes the Legal Regime and Measures for the Prevention and Combating of Money Laundering, Terrorist Financing, the Council of Ministers determines:

Article 1. The Report on the National Risk Assessment of Terrorist Financing, attached, which is an integral part of this Resolution, is approved.

Article 2. This Resolution enters into force on the date of its publication.

Approved by the Council of Ministers, on 19 December 2023.
Publish.
The Prime Minister, Adriano Afonso Maleiane.

Report on the National Risk Assessment of Terrorist Financing Executive Summary

Mozambique carried out the National Risk Assessment (NRA) of Terrorist Financing (TF) between April and November 2023, with the aim of identifying threats, vulnerabilities, and understanding the existing risks in the regime for the prevention and combating of Terrorist Financing, as resulting from the Recommendations of the Financial Action Task Force (FATF), which establish the need to adopt a risk-based approach.
The NRA aimed to improve the level of knowledge and understanding of TF threats and vulnerabilities, in order to define priorities in resource allocation, aiming at the mitigation of identified risks.
Mozambique approved a new legal and institutional framework for the prevention and combating of Terrorism and its Financing, through Law No. 14/2023, of 28 August, on the prevention and combating of Money Laundering, Terrorist Financing and Financing of the Proliferation of Weapons of Mass Destruction, and Law No. 15/2023, of 28 August, on the prevention and combating of Terrorism and the Proliferation of Weapons of Mass Destruction.
Regarding threats from persons and organizations, the group identified only one organization named Ahlu Sunnah Wal Jamaah (ASWJ), which has perpetrated terrorist acts in Northern Mozambique, especially in the province of Cabo Delgado.
The threat level of the terrorist organization ASWJ is high with a decreasing trend. Military operations carried out by the Defence and Security Forces, with the support of SAMIM and the Rwanda Defence Forces, resulted in a significant reduction in the combat capacity of terrorists. This reduction in combat capacity is demonstrated through the recovery of control of areas previously under strong terrorist influence in the districts of Mocímboa da Praia, Palma, and Nangade, which has allowed the gradual return of the population to their areas of origin, as well as the implementation of the Cabo Delgado Reconstruction Plan (PRCD 2021-2024) in affected areas.
The NRA identified the sectors of commercial banking, electronic money, informal channels for fund transfers, fauna, flora and fishery products, and mineral resources as susceptible to being used for TF.
The risk level of these sectors is generally medium-high, with the most serious risk sectors being mineral resources, electronic money, and fauna, flora, and fishery resources.

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Regarding national vulnerabilities, it was concluded that the general level is medium, with the most critical factors being the capacity and resources for competent investigation of financial crimes, capacity and quality of information collection on TF by institutions, and controls on migratory flows, goods, including strategic goods.
From the collected data and analysis carried out, a medium-high TF risk level in the national territory was reached, with a decreasing trend.

I. Introduction

Terrorist Financing, according to the International Convention for the Suppression of the Financing of Terrorism (FT), approved by the United Nations in 1999, consists of the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or knowing that they will be used, wholly or partially, with a view to the commission of terrorist acts or any other act intended to cause death or serious bodily injury to a civilian or to any other person not taking part directly in hostilities in an armed conflict, whenever the purpose of such act, by its nature or context, is to intimidate a population or to compel a government or an international organization to do or abstain from doing any act.
For the Convention in reference, the term "funds" comprises assets of any nature, tangible or intangible, movable or immovable, acquired by any means, and documents or legal instruments, whatever their form, including electronic or digital, which attest ownership or other rights over such assets, but without this enumeration being exhaustive, bank credits, travel cheques, bank cheques, payment orders, shares, bonds, debentures, bank drafts, and letters of credit.

1.1 Objectives of the National Risk Assessment of Terrorist Financing (NRA TF) in Mozambique

The main objective of the NRA TF is to identify, assess, and understand the terrorist financing risks in the country, and to present guidelines for the consolidation of a more effective legal regime for the prevention and combating of these crimes, through laws, regulations, and guidelines, aimed at mitigating TF risks.
This NRA TF also aims to assist authorities in establishing priorities and in the efficient allocation of human, material, and financial resources, in order to make State institutions more interventionist in the prevention and combating of TF.
At the national level, the NRA TF aims to identify different typologies of TF and thus contribute to the elaboration of a National Strategy for the Prevention and Combating of TF.
Inter-institutional risk assessment is an important step for a better understanding of threats and vulnerabilities in Mozambique, thus contributing to the improvement of the approach on this matter and the development of sectoral plans.

1.2 National Risk Assessment Process

The States' knowledge of the risks to which they are subject in terms of TF, in each area of their territory and in each sector of economic and financial activity, is more than a legal obligation; it is characterized as an essential tool to guarantee the awareness of public and private institutions regarding the prevention of the occurrence of the TF crime, contributing to the adoption of risk mitigation measures.
With the revision of the FATF Recommendations in February 2012 and subsequent updates, enshrining a risk-based approach, the recommendation determined that countries must, first of all, identify, assess, and combat the TF risks to which they are exposed, adopting subsequently, in conformity with the already identified risks, all adequate measures to attenuate them1.
In this context, as a result of the Action Plan agreed between the Government of Mozambique and the FATF, adopted on 22 October 2022, the Government of Mozambique decided to conduct and update the NRA TF with the aim of reinforcing and deepening the collective understanding of TF risks, and equipping national authorities with an essential instrument to more effectively allocate scarce available resources and to apply preventive measures proportional to the nature of the risks, thereby optimizing their efforts.

1.3 Organization of the National Risk Assessment Process

For the realization of the NRA TF process, the Group worked with the technical assistance of the World Bank, and adopted the model and tool of that organization. The exercise covered activity sectors with obligations under Law No. 14/2023, of 28 August, which establishes the legal regime for the prevention and combating of TF.
For this purpose, the Government indicated GIFiM as the coordinator of the NRA TF. A working group was constituted, integrated by the following institutions:

a) Financial Information Office of Mozambique (Coordinator); b) National Criminal Investigation Service (SERNIC); c) Ministry of National Defence (MDN); d) Ministry of Foreign Affairs and Cooperation (MINEC); e) Attorney-General's Office (PGR); f) State Intelligence and Security Service (SISE); g) National Criminal Investigation Service (SERNIC); h) Bank of Mozambique (BM); i) Mozambique Tax Authority (AT); j) National Administration of Conservation Areas (ANAC); k) Kimberley Process Management Unit (UGPK).

1 "Countries should identify, assess and understand the risks of money laundering and terrorist financing to which they are exposed, and should adopt measures, including the designation of an authority or mechanism to coordinate risk assessment actions, and mobilize resources, in order to ensure that risks are effectively mitigated. Based on this assessment, countries should apply a risk-based approach to ensure that measures to avoid or mitigate money laundering and terrorist financing are proportional to the identified risks. This approach should constitute the essential basis for efficient resource allocation within the AML/CFT regime and the implementation of risk-based measures for all FATF Recommendations. In cases where countries identify higher risks, they should ensure that their AML/CFT regime addresses such risks appropriately. In cases where countries identify lower risks, they may decide to permit, under certain circumstances, the application of simplified measures for some of the FATF Recommendations. Countries should oblige financial institutions and designated non-financial businesses and professions to identify and assess their respective money laundering and terrorist financing risks and to adopt effective measures to mitigate them."

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The members of the Working Groups proceeded with the collection of information and statistical data referring to the years 2018 to 2023, through questionnaires, direct contacts with sectors, collection of information in sectoral reports and intelligence information, among others, at the central and provincial levels, for the discussion and analysis of data, for the filling in of matrices and tools of their respective modules.

1.4 National Risk Assessment Methodology

In terms of methodology, a top-down approach was applied, that is, starting from a general view of the phenomenon at the national level to a specific/sectoral view.
A method was chosen that allowed the collection of statistical information on threats and vulnerabilities, to carry out diagnosis and scenario analysis, and to compare vulnerabilities resulting from various sectors, which allowed prioritizing and following up on potential actions and measures for the prevention and combating of TF.

1.5 Contextualization

Mozambique is located in the southern zone of the African continent, integrating into the Southern Region, with a total surface area of 801,590 km², with a population universe of 32,419,747 inhabitants2, projection of 2023. To the North it borders the United Republic of Tanzania, to the West with Zambia, Malawi, Zimbabwe and South Africa, to the Southwest and South with South Africa and Eswatini, to the East, with the Indian Ocean. It is divided into 11 provinces, namely, Niassa, Cabo Delgado, Nampula, Zambézia, Tete, Manica, Sofala, Inhambane, Gaza, Maputo and Maputo City3, capital of the Country, in 154 Districts and 65 Municipalities. The official language is Portuguese.
The coastline has a length of about 2,700 km, which includes sandy beaches, coastal dunes, coral reefs, estuaries, bays, forests, and mangrove swamps, seagrass beds. The coast also has numerous islands such as the Quirimbas Archipelago, the islands of Ibo and Mozambique, the Islands of Angoche and Primeiras, the Island of Chiloane, the Bazaruto Archipelago, the Xefinas Islands, Portugueses and Inhaca.
Mozambique achieved its National Independence on 25 June 1975, having approved the first Constitution of the Republic, with a one-party system and a People's Assembly, which was amended in 1990, at which time the multi-party system was introduced. The Constitution of the Republic was successively updated to accommodate new developments, the last being in 2018.
Regarding the Legal System, the Republic of Mozambique adopted the Romano-Germanic orientation, also known as "Civil Law", being governed by a Constitution that establishes a Law and a Democratic State. It has three branches of power, namely the Executive Power (President of the Republic and the Government or Council of Ministers), the Legislative Power (Parliament) and the Judicial Power, which comprises the organs of Administration of Justice. The Constitution of the Republic of Mozambique guarantees the separation of the aforementioned powers.
The Country has been registering notable economic growth, with Gross Domestic Product (GDP) growing at an average above 4.7% per year. In monetary terms, Mozambique has one of the most liberalized exchange regimes in Africa. The external reserves of the Central Bank have been situated above four months of imports of goods and services.
The economic potential of the Country for attracting investments in agro-industry, agriculture, tourism, fishing, and mining is widely considerable. Projects such as Mozal, Cahora Bassa Dam, Railway-Port Corridors, and Tourist Complexes throughout the Country have contributed significantly to placing Mozambique on the route of major regional and international investments.
The main export products of Mozambique are Aluminium, Mineral Coal, Bauxite, Graphite, Heavy Areas, Gold, Rubies, Tobacco, Wood, Electricity, Iron, Steel, and Natural Gas.
Terrorist Financing Risks

2.1. Terrorist Financing Risks at the National Level

2.1.1. Country Context regarding Terrorist Financing

The Republic of Mozambique is located in the Southern region of Africa, with about 2,700 km of maritime coast and about 4,212 km of land borders, with a patrol capacity of slightly more than 60%.
Since 2012, signs of criminal activity have begun to be felt, characterized by immigration and illegal mining, smuggling, drug trafficking, and piracy, under the influence of radical Islamic agents who gradually entered Mozambican territory.
The province of Cabo Delgado, located in the north of Mozambique, borders the United Republic of Tanzania4 and is abundantly rich in mineral and energy resources, such as, petroleum, gas, gold, graphite, marble, rubies, among others, and fauna and flora.
Some studies5 point out that the objective of terrorist acts is to create opportunities and platforms for illicit business in the region, among which, the trafficking of wood, ivory, charcoal, rubies, and narcotics.
The interface between organized crime syndicates in the Southern Africa region with terrorists in Mozambique, especially in the domain of narcotics, is duly documented6. Reports of heroin trafficking from Afghanistan and Pakistan, transported by sea to the Provinces of Cabo Delgado, Nampula, and Inhambane, in transit, to South Africa and from this country to Europe, are contained in several reports addressing transnational organized crime7.
The situation of instability and terrorist actions in the Horn of Africa and in the Democratic Republic of Congo, associated with the

2 According to the Population Projection 2017 – 2050 of the National Institute of Statistics (INE).
3 Has province status
4 Shares the Swahili language, customs and traditions, and the Islamic religion, without prejudice to a common historical past of brotherhood.
5 MACALANE, Geraldo et al. Terrorist Attacks in Cabo Delgado (2017-2020): The Causes of the Phenomenon by the Mouth of the Population of Mocímboa da Praia. Extension of Cabo Delgado of Rovuma University. 2020.
6 FRANCISCO, F. (2018), Studies of the Security Systems of State Borders in Mozambique Facing New Threats to Internal Security, Doctoral Thesis in Law and Security by the Faculty of Law of the New University of Lisbon. pp. 89 7 CIP (2018), Anti-Corruption Transparency and Integrity Review, Edition 7/2018; PGR (2022), Annual Information of the Attorney-General of the Republic to the Assembly of the Republic of Mozambique – 2022; Global Initiative (2021), From Afghanistan to Cabo Delgado – Political volatility along the southern route of drug trafficking

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porosity of national borders and the fragility of institutions, constitute and facilitate the possibilities of financing for terrorist groups in Mozambique.

Terrorism in northern Mozambique grew rapidly
since October 2017 exploiting the factors listed above, with the objective8 of creating a buffer zone from which to have a safe haven for the development of illicit activities, such as processing and exporting heroin received from Afghanistan and Pakistan by sea, as well as extraction and smuggling of ivory, gold, and rubies.
In these terms, a significant part of the mentors and
personnel used in the extremist expedition in the North of Mozambique comes from countries in conflict or at potential risk of extremist activity, namely, United Republic of Tanzania, Uganda, Kenya, Democratic Republic of Congo, and Somalia, which found fertile ground in the poverty of populations, contradictions in the interpretation of certain precepts of religion among Muslim communities, and the weak presence of the State in certain inland regions, as often happens in many African countries, for the recruitment of young Mozambicans.
Finally, the consolidation of the climate of terror and anarchy
could facilitate the obtaining of funds for the financing of terrorist actions inside and outside the country, which would constitute a risk in terms of a possible expansion of radical Islamic actions throughout Africa.

2.2 Threat of TF by Terrorist Persons and Organizations
2.2.1. General Analysis

Regarding existing terrorist persons/organizations in Mozambique, after discussions and analysis of information carried out by the ANR-FT working team, with a view to identifying existing individuals or terrorist organizations, only the terrorist organization ASWJ was identified, which was the specific object of analysis by the group.

As per the information presented below, in general terms, given the existence of a terrorist organization, combined with the existence of other factors, the ANR-FT group classified the threat level as High.

2.2.1.a General threat level

Regarding the assessment of the threat level
of terrorist activity, we can say that until 2021, it was very high, because on our territory, specifically in the northern region of Cabo Delgado province, the terrorist group designated as Ahlu Sunnah Wal Jamaah 10, also known internationally as ISIS-Mozambique, and locally designated as Al-Shabaab11, had the potential to expand to other regions of the Country to carry out terrorist attacks and could even expand into neighboring countries.
Taking into account the real threat and the potential risk for
regional security, the Government of the Republic of Mozambique requested support from the international community, having approved the SADC Military Mission in Mozambique (SAMIM), the European Union Training Mission in Mozambique (EUTM-Moz), including the deployment of a contingent of the Rwanda Defence Forces (RDF).

8
Scientific Journal of ISEDEF, Defense and Security Series, Vol. 1, 2021 9 NYUSI, Filipe Jacinto. Annual Information from the Head of State to the Parliament on the General Situation of the Nation. Maputo, December 16, 2020 10 Designated lists, Dispatch of the Attorney General of July 12, 2023, published in the Official Gazette Series I – number 133. 11 EU (2023), amending Decision (CFSP) 2016/1693 concerning restrictive measures against ISIL (Da’esh) and Al-Qaeda and persons, groups, undertakings and entities associated with them, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023D0848 12 Some individuals considered terrorists, sanctioned and listed nationally and internationally

Joint military operations (Mozambique, SAMIM
and RDF) significantly reduced the combat potential of the terrorists, who therefore adopted dispersion as a survival measure, temporarily spreading their actions to some districts of Niassa and Nampula provinces.
Currently, the center of gravity of the terrorists is located in the district of Macomia.
The terrorist group operating in the northern region of Cabo
Delgado consists of Mozambican citizens and foreigners, with notable individuals of Tanzanian and Somali nationality in leadership positions, namely Mohamed Ahmed QAHIYE, Abu Yasir HASSAN, Abdala HEMEDE, Adamu NHAUGWA, between others.12

2.2.1.b Level of need for funds/resources

The terrorist group evolved over time and space, having
spread its activities from the district of Mocímboa da Praia to other northern regions of Cabo Delgado province, which justified a greater need for mobilization of funds/ resources, especially between the Fourth Quarter of 2020 and First Quarter of 2021.
With the expansion of terrorist acts, the group demonstrated
a need to strengthen its ranks, recruiting more youth, extending training camps, acquiring weapons and communications equipment, vehicles, technical and logistical support infrastructure, paying its affiliates and family members of deployed combatants, and obtaining intelligence.
Meanwhile, with the intensification of military operations,
the terrorists weakened, reducing their capacity to mobilize funds/resources, especially from July 2022 onwards. However, due to the set of holistic measures implemented by the State, and the consequent reduction in the number of attacks carried out by the terrorists, there was also a clear decrease in fund/resource collection activities, which is why the classification of this variable is medium-high.

2.2.1.c Level of fund/resource collection activities

Commercial activities, such as the sale of
basic necessities, attacks on some positions of the Defense and Security Forces (DSF), the practice of robberies in some locations such as commercial establishments, private residences, the illegal exploitation of natural resources, artisanal mining, fishing, and the exploitation of forest and wildlife resources, the sponsorship of fishing activities in the region with materials for fishermen and then obtaining financial proceeds resulting from the sale of fish, demonstrate a very high level of fund collection activity13.
The high number of attacks carried out by the
terrorist group implied a large logistical support, and consequently, the need to practice resource collection activities. However, in the face of state repressive activities and the action of the Defense Forces in the region, with the reduction in the number of attacks carried out by the terrorist group, there was also a clear decrease in fund collection activities, which is why the classification of this variable is medium-high.

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In addition to the aforementioned actions, as a means of
financing, reports from International Organizations operating in the area of terrorism indicate that the terrorist group relied on support from international terrorist organizations through training, instruction, and provision of weapons material. One indicator is that ISIS has claimed attacks occurring in Mozambique.

2.2.1.d Level of fund/resource transfer activities

Access to formal financial services by the Mozambican
population is low, estimated that the level of banking inclusion is around 30%, with the expansion of electronic currency services currently being one of the factors driving financial inclusion and allowing easy movement of funds between people in the country.
At the end of 2021 and beginning of 2022, in Cabo Delgado province, particularly in rural areas, transactions were
made mostly in cash and using mobile wallets (electronic currency), given the non-existence of banks operating in these zones, whereby the terrorists had in this system, due to weak control, the preferred mechanism for moving funds channeled by relatives, friends, sympathizers, and others, and subsequently withdrawn at agents by people with friendship ties who later made delivery in cash for their terrorist activities.

2.2.2. Funding Sources

According to information collected from public information sources and based on facts occurred up to the present moment, the evaluator group identified that ASWJ uses various funding sources, among which stand out robbery of commercial establishments, theft from farms of the population, hospitals and health centers, illegal exploitation of mineral, wildlife, forest, and fisheries resources, and external support.
Cabo Delgado province is rich in mineral and natural resources (forest, wildlife, and fisheries), and in some areas of terrorism incidence, such as the circumscribed zone of Quirimbas National Park, Muidumbe, Macomia, Meluco, and Montepuez, although the latter district has no records of considerable terrorist action, there is occurrence of said resources, facilitating their illegal exploitation and commercialization14.
Similarly, it is suspected that some companies and
other economic agents that continue to operate in the areas of terrorist action are obliged to pay a certain amount to members of the referred terrorist organization, as extortion, to exercise their respective activities.
On the other hand, suspicious movements of
individuals and organizations positioned abroad were noted that finance terrorist activities in Mozambique. As an example, the US Department of the Treasury sanctioned Mohamed Ahmed, of Somali nationality, Farhad Hoomer, Siraaj Miller, Abdella Hussein Abadigga, and Peter Charles Mbaga, of South African nationality, implicated with links to ASWJ 15.
This fact serves as evidence of the existence of some
leaders of the terrorist group operating in Mozambique having been designated by the aforementioned bodies due to links between the terrorist group operating in the country with international terrorist groups, such as the Islamic State terrorist group.
It was also noted that some financial institutions
identified certain NGOs and some religious confessions, with activities in Cabo Delgado, raising large sums of money, for unclear purposes in areas affected by terrorism16.
No less important, the referred terrorist group
self-finances through the development of informal economic activities, such as grocery stores and electronic currency agents, using, for this purpose, the labor of young people from the region recruited for this effect.

2.2.3 Movement and use of resources

The ASWJ group has moved its resources
preferentially through handling of cash values. Fact verified in dismantled terrorist positions, among deserters and captured by the DSF.
On the other hand, the ASWJ group has moved its
resources in the form of physical money and electronic currency, to the detriment of banks. The financial intelligence authorities, notably GIFiM, notified electronic currency provider institutions about the movement of large sums of money from these channels in areas with active terrorist threat. In response to the situation, the Government of Mozambique instructed institutions acting in the area of electronic currency to regularly send reports of suspicious TF transactions.
Currently, the terrorists are besieged in remote areas, a fact that hinders the movement of resources for supply. There has been constant interception, by the Defense and Security Forces, of food products, computer and telecommunications equipment, weapons material, and chemical products (explosive precursors).
Regarding natural resources, it was noted that ASWJ
is involved in the smuggling of fauna and flora products (wood, charcoal, and hunting trophies). This group also uses as a funding source the trade of fish and direct exchange for foodstuffs and other goods. Furthermore, forces on the ground recorded cases of individuals belonging to ASWJ captured in possession of precious stones and metals.

2.2.4 Channels of Terrorist Financing

ASWJ uses as TF channels electronic currency services, smuggling, cash withdrawals, hawala system, bank transfers.
However, this group privileges the use of electronic currency services and smuggling of natural resources, as one of the main TF channels, as this is one of the fastest and most effective ways to channel its funds. In the banking system, there are stricter control mechanisms, which facilitates their tracing.
According to information provided by GIFIM, there are indications of occurrence of transfers and withdrawals of large sums in banking and electronic currency institutions, without known socio-economic reasons in Cabo Delgado. On
13 Based on intelligence information.
14 Lächelt, S., 2004. Geology and Mineral Resources of Mozambique. Ministry of Mineral Resources and Energy, National Directorate of Geology, Maputo, Mozambique. 515 p.; and Marques, J.M.P.R., 2000. Gemstones in Mozambique: present status and potential. Workshop on Tertiary Sector Geoscience Education in Southern Africa - Building regional networks on local expertise Maputo. Extended Abstract Volume, 103-118. 15 See https://sanctionssearch.ofac.treas.gov/Details.aspx?id=39644 16 Information provided by UIF (GIFiM) combined with reports from the Armed Forces on the ground, at the level of Cabo Delgado.

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the other hand, there is evidence of legal and natural persons receiving values through bank transfers in regions affected by terrorist acts, without plausible justification, which may lead to the understanding that some banking operations serve as channels for TF.

2.3 National TF Threat
2.3.1 TF Threat derived from the level of activities
and terrorist attacks in the jurisdiction;

Analyzing since the beginning of the phenomenon of terrorism
in the country, improvements have been registered in the last two (02) years. For this, in the military domain, the specialization of units of the Mozambique Defense Armed Forces (FADM) in counter-terrorism operations with the involvement of partners from the International Community; the reinforcement of operational capacity, through joint operations with SAMIM and RDF in Cabo Delgado, has been decisive for the decreasing trend of terrorism.
The rate of terrorist acts in annual comparative analysis was medium for the years 2017 and 2018, high in 2019, very high in the years 2020 and 2021, high in 2022, and medium in 2023. In the same period, the mortality rate, resulting from indiscriminate attacks on the population in 2017 and 2018, was medium, between 2019 and 2022 very high, standing above 250 deaths per year. Currently, the trend is decreasing, having dropped to less than 100 deaths in 2023, classifying as medium.

Terrorist Acts Mortality
Classification Variation Classification Variation 2017 Low 01 – 05 Medium < 50 2018 High 10 – 100 High 50 - 250 2019-2020 Very high > 100 Very high > 250 2021-2022 Medium 05 – 10 Very high > 250 2023 Medium 05 – 10 Medium < 50 Actions Period

During this period, terrorist acts consisted of murders (decapitations), kidnappings, extortion, exploitation, and sexual enslavement, forced marriages, looting of goods and products from the population, banks, and economic agents, house fires, imposition of radical Islamic ideology, intimidation, and death threats, among other practices.
The terrorist acts left marks of pain, mortal damages, responsible for approximately 900,000 internally displaced persons in Cabo Delgado, destruction of public and private institutions, paralysis of commercial activities and provision of basic services, and retreat of foreign investment in the country18.
In the business area, according to the National Federation of Agrarian Associations of Mozambique19, little more than 400 companies were affected and approximately 56,000 jobs were lost. The district of Mocímboa da Praia figures as the most affected, with approximately 40% of companies, 23% of jobs lost due to terrorist attacks.
Terrorist attacks in Cabo Delgado affected the business sector considerably, mainly in the districts of Macomia, Quissanga, Nangade, Palma, Mocimboa da Praia, and Muidumbe. Looking at indicators such as number of affected companies, number of affected workers, and the economic impact that unfolds into damage to physical capital, loss of agricultural production, and loss of flow of activities in value chains, as can be observed in the CTA report on the Impact of Terrorist Attacks in Cabo Delgado on the Business Sector20.
Tourism decreased significantly, implying a reduction in public revenues. The image of the Country at the international level was affected, causing the level of the Global Poverty Index not to register significant improvements.
Although the trend of attacks is currently decreasing, the level of activities connected to terrorist acts is high. These are related to the fact that a significant part of the terrorists operating in Cabo Delgado are recruited locally and in neighboring provinces, with some terrorists having affective relations with part of the population in the territory, thus being able to access information, logistical supply, and/or recruitment networks based on familial and religious affection.
At the level of connected activities, the trend is increasing in the last two years, with the association of ASWJ with other terrorist organizations in the region such as ADF and ISCAP, and in the world, with ISIS publishing and claiming attacks in Cabo Delgado, the group began to receive monetary and logistical support from other countries in Africa (South Africa, Tanzania, Kenya, and DRC) and the world. Moreover, the radicalization material collected in territories recovered by the FDM in Mozambique is from ISIS22.

2.3.2 TF Threat from Terrorist Organizations, Groups
and Individuals in the jurisdiction;

The TF threat from terrorist organizations, groups, and individuals in the jurisdiction is at a high level, with a decreasing trend.

17 Verifiable in various journalistic sources such as: Diário de Notícias, at: https://www.dn.pt/internacional/criancas-decapitadas-um-milhao-de-pessoas-com-fome-a-crise-no-norte-de-mocambique-13466143.html; DW, at https://www.dw.com/pt-002/terrorismo-em-cabo-delgado/t-55180646 18 UNHCR, (2023), Operational Update – September 2023 Mozambique 19 See at: https://fenagri.co.mz/wp-content/uploads/2022/08/ACELERANDO-AS-ACCOES-DE-RECUPERACAO-ECONOMICA-DO-SECTORPRIVADO-2021.pdf 20 See at: https://cta.org.mz/wp-content/uploads/pdf/IMPACTO-DOS-ATAQUES-TERRORISTAS-EM-CABO-DELGADO-NO-SECTOR-EMPRESARIAL.pdf 21 See at: https://www.undp.org/pt/brazil/desenvolvimento-humano/publications/indice-de-pobreza-multidimensional-global-de-2023-mpi 22 South African National Terrorism Financing Risk Assessment, March 2022. Intelligence reports.

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ASWJ began by distorting the principles of the Islamic religion, thereby recruiting, indoctrinating, and subsequently radicalizing young people. Later, the group began attacking the population using blunt instruments; the situation worsened when the group began attacking populations and the positions of the FDS.
The origin of financing is both external and internal. The greatest threat to TF for Mozambique comes from funding originating from individuals and organizations in the United Republic of Tanzania, the Democratic Republic of Congo, the Republic of Uganda, the Republic of Kenya, the Federal Republic of Somalia, and the Republic of South Africa23.
Attentive to open-source information24 and to the Terrorist Financing Risk Assessment reports of the United Republic of Tanzania and South Africa, these mention the possibility of the existence of terrorist cells in Tanzania and South Africa that provide support to the terrorist group in Mozambique, under the pretext that the funds are destined for humanitarian support and education25.
There is information that some national economic agents with links to organizations in some countries of the Great Lakes and Horn of Africa regions resort to the informal Hawala system to receive funds with the aim of passing them to the terrorist group.

2.3.3 Threat of TF derived from persons sympathetic to the terrorist ideology within the jurisdiction;

The vulnerability to hosting foreigners in the coastal regions of the northern zone of the country is accentuated, especially for people who profess the Islamic religion, whose values of brotherhood are high and enjoy greater primacy. These factors contribute to the insertion of terrorists who are subsequently supported by the populations.
However, some collected information suggests approaches regarding sympathizers, although superficially regarding the presence of foreigners and even the collaboration of the local population with ASWJ in Cabo Delgado. Matters related to the radicalization of local youth, invoking social and economic exclusion in the coastal region of the northern zone of Mozambique, based on the discoveries of natural gas reserves, mining exploration, and the massive registration of foreign labor to the detriment of the local population.

2.3.4 Threat of TF derived from terrorist activities in neighboring jurisdictions

The current level of TF threat derived from neighboring jurisdictions is high, especially regarding the United Republic of Tanzania due to historical migration backgrounds, social relations, and the presence of Tanzanian leaders in ASWJ in Mozambique.
Generally, the estimated mortality rate in neighboring countries in the region has been low over the last 5 years. On the other hand, in 2017, Tanzania recorded attacks in the Rovuma Province, which borders the Cabo Delgado province in Mozambique. With the expansion of terrorism into Mozambique, the number of terrorist attacks in the United Republic of Tanzania has been decreasing. The exception is the DRC region, which has a high level of mortality, both from attacks26.
In this sense, the level of financing associated with active terrorist threat in neighboring countries is high, given the existence of cells, individuals, or groups of people based in those countries, who financially support the terrorist group operating in our country.

2.3.5 Threat of TF derived from Financial or Commercial Centers

Mozambique is not characterized as an International or regional Financial Center according to the Global Financial Centres Index (GFC Index27).
However, Mozambique constitutes an important maritime transshipment center for the Southern, Eastern, Middle East, and Asian Africa regions. From this perspective, national maritime ports represent a significant contribution regarding international trade, serving as departure and arrival points for various goods, which may constitute a vulnerability. This fact means that ports can be used for the transport of weapons, goods, and products destined for terrorist actions.

2.3.6 Threat of TF derived from the Supply of Strategic Goods and Services

There is a record of the operation of various construction companies in the Palma district and throughout the territory of Cabo Delgado, which work to rebuild public and private infrastructure destroyed by terrorists.
The northern zone of the country in general, particularly the province of Cabo Delgado, is rich in mineral resources and has a little over 250 licensed mining exploration companies, of which only 100 are operational28. These companies, in the pursuit of their activities, use radioactive products and explosives, in addition to communication radios, vehicles, excavation machines, and generators.
Other strategic goods to consider come from local trade, gas stations, commercial establishments selling cell phones, batteries, various electrical materials, construction materials, cleaning products, and other products that can be used by the terrorist group. Notwithstanding formal commerce, there are informal trade hubs for the aforementioned products, originating from smuggling at the national level and from the neighboring United Republic of Tanzania.
On the other hand, there are increasingly more Non-Governmental Organizations installed in Cabo Delgado, namely, Religious Confessions, United Nations agencies, NGOs from the European Union, Africa, and Mozambique, which work in supporting displaced populations and their return to their areas of origin. Some NGOs have provided construction kits, 23 South Africa National Terrorism Financing Risk Assessment, March 2022; 24 See at: https://www.dw.com/pt-002/cabo-delgado-eua-de-olho-no-financiamento-a-terroristas/a-61020519 25 A Report on Assessment of Terrorist Financing Risk In Non-Profit Organisations

26 See at: https://www.visionofhumanity.org/wp-content/uploads/2023/03/GTI-2023-web-170423.pdf

27 See at: https://www.longfinance.net/media/documents/GFCI_32_Report_2022.09.22_v1.0_.pdf 28 Data collected from the Ministry of Mineral Resources.

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financial support to the displaced, and agricultural inputs. In addition to these facts, GIFiM reported that some NGOs have raised substantial sums of money in Cabo Delgado.

2.4 Sectoral Risks of TF

In this assessment, the following sectors were taken:

Commercial Banking Sector;
Electronic Money Sector;
Informal Sector – Alternative Fund Transfer Channels;
Fauna, Flora, and Fishery Products Sector; and
Mineral Resources Sector.

The selection of these sectors was made taking into account the fund movement channels as well as the financing sources used by ASWJ and terrorist groups globally that indicate possible sectors that would be at risk of TF in Mozambique. On the other hand, elements extracted from the National Risk Assessment of Money Laundering29 were taken into account. Likewise, the perception of experts from the involved sectors regarding the possible use of their respective areas for terrorist financing was also considered.

2.4.1. Commercial Banks

2.4.1.1. Characterization of the Banking Sector

a) Supervisory Entity

The Bank of Mozambique is the supervisor of credit institutions and financial companies.

b) Evolution of the financial system

29 See at: http://www.gifim.gov.mz/documents/138.pdf 30 Bank of Mozambique - Annual Report (2022) available at: www.bancomoc.mz

The Mozambican banking system consists of 15 banks, and the degree of evolution of Mozambican banks remained unchanged since December 2021.
Regarding agencies, by December 2022, the number of bank agencies was 657, representing a reduction of 1.2% compared to December 2021, or corresponding to a reduction of 8 agencies. In terms of territorial distribution, the city of Maputo concentrates 34% of bank agencies, followed by the provinces of Nampula with 12% and Maputo with 11%. The provinces with the lowest levels of concentration of bank agencies are Niassa and Manica with 4% each.30

Assets

Data referring to September 2023 when compared to December 2022, show an increase in the total assets of banks by about 4.77% to MZN 840.684 million, resulting from the increase in the value of Cash and Balances with Central Banks by about MZN 164.257 million (206.17%) and Financial Assets Available for Sale by about MZN 10.469 million (18.87%).
Regarding the same period, the asset structure of the banks was distributed as follows: Loans to Customers (29.90%), Cash and Balances with Central Banks (29.02%), Investments in Credit Institutions (11.70%), Investments Held to Maturity (10.16%), and Financial Assets Available for Sale (7.85%), with other asset aggregates having a combined weight of 11.38%.

Data referring to September 2023 when compared to December 2022, show an increase in the total assets of banks by about 4.77% to MZN 840.684 million, resulting from the increase in the value of Cash and Balances with Central Banks by about MZN 164.257 million (206.17%) and Financial Assets Available for Sale by about MZN 10.469 million (18.87%).
Regarding the same period, the asset structure of the banks was distributed as follows: Loans to Customers (29.90%), Cash and Balances with Central Banks (29.02%), Investments in Credit Institutions (11.70%), Investments Held to Maturity (10.16%), and Financial Assets Available for Sale (7.85%), with other asset aggregates having a combined weight of 11.38%.

Table 1 – Main asset aggregates of banks
Source: BM

It should be noted that customer resources essentially comprise customer deposits, which were more concentrated in call deposits with a weight of 59.34%, and when disaggregated by currency, the weight of deposits in National Currency in total funding (Customer Resources) was 75.62%.

Liquidity

In September 2023, the transformation ratio of banks stood at 45.57%, an increase of 77 b.p. (basis points) compared to December 2022. On the same date, the Ratio of Liquid Assets to Short-Term Liabilities was fixed at 45.21% as a result of the reduction in Liquid Assets.

Table 3: Liquidity Indicators
Source: BM

Data referring to September 2023 when compared to December 2022, show an increase in the total assets of banks by about 4.77% to MZN 840.684 million, resulting from the increase in the value of Cash and Balances with Central Banks by about MZN 164.257 million (206.17%) and Financial Assets Available for Sale by about MZN 10.469 million (18.87%).
Regarding the same period, the asset structure of the banks was distributed as follows: Loans to Customers (29.90%), Cash and Balances with Central Banks (29.02%), Investments in Credit Institutions (11.70%), Investments Held to Maturity (10.16%), and Financial Assets Available for Sale (7.85%), with other asset aggregates having a combined weight of 11.38%.

Table 1 – Main asset aggregates of banks
Source: BM

It should be noted that customer resources essentially comprise customer deposits, which were more concentrated in call deposits with a weight of 59.34%, and when disaggregated by currency, the weight of deposits in National Currency in total funding (Customer Resources) was 75.62%.

Liquidity

In September 2023, the transformation ratio of banks stood at 45.57%, an increase of 77 b.p. (basis points) compared to December 2022. On the same date, the Ratio of Liquid Assets to Short-Term Liabilities was fixed at 45.21% as a result of the reduction in Liquid Assets.

Table 3: Liquidity Indicators
Source: BM

It should be noted that customer resources essentially comprise customer deposits, which were more concentrated in call deposits with a weight of 59.34%, and when disaggregated by currency, the weight of deposits in National Currency in total funding (Customer Resources) was 75.62%.

Liquidity

In September 2023, the transformation ratio of banks stood at 45.57%, an increase of 77 b.p. (basis points) compared to December 2022. On the same date, the Ratio of Liquid Assets to Short-Term Liabilities was fixed at 45.21% as a result of the reduction in Liquid Assets.

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Regarding the evolution of the transformation ratio, its increase was due to the increase in loans to customers at a rate higher than that of deposits, translating, on the one hand, into a reduction in liquidity indicators, namely Liquid Assets/Total Deposits, Liquid Assets/Total Assets, and Liquidity Ratio. This reduction in liquidity indicators was also due to the increase in mandatory reserve coefficients for liabilities in Meticais and Foreign Currency throughout the current year.

Threat Factors

The threat level of the Commercial Banking sector for Terrorist Financing in the country is Medium Low.
There is a record of use of the national financial system for fund transfers, in a fragmented manner, to accounts of low-income individuals, located in terrorist threat zones and who may be linked to sympathizers or even terrorists. There is also a record of fund transfers from abroad to regions with active terrorist threat, followed by cash withdrawals, either in a fragmented manner or in full31.
Additionally, available information suggests that individuals suspected of involvement in terrorism have used the banking system to make transfers of insignificant values.
In the Cabo Delgado region, International Organizations, NGOs, and charitable institutions were found in various activities that use the commercial banking sector in their activities supporting terrorism victims and religious confessions.
In these activities, the movement of high values has been observed without the proper tracking of the ultimate beneficiaries of these funds, a fact that increases the risk of sector abuse, in the sense that the ultimate beneficiaries could be terrorists32.
The fact that the region is rich in mineral and energy resources enables terrorists to raise financial resources through the sale of such resources to licensed mining companies operating in active terrorist threat zones and other interested parties. The resources obtained can be integrated into the financial system within the scope of the activity for which the company is licensed.
Due to economic informality, such resources can also be integrated and justified through unregistered commercial activities or the proceeds used to finance terrorists.
On the other hand, the financial intermediation activity, exercised by commercial banks, always opens space for individuals of bad faith to use the sector for their criminal activities, notwithstanding the controls in place.

2.4.1.b Vulnerabilities

The level of Vulnerability of the Commercial Banking sector for Terrorist Financing in the country is Medium Low.

There are 15 (fifteen) banks in Mozambique, with the largest volume of operations, share capital, and assets concentrated in the 5 (five) largest banks in the market, namely, MBIM, BCI, SBM, ABSA, and Moza Banco.

In terms of foreign operations, banks carry out transactions abroad, mostly for payment of imports, services, and family aid. However, most transactions are domestic. In this regard, it should be mentioned that there is a record of transactions to some high-risk countries/jurisdictions, albeit at a low level, as banks are aware of the risks of transacting with high-risk jurisdictions.
International transactions are more in the direction of sending/remittances. This is also supported by the volume of imports vs. exports and by the deficit balance of payments. Regarding transfers to high-risk jurisdictions, we also verify a low level.
Regarding customers, banking institutions have Customer Due Diligence controls, with which they are segmented according to their risk and transactional profile, in order to ensure proper monitoring and vigilance. These obligations are stipulated by law, hence banks have databases and greater awareness of ML and TF issues.
Being a cash-based economy, characterized by high informality, the level of cash activity is high, increasing vulnerability.
Although banks use banking agents to expand their activity, the business is mainly conducted through agencies and centralized banking channels. Thus, notwithstanding the above factors, the banking sector is not very attractive for moving resources for TF, due to the high controls imposed by laws and regulations and the existence of institutions with supervisory and inspection duties.

2.4.1.c Control

The quality of controls of the Commercial Banking sector for Terrorist Financing in the country is Medium Low.

Scope of the legal/regulatory framework for combating TF

A large part of the sector's legislation is up-to-date and results from the efforts undertaken by the country, from 2022 to this part, with the aim of improving the deficiencies identified in the Second Mutual Evaluation Report of Mozambique, highlighting in particular the introduction of standards on the registration of Virtual Asset Service Providers, approval of the Asset Recovery Law and Law No. 20/2020, of December 31 (Law of FIsC).

Effectiveness of supervision procedures and practices

The BM has powers and tools to carry out effective supervision of commercial banks, derived from the legislation on the matter, as well as recent updates. Currently, risk-based supervision is employed, and inspections to banking institutions are underway according to the 2023 plan, a fact that has addressed the deficiencies previously identified in the Mutual Evaluation Report (MER).
The inspection actions that the BM has developed are duly documented in annual reports, but we highlight the joint inspection between the Prudential Authority (PA) of the South Africa Reserve Bank (SARB) and the Bank of Mozambique at Nedbank, SA and Standard Bank, SA.
Additionally, the supervision unit was reinforced with more staff, totaling currently 6 professionals in the ML/TF area, who are being trained to implement risk-based supervision.
As challenges, we point out the following:

Need to consolidate the new risk-based supervision model;
Continuity of holding workshops with supervised institutions and the Mozambican Bank Association, to improve the understanding of risks in the banking sector and persuade top management of these institutions on ML/TF matters;
Need to increase human resources in the supervision area regarding ML/TF matters.

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Availability and Application of Administrative Sanctions

In aggregate terms between 2020 and 2023, on-site inspections carried out regarding Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) at Banks resulted in the application of sanctions with fines totaling 124,851,350.00 MT (one hundred and twenty-four million, eight hundred and fifty-one thousand and three hundred and fifty meticais), which were published in the media and on the BM website.
In general, the assessment reveals that the administrative sanctions applied are sufficiently proportional and dissuasive, a result also of the revision of the ICSF Law, which further increased the fines provided for.

Availability and Effectiveness of Entry Controls

Regarding entry controls, the legal framework approved by the ICSF Law and its regulation imposes licensing, registration, and assessment of the suitability of shareholders and members of the governing bodies of credit institutions and financial companies. These controls allow for the avoidance of the use and abuse of these entities for purposes of TF and other criminal activities.
The BM licenses and registers institutions, and coordinates with similar entities in other countries, regulators and supervisors of various National and International sectors, and other international organizations.
As challenges, the following have been identified:

Need to broaden the range of cooperating entities in order to improve the capacity to search for relevant information within the scope of licensing, registration, among others.

Integrity of Personnel

The legislation in force, notably the ICSF Law and legislation on the prevention and combating of AML/CFT, provides guarantees of independence, impartiality, and confidentiality for bank employees.
As improvements, we highlight:

Massification and continuous improvement of training programs for their employees, including top managers, on matters of confidentiality and other matters related to AML/CFT.

Effectiveness of the Compliance Function

Regarding the compliance function, credit institutions have an average organization with a growing trend, when analyzed comparatively to the inherent risks, being equipped with resources and exercising the compliance function independently. In general, there is a department/office director, where the compliance area is integrated. In compliance with legislation on AML/CFT/FP, institutions are obliged to appoint Suspicious Transaction Reporting Officers to the headquarters and branches/agencies.
One of the challenges noted in this area relates to the fact that banks must adjust their internal regulations and programs to the new regulatory framework on AML/CFT matters.

Effectiveness of the Implementation of Specific Financial Sanctions

Regarding this variable, we note that banks generally implement customer due diligence in order to detect persons listed under Resolutions n.º 1267 and 1373 of the United Nations Security Council.
Very recently, Mozambique published the first list of designated entities at the national level, published through the BR n.º 133, 1st Series, of July 12. Following this publication, banks adopted tracking measures aimed at identifying any clients who appear on the aforementioned list of designated national entities.
Meanwhile, at this point, improvements must be implemented, namely, the improvement of internal procedures aimed at the immediate freezing of assets of individuals who have been designated by the United Nations Security Council.

Effectiveness of Monitoring and Reporting of Suspicious Activity

With regard to the monitoring and reporting of transactions, credit institutions have appropriate systems for maintaining records, monitoring, and sending communications of suspicious transactions. Computer systems allow tracking and categorizing clients according to their risk level and thus monitoring their respective transactions.
However, the perception is that the number of suspicious transactions for TF is quite reduced compared to the number of ML transactions, which suggests that banks need to improve and refine their understanding of TF risks, in order to detect and report these transactions. This information is corroborated by the number of STRs received by GIFiM.
In this part, the major challenges we identify lie in the need for banks to further empower their staff and improve internal controls in order to improve the institutional capacity to understand and identify cases of TF.

Availability and Access to Information on Beneficial Owners

There is no effective centralized database for the purpose of querying information on beneficial owners. However, information on business entities can be accessed through the Registry of Legal Entities Conservatory (CREL) and the Official Gazette.
Meanwhile, at the level of the Ministry of Justice, Constitutional Affairs and Religious Affairs, the implementation of a project aimed at operationalizing the national database on Beneficial Owners is underway.
Despite the non-existence of the database, the law on credit institutions and financial companies requires commercial banks to provide information on beneficial owners during the licensing process. Thus, it is understood that for institutions subject to licensing and registration by the BM, this weakness is duly mitigated.
Thus, as challenges, it is pointed out:
a. Need to create and operationalize a centralized national registry that allows for the identification of partners and beneficial owners of legal entities.

Availability of a Reliable Identification Infrastructure

Regarding identification infrastructure, there is the National Directorate of Civil Identification, which holds adequate and reliable identifying information. However, banks face difficulties in verifying the authenticity of client documents, due to the non-existence of an information system to assist in the verification and detection of fraudulent documents.
Thus, the weakness we detected relates to the fact that both banks and other institutions do not have a swift mechanism that allows for the verification of the authenticity of the identification documents presented to them. At this moment, this verification can only be done with the issuing entity through the physical presentation of these documents.

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There is a need to establish a swift mechanism for verifying the authenticity of documents, namely a system for querying information on the identification of persons.

2.4.1.e Results of the Analyzed Sector and Risk Maps

The analysis carried out suggests that the banking sector is characterized by a medium level of risk with a constant trend in terms of TF. In this regard, the following necessary improvements are highlighted:

Need to improve the training of professionals in specific TF matters, as well as for banking institutions to carry out organizational-structural reforms in order to improve their capacity for prevention and combating of TF;
Need to consolidate the new risk-based supervision model;
Need to increase human resources in the area of supervision on AML/CFT matters;
Continuation of the holding of workshops with supervised institutions and the Mozambican Bank Association, to improve the understanding of risks in the banking sector and persuade top management of these institutions on AML/CFT matters;
Adjust their internal regulations and programs to the new regulatory framework on AML/CFT matters;
Need to create and operationalize a centralized national registry that allows for the identification of partners and beneficial owners of legal entities;
Need to establish a swift mechanism for verifying the authenticity of documents, namely a public system for querying information on the identification of persons;
Need for a central independent body responsible for maintaining a database with relevant information on individuals and legal entities, regarding entities convicted of financial crimes and other relevant offenses.

2.4.2. Electronic Money Institutions
a) Evolution of EMIs

Currently, there are 3 (three) EMIs operating in Mozambique, with the one having the highest volume of operations, highest share capital, and high asset volume being Vodafone-MPesa, SA33.
The value of assets of electronic money institutions as of September 2023 was 16,940 million Meticais. The accumulated share capital was 2,004 million Meticais.
The mobile money or electronic money market has been growing, as the number of cell phone users has increased and the penetration level in rural areas is quite high compared to traditional (conventional) banking.
All EMIs have their headquarters in the City of Maputo; however, only two operate at the national level, as they have adopted agents as a resource for expanding their activity.

a) Evolution of EMIs

Currently, there are 3 (three) EMIs operating in Mozambique, with the one having the highest volume of operations, highest share capital, and high asset volume being Vodafone-M-Pesa, SA33.
The value of assets of electronic money institutions as of September 2023 was 16,940 million Meticais. The accumulated share capital was 2,004 million Meticais.
The mobile money or electronic money market has been growing, as the number of cell phone users has increased and the penetration level in rural areas is quite high compared to traditional (conventional) banking.
All EMIs have their headquarters in the City of Maputo; however, only two operate at the national level, as they have adopted agents as a resource for expanding their activity.
Table 1 – Main Asset Aggregates
Source: BM

2.4.2.a Threats

The threat level of the electronic money sector for Terrorism Financing in the country is High.

There is excessive movement of funds to areas of active terrorist threat using the electronic money institutions operating in the Country.
Analyzing the phenomenon of terrorism, it is observed that it is concentrated in rural areas and areas with limited access to the national banking network. For this reason, there is a preference for the use of electronic money institutions, given the ease of use of the service and the rapid movement of funds it provides. These factors combined precipitate and make this sector appealing for abuse by terrorist sympathizers.
Given the existence of population clusters that reside and develop social, commercial, and other activities in regions with active terrorist threat, it enables terrorists and terrorist sympathizers to abuse the services of electronic money institutions for the movement of funds.

33 See the Bank of Mozambique Annual Report of 2022

Asset Aggregates Table
Dec-20 | Dec-21 | Dec-22 | Sep-23
Cash and Balances with Central Banks (in Millions of Meticais) | 476 | 540 | 899 | 830 Balances with credit institutions | 7,032 | 10,383 | 13,431 | 15,246 Investments in Credit Institutions (in Millions of Meticais) | 0 | 40 | 90 | 150 Assets | 487 | 338 | 245 | 305 Other assets | 216 | 325 | 437 | 408 Total Assets (in Millions of Meticais) | 8,214 | 11,629 | 15,309 | 16,940 Values in millions of Meticais

33 See the Bank of Mozambique Annual Report of 2022

2.4.2.a Threats

The threat level of the electronic money sector for Terrorism Financing in the country is High.

There is excessive movement of funds to areas of active terrorist threat using the electronic money institutions operating in the Country.
Analyzing the phenomenon of terrorism, it is observed that it is concentrated in rural areas and areas with limited access to the national banking network. For this reason, there is a preference for the use of electronic money institutions, given the ease of use of the service and the rapid movement of funds it provides. These factors combined precipitate and make this sector appealing for abuse by terrorist sympathizers.
Given the existence of population clusters that reside and develop social, commercial, and other activities in regions with active terrorist threat, it enables terrorists and terrorist sympathizers to abuse the services of electronic money institutions for the movement of funds.
The practice of informal economic activities is essentially based on cash and contributes to raising the TF threat, as sympathizers can exercise legitimate activities, the proceeds of which are channeled to TF, without authorities detecting it.

2.4.2.b Vulnerabilities

The vulnerability level of the electronic money sector for Terrorism Financing in the country is Medium-High.

Similar to banks, electronic money institutions are also characterized by their robustness and high profitability. Broadly speaking, these do not carry out foreign exchange operations (on foreign currency), so there are no records of transactions to and from other jurisdictions.
Regarding the profile of clients, most of the population in areas with active terrorist threats is poorly educated (low education level) and engages in informal economic activities. This may constitute a factor that increases the preference for the use of electronic money in these regions, due to the ease of adherence, use, reduced bureaucratic processes for opening accounts and moving funds, compared to banking institutions.

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Given the economic informality, the level of monetary activity (cash) in this sector is high, with a growing trend, due to the simplified manner of use, considering that the business base in the country is in cash.
Considering that the electronic money business is mostly carried out based on agents and super-agents34, mainly in regions with active terrorist threat, it is noted that these are not adequately trained on AML/CFT matters. Thus, there is a high probability of person-to-person fund transfers without transaction monitoring and due diligence, allowing fund movements to higher-risk locations, including to terrorists.

2.4.2.c Control

The quality of controls of the Electronic Money sector for Terrorism Financing in the country is low-medium.
(0.30)

Scope of the Legal Framework of the TF Law

The perception of the evaluators is that the applicable legal framework is understood by providers of electronic money services; however, the dissemination, training, and awareness of agents remains a challenge.
In terms of challenges, one can point out:

Need to improve the training of professionals in specific TF matters, as well as for EMIs to carry out organizational-structural reforms in order to improve their capacity for prevention and combating of TF;
Need to review Notice n.º 6/GBM/2015 in order to update it to the current context;
Need to consolidate the legislation applicable to EMIs.

Effectiveness of Supervision Procedures and Practices

As a result of the legislation on the matter as well as recent updates, supervision actions are underway, where risk-based supervision is employed.
Similar to what was stated regarding banks, currently, risk-based supervision is employed and inspections of EMIs are underway according to the 2023 plan, thus addressing the deficiencies previously identified in the Mutual Assessment Report (MAR).
The BM Annual Reports contain information on the inspection actions that the BM has developed, but inspections based on risk-based supervision are still underway.
As challenges, we point out the following:

Need to consolidate the new risk-based supervision model;
Continuation of the holding of workshops with EMIs, to improve the understanding of risks in the banking sector and persuade top management of these institutions on AML/CFT matters;
Need to increase human resources in the area of supervision on AML/CFT matters.
Consolidation of Notice n.º 5/GBM/2022 of November 17 - AML/CFT/FP Guidelines

Availability and Application of Administrative Sanctions

The legislation provides for sanctions on this matter, and electronic money institutions are subject to sanctions when applicable. However, low effectiveness of sanctions is noted as they do not directly affect the agents, but rather the providers of electronic money services.
The sanctions provided for in the legislation are proportional and dissuasive, in order to influence the behavior of EMIs.

Availability and Effectiveness of Entry Controls

As stated for banks, the legal framework approved by the Law on Credit Institutions and Financial Companies (LICSF) and its regulation imposes licensing, registration, and assessment of the suitability of shareholders and members of the governing bodies of EMIs.
At the BM level, the Regulation and Licensing Department is the specific unit responsible for the licensing and registration of EMIs, which has trained technicians for the good evaluation of licensing and registration requests.
As a challenge, the need to broaden the range of cooperating entities in order to improve the capacity to search for relevant information within the scope of licensing, registration, among others, was identified.

Integrity of Personnel

For the case of EMIs, considering that they develop their business mostly through agents, it is noted that these institutions do not carry out a rigorous verification of the suitability of the same, nor do they have continuous training programs on AML/CFT matters.
On the other hand, these entities do not have adequate procedures for updating and registering their agents.
In general, since the AML/CFT Legislation, notably Notice n.º 5/GBM/2022, is relatively recent, we can say that EMIs still need to adjust their internal procedures to this regulation in order to comply with it.
As improvements, the following is highlighted:

Massification and continuous improvement of annual training programs for their employees, including top managers and agents, on AML/CFT matters;
Need for EMIs to consolidate the effective application of the legislation related to AML/CFT matters;
Need for EMIs to improve their procedures for verifying the suitability of their agents, as well as the respective registration.

Effectiveness of the Compliance Function

Electronic money institutions have a compliance function; however, due to the high number of agents under their jurisdiction, it is noted that not all are adequately empowered to ensure compliance with the norms and procedures applicable in AML/CFT matters. On the other hand, from the work done, it is noted that institutions do not have internal compliance programs sufficiently adjusted to the risk of the sector and the legislation in force.

34 According to the BM Annual Report of 2022, Electronic Money Institutions as of December 2022 had 147,519 agents against 94,697 in 2021. pp:166

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Also, there is no evidence that IMEs are implementing at all the measures provided for in Notice No. 5/GBM/2022.

Effectiveness of the implementation of FT sanctions

IMEs are not adequately prepared for effective customer due diligence, in order to detect persons who appear on the list of sanctioned entities under United Nations Security Council Resolutions 1267 and 1373.
After the publication of the first list of persons and entities designated at the national level, IMEs adopted screening measures aimed at identifying potential clients who appear on the aforementioned list of designated national entities.
However, at this point, improvements must be implemented, namely the refinement of internal procedures aimed at immediate freezing.

Effectiveness of Reporting, Monitoring, and Reporting of Suspicious Activity

Generally, IMEs have information systems that allow for the recording, monitoring, and reporting of transactions.
However, the prevailing perception is that the number of FT suspicious transactions reported is not consistent with the level of risk to which the activity is exposed. This fact is also supported by the number of STRs (Suspicious Transaction Reports) transmitted to GIFiM by IMEs.
Thus, the following challenges are identified:

The need for IMEs to design and implement massive awareness programs for employees, agents, and top management;
Improvement of transaction monitoring systems;
Organizational-structural reforms aimed at improving the institutional capacity to understand and identify FT risks.

Availability and Access to Information on Beneficial Owners

As mentioned for banks, there is no effective centralized database for querying beneficial owners, although information on business and legal entities can be obtained through the Registries of Legal Entities or at the BR.
For these reasons, the following challenges are identified:
a. Need for the creation and operationalization of a centralized national registry that allows for the identification of partners and beneficial owners of legal entities; b. Need for the registration of representation mandates in business entities and other legal persons.

Availability of a Reliable Identification Infrastructure

Regarding reliable identification infrastructure, IMEs also depend on the National Directorate of Civil Identification. Similar to banks, IMEs face difficulties in verifying the authenticity of client documents, due to the lack of an information system to assist in the verification and detection of fraudulent documents.
As an improvement, we point out the need to establish a swift mechanism for verifying document authenticity, namely a system for querying information on person identification.

Availability of Independent Information Sources

There are independent, reliable, available, and comprehensive information sources, as well as other client information; however, in certain cases, access to them depends on certain legal procedures.
However, as we mentioned for banks, IMEs are also affected by the lack of a central independent body responsible for maintaining a database with relevant information on individuals and collectives, regarding entities convicted of financial crimes and other relevant offenses.

2.4.2.e Results of the Analyzed Sector and Risk Maps

The analysis conducted suggests that the IME sector is characterized by a high level of risk with a constant trend in terms of FT. In this part, we highlight the following necessary improvements:

Need to improve the training of professionals in specific FT matters, as well as for IMEs to carry out organizational-structural reforms aimed at improving their capacity for prevention and combat of FT;
Need to revise Notice No. 6/GBM/2015 to update it to the current context;
Need to consolidate the legislation applicable to IMEs.
Need to consolidate the new risk-based supervision model;
Continuation of workshops with IMEs, to improve the understanding of risks in the banking sector and persuade top management of these institutions regarding CFT/AML matters;
Need to increase human resources in the area of supervision in CFT/AML matters;
Consolidation of Notice No. 5/GBM/2022 of November 17 - CFT/AML/FP Guidelines;
Need to improve the effectiveness of administrative measures through the simultaneous application of criminal measures;
Need to increase sanctions applied to members of management bodies, as provided for in international recommendations.
Improvement of transaction monitoring systems;
Need for the creation and operationalization of a centralized national registry that allows for the identification of partners and beneficial owners of legal entities;
Need to establish a swift mechanism for verifying document authenticity, namely a system for querying information on person identification.

2.4.3 Informal Channels for Fund Transfers

2.4.3.a Threat Factors
The threat level of this sector for Terrorism Financing in the country is Medium.

In this sector, the Hawala transfer system constituted the only typology subject to analysis to determine the FT risk in the sector. The sensitivity of experts is that the Hawala system is used in the country; however, being an unlicensed/unregulated sector, there is scarce information that allows for a detailed description of how this typology develops.
Notwithstanding the scarcity of information at the internal level, there are international studies that indicate how the Hawala system works and how it has been exploited by terrorists. For example, the 2023 Bridgeway Foundation report indicates that the Hawala network in East Africa has been maintained through the "Karrar Center," managed by the Islamic State of Somalia, in Somaliland, which supervises agents operating in Southern Africa, Tanzania, Kenya, Uganda, and Somalia, whose majority of funds come from robberies, kidnappings, illegal trade in precious stones, and extortions, and finance terrorist activities on the continent, including in Mozambique.
Several factors that facilitate the occurrence of informal financial transactions can be listed, among them:

The predominance of informal activities, characterized by transactions outside the financial circuit, with emphasis on banking, especially in the northern region of the country, where terrorist acts occur;
Deficient accessibility of the formal banking system in areas with active terrorist threat;
The multicultural nature of the country, especially in the region with active terrorist threat, where the majority of the population professes the Islamic religion, which increases trust among people practicing the same religion;

The predominant terrorism in the country is basically rural and community-based, where terrorists are embedded in communities and/or have ties of familiarity or friendship with members of the communities where they operate. In these terms, considering the modus operandi of hawaladars (agents embedded in communities), it is noted that this type of informal transfer can contribute significantly to moving funds aimed at financing ASWJ activities in areas with active terrorist threat 38.

2.4.3.b Vulnerability Factors
The vulnerability level of the informal financial sector for Terrorism Financing in the country is Medium.

Although there is no detailed study, international reports and studies indicate that the Hawala system has been used by terrorists for fund movement and the fact that this activity occurs outside the formal financial system makes it difficult to estimate the business volume of this sector.
There are indications that the Hawala system has been used in the country to receive funds through various commercial activities, such as payments for smuggled or illegally exploited materials.
The client base of this activity is not necessarily linked to terrorist activity, as it is also used for fund transfers resulting from lawful and unlawful activities.

2.4.3.c Control

Being an informal activity not subject to regulation or registration of transactions, it operates outside the applicable regulatory procedures.
This service is not covered by the inspection and control activities of the authorities. For this reason, administrative sanctions applicable to the sector are not available.
According to financial legislation, the exercise of informal financial activity is punishable, although there are no statistics demonstrating the execution of criminal sanctions for this type of activity.

Since Hawala is a mechanism used for lawful and unlawful purposes, persons or entities operating in this sector can also be integral. However, given its characteristics of informality and secrecy, the risk of formalizing funds from unlawful activities is elevated.

2.4.3.e Results of the Analyzed Sector

From the combination of threat factors and vulnerability factors of the sector, it is verified that the sectoral risk of informal fund transfer channels is medium, since during the assessment it was not possible to identify a high number (based on statistical data) of the existence of this typology in the country, however, the possibility of abuse of this sector for Terrorism Financing cannot be overlooked.

2.4.4. Wildlife, Flora, and Fisheries Products Sector

2.4.4.a Threat Factors
The threat level of the Wildlife, Flora, and Fisheries Products sector for Terrorism Financing in the country is High.

Environmental crimes in Africa have become so sophisticated that they can be compared to drug and arms trafficking crimes, which cross borders. Several terrorist organizations on the continent have abusively benefited from maritime resources, fauna, and flora, aiming to finance their activities. Al-Shabaab from Somalia, for example, obtains funds through the taxation of charcoal, and the Lord's Resistance Army from Uganda depends heavily on poaching and ivory sales to obtain capital.
In Mozambique, it has not been different, as there are several typologies of environmental crimes that can be associated with terrorism financing, among them, poaching, specifically the trafficking of hunting trophies and other faunistic species, timber smuggling, and illegal fishing, developed mainly in areas with active terrorist threat.
Although some activities are related to money laundering, their occurrence in areas with active terrorist threat elevates the risk of terrorism financing. Hence, the following factors are identified as conditioning the occurrence of these crime typologies:
a) The fact that regions with active terrorist threat are fully and/or partially inserted in conservation areas, combined with the low financial conditions of the local population, makes it easy to recruit them for the commission of these crimes; b) The geographical configuration of the terrain in the provinces of Cabo Delgado and Niassa is mostly composed of dense forests, which facilitates the cover and protection of criminals and at the same time hinders control actions by authorities; c) The fact that it involves people with very high financial power and the high demand for forest and faunistic resources in the international market facilitates the occurrence of corruption.
However, it has been observed that environmental crimes in the country occur more frequently in border regions, due to the porosity of national borders, which facilitates the smuggling of these resources to other jurisdictions.

2.4.4.b Vulnerability Factors
The vulnerability level of the Wildlife, Flora, and Fisheries Products sector for Terrorism Financing in the country is Medium-High.

Mozambique is a country that has a vast forest coverage, of about 31,693,872 hectares, of which 25% are environmental conservation areas, with a great diversity of fauna and flora. In this sense, the sector becomes vulnerable to criminal activities that can easily be associated with terrorism financing.
The illegally exploited resources have high commercial value, with the largest clients originating from Asia, driven by commercial appetites in search of raw materials. However, despite not having a record of their direct links to terrorism, the fact that timber and other forest product smuggling occurs in areas with active terrorist threat suggests that this activity has been a source of income for terrorists, as it is estimated that timber smuggling in Cabo Delgado yields about 125 million meticais per month to smugglers.
From the assessment made, it was possible to identify as the main vulnerabilities of this sector the weak inspection of conservation areas, as well as the weak inspection capacity of the coast, especially in areas with active terrorist threat, which increases the risk of terrorism financing through illegal fishing, aimed at ensuring the logistical base of terrorists.
It was also identified that in the activity of harvesting forest and faunistic resources, national and foreign citizens are involved (as intermediaries and agents, recruited by terrorists).

2.4.4.c Control
The quality of controls of the Wildlife, Flora, and Fisheries Products sector for Terrorism Financing in the country is Medium-Low.

The conservation areas sector has a robust, current legal framework that adequately responds to international normative standards on the fight against Terrorism Financing.
The effectiveness of the legal framework is guaranteed by effective supervision in conservation areas and all licensed entities, and whenever they need to export any wildlife or flora product, they must request authorization, being obliged to periodically (semi-annually or annually) submit to the National Administration of Conservation Areas (ANAC) a report on the exploitation of the referred areas.
However, outside conservation areas and in zones where there is an active terrorist threat, inspection is deficient and/or almost non-existent, but for this effect, it has relied on the collaboration of other actors (Defense and Security Forces - FDS).
A very high number of suspicious activities were reported in the last 3 years. Despite, in a universe of about 12,000 cases of suspicious activities reported and investigated in that period being related to money laundering, some of these processes are associated with FT, as they occurred in areas with active terrorist threat.
As a result of the supervisions, administrative sanctions have been applied to various entities; however, these are not complied with (paid), as the sanctioned prefer to drag the cases to court rather than comply with the sanctions.
Regarding the application of criminal sanctions, the level is considered low, as out of the approximately 8,505 accused cases in 2022, only 8.76% were tried and 0.35% convicted.
Regarding the degree of compliance with norms and entry procedures into the sector, these are well established and scrupulously complied with. However, it remains a concern for the sector that entities continue to exploit resources different from those for which they were licensed.
From the analysis conducted, it is considered that the high levels of illegal exploitation in this sector are always related to the low level of integrity of personnel and consequently linked to corruption. On the other hand, the process of sensitizing sector personnel on the matter of combating Terrorism Financing has been evolving gradually, with the sector promoting training aimed at equipping staff with knowledge on the matter.
Access and availability of information on beneficial owners depends on the approval of the regulation on the matter.

2.4.4.e Results of the Analyzed Sector and Risk Maps The sector under evaluation presents a high risk of being used for FT. This risk is derived from several factors, among them the inherent threats combined with the sector's vulnerabilities and the weak quality of controls. In these terms, given the need for implementation and a risk-based strategy, it is expected that to mitigate the risk identified in the fauna, flora, and fisheries resources sector, resources will be directed to activities based on the identified vulnerabilities.

2.4.5. Mineral Resources Sector

2.4.5.a Threat Factors
The threat level of the Mineral Resources sector for Terrorism Financing in the country is High.

The mining sector in Mozambique records a significant increase in the legal exploitation of resources, with new companies entering to invest throughout the Country, with greater emphasis on the Gas project in the Rovuma Basin, concessioned to ENH and Total Energies.
Mozambique's exposure at the mining sector level has attracted not only legal organizations but also smugglers and illegal explorers; however, the assessment of abuse cases in the mining sector in the jurisdiction is at a moderate level with a constant trend.
The trafficking of minerals by national and international criminal organizations, framed within the legal framework of the crime of Smuggling and Trafficking of Gemstones and Precious Metals, represents a loss of revenue for the State and a threat in the financing of unlawful activities.
At the global level, the mineral resources sector has suffered abuses, with cases related to FT. It is the modus operandi of the Taliban to use existing mineral resources in the area for FT. The terrorist group Al-Shabaab has used mineral resources as a source of FT.
Another important aspect is correlated to the fact that some members of ASWJ, which operates in Mozambique, have individuals of Kenyan, Somali, and DRC nationalities, countries with cells of Al-Shabaab and other terrorist groups, enabling the application of FT techniques using the exploitation and commercialization of minerals.
The abundance of mineral resources, in territories with weak state control coverage, allied to the porosity of borders, makes the illegal exploitation and commercialization of mineral resources an attractive source of wealth for extremist groups in Africa, notably Al-Shabaab, the Lord's Resistance Army (LRA), and the Janjaweed militia.
Particularly, the typology of terrorism in Mozambique is rural and circumscribes the northern zone of the country, with greater focus on Cabo Delgado province.
Notwithstanding the formal growth of the sector, there are records of illegal exploitation and commercialization of mineral resources by groups of nationals and foreigners.

2.4.5.b Vulnerability Factors
The vulnerability level of the mineral resources sector for Terrorism Financing in the country is Medium-High.

Mining companies operating in Mozambique are 90% foreign capital, with Mozambican companies currently contributing only with human capital and land. On the other hand, the Country has no refining products

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minerals in operation, which conditions that all production be exported in raw form. In this context, financial tracking of investments and illegal trade in precious metals and gems in the sector becomes deficient.

The use of agents, sellers, and other intermediaries is high. Taking as an example the commercialization of precious metals and gems, in which most license holders do not have sufficient capital, which leads to many trade agents and other intermediaries forming an extensive chain, constituting a risk for TF. The sector is quite attractive for TF, at the level of illegal exploitation of mineral resources, the case of artisanal miners, who exploit resources in areas licensed for sale to nationals and foreigners, without using the national financial system.

2.4.3.c Control

The quality of controls in the Mineral Resources sector for Terrorism Financing in the country is low-medium.

MIREME, the supervisory body of the sector, directs and ensures the execution of the government's policy in geological research, exploration of mineral and energy resources, in the development and expansion of energy supply infrastructure, Natural Gas and petroleum products. According to the Decree of creation (Resolution No. 14/2015, of July 8).
MIREME through INAMI regulates mining activity, implements guidelines for the participation of the public and private sector in the search, exploration, treatment, export and import of mining products and their derivatives. The Kimberley Process Management Unit (UGPK) is responsible for implementing the Kimberley Process in Mozambique, which aggregates the management of technical and administrative procedures for tracking, security and internal control of rough diamonds and the commercialization of precious metals and gems.
The General Inspection of Mineral and Energy Resources is the entity responsible for inspecting and monitoring the degree of compliance with Laws, Regulations and other guidelines approved by the Government in the context of the rational and sustainable exploitation of mineral, petroleum and energy resources.
The difficulty of controlling production and commercialization in artisanal mining, weak capacity for specific supervision and inspection for the purposes of TF prevention, namely in the sale of stones and precious metals, difficulty in identifying potential illegal buyers and suppliers, ease and frequency of cash transactions, characterized by a market chain involving many intermediaries, lack of control over transactions of large sums of money, existence of illegal transfer and rental of commercialization licenses.
Mining legislation provides for administrative sanctions, but the level of effectiveness is still low taking into account the supervision difficulties already mentioned. MIREME finds difficulties in administratively sanctioning smuggling and illegal sale of mineral resources.
Although mining legislation provides for the application of criminal sanctions, this action falls to institutions dedicated to this effect. Of the cases referred to the courts regarding possession and trafficking of minerals, some cases have been judged, however none refer to TF.
MIREME technicians have benefited from specific training and capacity building programs in AML and TF matters, with a view to creating institutional awareness about mineral smuggling. However, inspection is not only carried out on mining operators, but also on sector employees.
MIREME works in close collaboration with the Migration Services, and the Registry of Legal Entities Conservatory for the case of identification of people and companies respectively and has collaborated with PRM, specifically with the Police for the Protection of Natural Resources and the Environment, as well as AT, for the inspection process of entry and movement of strategic goods used by mining companies, including the circulation of ores.

2.4.5.e Results of the Analyzed Sector

According to the combination of the factors described above, it is concluded for the present sector that the level of TF risk is high.

2.4 National TF Vulnerability

2.4.1 National Combat Capacity

The National capacity to prevent and Combat Terrorism Financing is an indispensable condition for the Country's effectiveness in combating TF. In summary, the different variables analyzed indicate a high average score, which means that institutions must continue to make efforts to find ways to improve their performance in the prevention and combat of terrorism financing.
From the analysis carried out, the strengths of the National Capacity to Combat TF are:

a) Existence of a National Risk Assessment (NRA) of Money Laundering and Terrorism Financing;

b) Existence of a national body for organizing, formulating and implementing policies and strategies for the prevention and Combat of Terrorism Financing;

c) Existence of a definition of TF crime that meets the international parameters present in the conventions and international resolutions ratified by Mozambique and FATF Recommendations. The sanctions are proportional and sufficiently dissuasive;

d) Mozambique has a comprehensive legal customs and migratory framework that allows responding positively to threats and vulnerabilities of control systems for goods (including strategic), merchandise, assets, means of transport and people;

e) Mozambique has a financial intelligence unit (GIFiM) adequately structured in terms of human and financial resources. The law establishes safeguards that allow GIFiM to perform its functions with independence and technical and operational autonomy;

f) Competent intelligence services are authorized by legislation to collect, analyze and effectively and spontaneously disseminate, upon request, information and the results of their analysis to relevant investigation authorities and other competent bodies. Likewise, the law establishes safeguards that allow GIFiM to perform its functions with independence and technical and operational autonomy;

g) Investigators and prosecutors enjoy guarantees and safeguards of exemption and integrity so that they can investigate crimes impartially without influence and with due autonomy and independence in accordance with the Constitution of the Republic, Law No. 1/2022, of January 12 and Law No. 2/2017, of January 9;

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h) Investigation agencies have minimum human, material and institutional means to investigate Terrorism Financing crimes. These agencies regularly receive information from intelligence agencies to strengthen their investigative capacity;

i) The Country has financial, police and tax intelligence services with sufficient knowledge of the TF crime, as well as a body for instructing criminal cases with a framework of Public Ministry magistrates experienced in the matter and trained for this purpose;

j) Judicial Magistrates have benefited from various training and capacity building actions aimed at improving the national capacity for prosecution and asset confiscation in matters of terrorism financing;

k) Judicial Magistrates also enjoy guarantees and safeguards of exemption and integrity so that they can judge crimes impartially without influence and with due autonomy and independence in accordance with the Constitution of the Republic and Law No. 8/2018, of August 27 (Statute of Judicial Magistrates);

l) GIFiM, investigation authorities, regulators and supervisors, Tax Authority, Prosecutors and Judges have mechanisms for exchange, information sharing and promotion of coordination meetings on AML and TF. There are also internal coordination and cooperation bodies, namely the CEC.

m) The Country has a legal framework applicable to situations of judicial and judicial assistance which is Law No. 21/2019, of November 11 (Law on International Judicial and Judicial Cooperation in Criminal Matters). On the other hand, it is part of international cooperation bodies beyond regional and bilateral agreements signed;

n) The Country has comprehensive legal mechanisms to seize, freeze and confiscate assets derived from, used or intended for use in the financing of terrorism, terrorist acts or terrorist organizations, or property of corresponding value.

o) The Country has comprehensive legislation on Specific Financial Sanctions (SFS), and effectively implements relevant resolutions of the United Nations Security Council (UNSC) related to terrorism and the financing of terrorism;

p) Obligated institutions have mechanisms to confirm the authenticity of citizens' identification documents with issuing public institutions (DIC, SENAMI, INAR and INATRO);

q) Information on transactions carried out by clients is available at financial institutions, as they are obliged to keep records about their clients (legislation on money laundering, tax and commercial code);

r) Information on the structure, management, control and beneficial ownership of commercial companies and other legal entities is available through dedicated State institutions, namely the Registry of Legal Entities Conservatory, the Land Registry and other public and private services with competence for this purpose;

Regarding vulnerabilities related to the prevention and combat of TF crime, the following weaknesses were identified:

a) Lack of a code covering general customs matters in all its regimes;

b) Lack of legal instruments and procedures that guide authorities in the control and tracking of all strategic goods;

c) Use of data and document archiving system in physical format;

d) Need to equip investigation agencies in terms of personnel, with training in financial crime matters, material, financial, technical and other means;

e) Porosity of borders, outdated Law No. 6/2008, of July 9 on Prevention and Combat of human trafficking and need for massive and systematic training of employees to identify victims and apply guidance procedures;

f) GIFiM's non-adherence to the Egmont Group of FIUs, although it is in the final phase of the application process to become a member, with the same expected to happen by June 2024;

g) Existence of a small number of Magistrates with specific training for investigation and judgment of TF crime cases;

h) Need to improve the internal cooperation model with a view to eliminating associated asymmetries;

i) Existence of Countries that do not respond or take a long time to respond to requests for mutual legal assistance. (absence of statistics on asset confiscation and seizure that illustrate the effectiveness of the legal system);

j) Absence of statistics on funds seized under designated lists (national and international);

k) High level of informal economic activities;

l) Non-existence of a public information system that allows verification of the authenticity of citizens' identification documents;

m) Lack of a public information system to consult information on beneficial owners of legal entities;

Recommendations:

a) Creation of a code that aggregates all customs matters to facilitate their promotion and consultation of linked contents;

b) Proposal for approval of a legal instrument or procedures that instruct law enforcement agents in the control and tracking of all strategic goods;

c) Equipping investigation agencies in terms of personnel with training in specific matters of financial crimes, material, financial, technical and other means;

d) Improvement of patrols at all borders with greater focus on land and maritime;

e) Update of Law No. 6/2008, of July 9, on the Prevention and Combat of human trafficking;

f) Continuous training and training of customs and Migration employees on TF and related crimes;

g) GIFiM's need to join the Egmont Group of FIUs;

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h) Massive training of Magistrates in matters related to investigation and judgment of TF crimes;

i) Improvement of internal and international cooperation models to eliminate associated asymmetries and promote swift and timely mutual assistance;

j) Improvement on asset confiscation and seizure that illustrate the effectiveness and efficiency of the legal system.

k) Improvement of statistical information on funds seized under designated lists (national and international);

l) Design and adoption of concrete measures to systematically raise the level of formalization of the national Economy;

m) Creation of interconnectivity of computer systems that allows verification of the authenticity of identification documents by obligated entities;

n) Operationalization of Information System on beneficial owners of legal entities.

o) Implementation of awareness programs on TF matters.

2.5.1. TF Combat Capacity: Description of Input Variable Results

Although Mozambique has made great advances to respond and adapt legislation to the current challenges that Terrorism imposes, it is still pertinent to combine efforts to improve strategic TF Combat policies, the understanding of newly adopted legal and administrative measures.
In the control of strategic goods, there is still much work to be done, it is necessary to map companies, public and private entities that deal with such goods, as well as the control of circulation and commercialization. It is also a challenge to control immigration, the effectiveness of international and domestic cooperation, law enforcement and the training of legal institution staff to implement measures.
Therefore, in general terms Mozambique is in a median phase in the implementation and improvement of TF Combat capacity, as illustrated in the table below:

h) Massive training of Magistrates in matters related to investigation and judgment of TF crimes;

i) Improvement of internal and international cooperation models to eliminate associated asymmetries and promote swift and timely mutual assistance;

j) Improvement on asset confiscation and seizure that illustrate the effectiveness and efficiency of the legal system.

k) Improvement of statistical information on funds seized under designated lists (national and international);

l) Design and adoption of concrete measures to systematically raise the level of formalization of the national Economy;

m) Creation of interconnectivity of computer systems that allows verification of the authenticity of identification documents by obligated entities;

n) Operationalization of Information System on beneficial owners of legal entities.

o) Implementation of awareness programs on TF matters.

2.5.1. TF Combat Capacity: Description of Input Variable Results

Although Mozambique has made great advances to respond and adapt legislation to the current challenges that Terrorism imposes, it is still pertinent to combine efforts to improve strategic TF Combat policies, the understanding of newly adopted legal and administrative measures.
In the control of strategic goods, there is still much work to be done, it is necessary to map companies, public and private entities that deal with such goods, as well as the control of circulation and commercialization. It is also a challenge to control immigration, the effectiveness of international and domestic cooperation, law enforcement and the training of legal institution staff to implement measures.
Therefore, in general terms Mozambique is in a median phase in the implementation and improvement of TF Combat capacity, as illustrated in the table below:

a. It results from all the information above that, combining the factors previously analyzed, namely the threats (National and of people and organizations, vulnerabilities and sectoral risks), it results that the national TF risk is Medium High with a Decreasing trend.

b. This situation results from the following partial risks by sector:

Commercial Banks – Low Medium;
Electronic Money – High;
Informal Finance – Medium;
Fauna, Flora and Fishery Resources – Medium High;
Mineral Resources – High.

c. On the other hand, the following risk categories also influenced:

Domestic – Medium High;
Cross-border/exit – Medium High;
Cross-border/entry – Medium
Transit – Medium

Acronyms

ANRFT - Terrorism Financing Risk National Assessment CEC - Executive Coordination Committee FDS - Defense and Security Forces OT - Terrorist Organization SAMIM - Southern African Development Community Mission in Mozambique ANR - Risk National Assessment ADF/FDA – Allied Democratic Forces ANAC – National Administration of Conservation Areas APNFD’s - Activities and Non-Financial Professions Designated ASWJ – Ahlu Sunnah Wal Jamaah AT – Mozambique Tax Authority AML - Money Laundering BE – Beneficial Owner BM - Bank of Mozambique CFT - Combating the Financing of Terrorism UNSC - United Nations Security Council DIC - Civil Identification Directorate ESAAMLG - Southern and Eastern Africa Anti-Money Laundering Group ERS - Lord's Resistance Army TF – Terrorism Financing FATF - Financial Action Task Force GFC Index Global Financial Centres Index IME – Electronic Money Institution INATRO - National Institute of Road Transport LICSF – Credit Institutions and Financial Societies Law MP – Public Ministry MIREME – Ministry of Mineral Resources and Energy SARCO – Suspicious Operations Reporting Officer NGO'S - Non-Governmental Organizations TIN – Unique Tax Identification Number GDP - Gross Domestic Product PRCD - Cabo Delgado Reconstruction Plan PRM – Police of the Republic of Mozambique RAM - Mutual Assessment Report DRC – Democratic Republic of Congo SENAMI - National Migration Service SFS - Specific Financial Sanctions FIU – Financial Intelligence Unit UNSCR – United Nations Security Council Resolution SADC - Southern Africa Development Community / Community for Development of Southern Africa

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Resolution No. 56/2023 of December 29

Given the need to approve the National Strategy to Combat the Financing of Terrorism, under the provisions of paragraph 6 of Article 57 of Law No. 14/2023, of August 28, which establishes the Legal Regime and Measures for the Prevention and Combat of Money Laundering, Terrorism Financing, the Council of Ministers determines:

Article 1. The National Strategy to Combat the Financing of Terrorism, 2024-2029, attached hereto, is approved, which is an integral part of this Resolution.

Article 2. This Resolution enters into force on the date of its publication.

Approved by the Council of Ministers, on December 19, 2023.

Let it be published.
The Prime Minister, Adriano Afonso Maleiane.

National Strategy to Combat the Financing of Terrorism 2024-2029

Introduction
The Mutual Evaluation of the Republic of Mozambique took place between November and December 2019, with the Report published in June 2021 by the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG). This assessment identified the main weaknesses of the country's legal and institutional framework regarding the Prevention and Combat of Money Laundering, Terrorism Financing, and the Financing of Proliferation of Weapons of Mass Destruction, as well as the challenges in application and effectiveness of the same. The aforementioned Report establishes key recommendations to strengthen the operationalization and effectiveness of the ML/CFT mechanisms of the country, including the need to draft and approve a National Strategy in these matters1.
Between April and November 2023, Mozambique conducted the National Risk Assessment (NRA) on Terrorism Financing (TF), aiming to identify threats, vulnerabilities, and understand existing risks in the prevention and combat regime for Terrorism Financing, as derived from the Recommendations of the Financial Action Task Force (FATF), which establish the need to adopt a risk-based approach.
The NRA aimed to improve the level of knowledge and understanding of Terrorism Financing threats and vulnerabilities, in order to define priorities in resource allocation, targeting the mitigation of identified risks.
Mozambique approved a new legal and institutional framework for the prevention and combat of Terrorism and its Financing, through Law No. 14/2023, of August 28, on the Prevention and Combat of Money Laundering, Terrorism Financing, and Financing of the Proliferation of Weapons of Mass Destruction, and Law No. 15/2023, of August 28, on the Prevention and Combat of Terrorism and the Proliferation of Weapons of Mass Destruction, repealing Law No. 11/2022 of July 7 and Law No. 13/2022 of July 8, respectively.
This document aims to present priority elements to improve the national TF mechanism, through a National Strategy for TF, which is a continuation of the work carried out on the NRA and Mutual Evaluation (ME), incorporating their findings and recommendations, in order to develop a common framework of action for all organs and institutions of the country, thereby making the national system for combating TF more effective and efficient.
Objectives of the National CFT Strategy
This National CFT Strategy aims to sensitize public and private institutions in the country, in particular, and the public in general, regarding the risks of terrorism financing (TF). Similarly, this Strategy intends to mitigate the TF risks to which the Mozambican financial and non-financial systems are exposed, as well as to strengthen the regulatory framework and the application of an effective risk-based approach.
The Strategy also aims to make national coordination actions and international cooperation effective, so that the deficiencies identified in the ME and the results of the country's TF NRA are addressed.
This National Strategy constitutes a reference basis for the various stakeholders in the field of CFT. Therefore, this strategic document refers not only to the action of organs and institutions that make up the public service (among others, supervisory and inspection authorities, regulators, judicial authorities, and law enforcement authorities), but also to the private sector (self-regulatory organizations, regulated professionals, and other relevant actors in the private sector), and to civil society.
Thus, this Strategy intends to institute and promote a common vision among all stakeholders for the adoption of prevention and combat measures against TF on the main national objectives and priorities in sectors identified as being at high risk of ML/TF.
Strategic Guidelines
The National CFT Strategy aims to provide all national stakeholders acting in the area of prevention and combat against TF with a common framework of reforms and improvements to be carried out in order to strengthen the legal and institutional framework, national coordination, and international cooperation in this field.
It is also intended to adopt measures regarding the promotion of financial inclusion and the formalization of the economy, the reduction of the use of cash values in the payment of economic operations, and transparency in the associative sector, which will allow for better detection of illicit value flows linked to transnational organized crime, including terrorism and its financing.
For the pursuit of this Strategy, awareness actions are necessary for the main stakeholders regarding TF risks, and regarding the specific vulnerabilities of each sector evaluated within their responsibilities, in order to allow for better mobilization of organs and institutions regarding their role in fighting illicit financial flows and against the use of certain non-financial activities and professions for TF purposes, regarding activities to strengthen the capacity and allocation of resources to organs and institutions for the full exercise of their functions.
Therefore, the implementation of a risk-based strategy will allow national authorities to better direct financial, technical, technological, and human resources to activities and sectors with a higher degree of exposure to ML/TF risks, thereby seeking to achieve notable and tangible results. It will also allow for the rationalization of resources in situations of medium and low risk identified in the NRA and ME process.

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In this context, five strategic objectives were identified to strengthen the effectiveness of the national CFT system. These objectives are as follows:

Strategic Objective 1: Update the legal framework for the prevention and combat of TF:
Intervention Area 1: Update the current legal framework to combat the crime of terrorism financing; Intervention Area 2: Promote changes in the legal and regulatory framework, in order to enable the adequate action of entities and obligated subjects when applying prevention and combat measures against TF; Intervention Area 3: Introduce changes in the legal and regulatory framework to enable the adequate identification of beneficial owners (effective); Intervention Area 4: Improve the legal framework regarding the application of precautionary, patrimonial, and confiscation measures.

Strategic Objective 2: Strengthen the understanding of the country's exposure to TF risks as well as national coordination and international cooperation mechanisms:
Intervention Area 1: Adopt the national CFT policy and measures to strengthen the understanding of the national CFT strategy; Intervention Area 2: Strengthen measures for adequate and efficient cooperation and coordination among services and authorities acting within the national scope in the prevention and combat of TF; Intervention Area 3: Promote international cooperation within the scope of prevention and combat activities against TF; Intervention Area 4: Adopt measures for the implementation of an efficient system for collecting and analyzing data on prevention and combat activities against TF.

Strategic Objective 3: Strengthen prevention, detection, investigation, prosecution, and judgment measures for TF crimes, and measures related to the loss of products and proceeds resulting from the commission of crimes:
Intervention Area 1: Improve the capacity to prevent and detect TF crimes; Intervention Area 2: Promote specific training and capacity-building activities for judicial and law enforcement authorities to investigate and prosecute TF matters, including the application of provisional measures and loss of assets; Intervention Area 3: Increase the interoperability of data and document filing systems to allow free access by investigation authorities to such information; Intervention Area 4: Increase the effectiveness in applying patrimonial precautionary measures and confiscation; Intervention Area 5: Increase the effectiveness in applying Financial Sanctions for Designated Persons and Entities.

Strategic Objective 4: Infrastructure and Information Availability Intervention Area 1: Strengthen the effectiveness of border controls, with greater emphasis on the transit (entry and exit) of cash and INP (Negotiable Instruments/Papers); Intervention Area 2: Provide reliable identification infrastructure; Intervention Area 3: Create and make available an effective system for identifying the beneficial owner; Intervention Area 4: Establish effective control mechanisms for the provisioning of equipment, goods, and strategic services for conflict zones; Intervention Area 5: Adopt measures to increase the level of formalization of the economy.

Strategic Objective 5: Strengthen measures to combat terrorism financing within the sectoral scope:
Intervention Area 1: Banking sector;
Intervention Area 2: Electronic Money sector;
Intervention Area 3: Informal sector – alternative channels for fund transfers; Intervention Area 4: Fauna, flora, and fisheries resources sector; Intervention Area 5: Mineral resources sector.

The implementation and coordination of the National Strategy to Combat TF will be carried out by a Multi-sectoral Technical Group, and its actions will be implemented by all national actors involved in this Strategy.
Institutions involved in the drafting of the Strategy
This strategy is the result of the work of members of the Multi-sectoral Technical Group created to conduct the National Risk Assessment on TF, namely:
Ministry of Foreign Affairs and Cooperation (MINEC), Ministry of Interior (MINT), Ministry of National Defense (MDN), Attorney General's Office (PGR), State Intelligence and Security Services (SISE), Bank of Mozambique (BM), GIFiM, Tax Authority (AT), National Criminal Investigation Service (SERNIC), Kimberley Process Management Unit (UGPK), and National Administration of Conservation Areas (ANAC).
Description of Strategic Objectives, Intervention Areas, and Results and Performance Indicators Oriented
For each of the five (5) strategic objectives, intervention areas and respective activity lines were identified for their proper implementation. Furthermore, this Strategy has its action plan and respective result indicators.

Strategic Objective 1: Update the legal framework for the prevention and combat of TF Expected Result:
18. Availability of a legal and regulatory framework in technical conformity with international ML/CFT standards (FATF Recommendations), which will allow national authorities to face the crime of TF efficiently and effectively.

Context
19. With the approval of Laws No. 14/2023, of August 28, on the prevention and combat of ML/TF, and 15/2023, of August 28, on the combat against Terrorism, Mozambique has CFT norms, and respective Regulations approved through Decrees No. 53/2023, of August 31, and 54/2023, of August 31.

The following sectors were identified as vulnerable to TF risk in the country: banking, electronic money, alternative fund transfer channels, mineral resources, forestry, faunal, and fisheries sectors, with gaps and deficiencies in legislation that practically prevent the effective action of judicial and law enforcement authorities.
For effective compliance with international norms, it is imperative to implement a legal framework that enables the adequate application of the norms contained in UN Security Council Resolutions regarding TF.
Finally, deficiencies were also identified in the legal framework that need to be addressed to enable the adequate action of obligated entities in applying TF combat measures and the effective identification of beneficial owners.

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Intervention Areas

Intervention Area 1: Update the legal framework for the prevention and combat of TF Activity Lines | Responsible Authority

Review of Law No. 6/2008, of July 9, on the prevention and combat of human trafficking. | MINT (CGPRM, SERNIC and SENAMI) (Resp.) PGR, MJCR, MINEC and AT.
Review of Law No. 15/2023, of August 28, on the Combat against Terrorism. | MJCR (Resp.) PGR, MINEC and FDS.
Review of Law No. 1/2010, of December 31, which approves the legal regime of insurance. | ISSM (Resp.) PGR, MEF and MJCR.

Intervention Area 2: Promote changes in the legal and regulatory framework, in order to enable the adequate action of entities and obligated subjects when applying prevention and combat measures against TF.
Activity Lines | Responsible Authority

Review of Decree No. 63/2021, of September 1, Regulation on the Commercialization of Diamonds, Precious Metals, and Gemstones. | UGPK (Resp.) MIREME, MJCR, PGR.
Conduct inspection actions and regulate the exercise of informal activities, taking into account TF prevention obligations. | UGPK (Resp.) MIREME
Legalize the exercise of activities of the Hawala System | MEF and MIC

Intervention Area 3: Introduce changes in the legal and regulatory framework to enable the adequate identification of beneficial owners (effective).
Activity Lines | Responsible Authority

Draft and approve the Law on Beneficial Owners. | MJACR (Resp.) PGR, MEF, BM and GIFiM
Review sectoral legislation to conform with the need to identify the Beneficial Owner. | Supervisory Authorities.

Intervention Area 4: Improve the legal framework regarding the application of precautionary, patrimonial, and confiscation measures.

Draft and approve the Law on Civil Confiscation (confiscation not based on criminal conviction) | MJCR, PGR (GCRA, GCCC and GCCCOT) and GIFiM

Strategic Objective 2: Strengthen the understanding of the country's exposure to TF risks and national coordination and cooperation mechanisms Expected Result:
23. Understanding of the risks to which the country is exposed, and availability of national coordination policies and mechanisms and international cooperation, which allow national actors to mitigate the TF risks to which the country is exposed.

Context
24. With the completion of the NRA, which serves as the basis for this national strategy, the country has made efforts to achieve a common understanding among all stakeholders in CFT, of the public and private sectors, of the country's exposure to TF risks. Notwithstanding the completion of the NRA, the level of understanding of TF risks by financial institutions and designated non-financial entities and professions is low, according to the finding of Mozambique's 2020 Mutual Evaluation, carried out by ESAAMLG. This conclusion draws attention to the need to promote actions disseminating the results of the NRA among the sectors most vulnerable to TF, in order for them to map the existing TF risks in the context of their activities, so that they can apply internal measures to mitigate identified risks.

Furthermore, the constant evolution of the country's TF risk profile leads to the need to continuously update the understanding of national authorities to ensure the relevance of national policies and laws in this area.
Institutionally, the creation of the GTM to deal with CFT matters ensures that the main ministries and authorities involved in implementing CFT measures can coordinate their efforts appropriately. Mozambique has also strengthened its national coordination structures through the creation of a political body, the Executive Coordination Committee, to channel recommendations to the Council of Ministers for decision-making. These bodies need to be endowed with adequate resources to perform their functions effectively and adequately drive the implementation of this strategy and subsequent actions.
The institution of high-level coordination must also be realized at the operational level, with the strengthening of coordination and cooperation among all competent authorities, including judicial and law enforcement authorities, supervisory and inspection authorities, and self-regulatory bodies, to improve internal information exchange on CFT and operationalize national CFT devices, namely in matters of applying relevant United Nations Security Council Resolutions.
It is also necessary to institute public-private partnerships to maximize the trust gains achieved in the implementation of the NRA and sustain a greater understanding of risk and the implementation of preventive TF measures.
At the international level, due to the transnational nature of crime in Mozambique, national authorities must have adequate means to mobilize all available sources of information, to collect evidence, seize, and declare forfeited to the State the proceeds of crime.
The effectiveness of the fight against transnational organized crime depends on the capacity of competent authorities to make greater use of Mutual Legal Assistance (MLA), to collect intelligence information, gather evidence, and proceed to asset recovery.

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The improvement of information management devices and the maintenance of comprehensive statistics on CFT, to analyze the effectiveness and efficiency of the system, constitute fundamental elements for Mozambique. Thus, the country should introduce a case management framework and priority-setting mechanisms to allow for the handling of TF cases, as well as international cooperation issues, in a timely and coherent manner according to the country's risk profile, which will allow for monitoring and accounting for handled requests.

Intervention Areas

Intervention Area 1: Adopt the national CFT policy and measures to strengthen the understanding of the national CFT strategy Activity Lines | Responsible Authority

Organize the dissemination of NRA results to sectors identified as most vulnerable to TF. | MEF (Resp.) Law Enforcement Authorities (LEA) and Supervisors
Promote awareness among Law Enforcement Authorities, Supervisory Authorities, and obligated entities regarding the TF risks to which the Country is exposed. | MEF (Resp.) LEA and Supervisors
Draft, approve, and implement the national CFT policy. | PGR, FDS, GIFiM, BM, AT and UGPK
Creation of a TF Risk Assessment Office and for the effective monitoring of the implementation of the national CFT policy and strategy. | FDS, PGR, GIFiM, BM, AT and UGPK
Create a National TF Alert System. | FDS, PGR, GIFiM, BM, AT and UGPK

Intervention Area 2: Strengthen measures for adequate and efficient cooperation and coordination among services and authorities acting within the national scope in the prevention and combat of TF Activity Lines | Responsible Authority

Strengthen national coordination, through the celebration of Protocols for coordination and information exchange among competent authorities, in the identification of threats aimed at combating TF. | MEF (Resp.) National Authorities
Create a Multi-sectoral Technical Group related to the prevention, detection, and combat of TF. | MEF (Resp.) LEA and Supervisors

Intervention Area 3: Promote adequate international cooperation within the scope of prevention and combat activities against TF.
Activity Lines | Responsible Authority

Strengthen cooperation between national authorities and international authorities involved in combating TF. | MEF (Resp.) LEA and Supervisors
Promote border control mechanisms in cooperation with neighboring countries, regional, and international bodies. | MINEC (Resp.) LEA and FDS
Ensure the adherence of GIFiM to the Egmont Group and promote cooperation between supervisory authorities and their counterparts. | MEF (Resp.) LEA and Supervisory Authorities

Intervention Area 4: Adopt measures for the implementation of an efficient system for collecting and analyzing data on prevention and combat activities against TF.
Activity Lines | Responsible Authority

Creation of computerized databases in judicial and law enforcement authorities, as a way to have comprehensive statistics regarding the entire action of the CFT system. | MEF (Resp.) MJCR and PGR
Ensure the effectiveness of customs controls on cash and negotiable instruments to bearer. | AT (Resp.) MEF, PGR, BM, GIFiM, SERNIC

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Strategic Objective 3: Strengthen measures for the prevention, detection, investigation, prosecution, and trial of terrorism financing (TF) crimes and measures related to the loss of proceeds and profits resulting from the commission of crimes

Expected Result
32. Strengthening the capacity of law enforcement authorities to effectively identify TF threats in the country.

Context
33. Although Mozambique has achieved significant advances in recent years in the detection, investigation, and prosecution of TF cases, it was found that financial "intelligence" activity is rarely used by law enforcement authorities to initiate TF or predicate offense investigations. In the Mozambican repressive system, the receipt and analysis of Suspicious Transaction Reports (STRs) are the responsibility of the Financial Intelligence Unit of Mozambique (GIFiM), which subsequently disseminates them to law enforcement authorities for investigation tasks and subsequent prosecution of TF cases.
34. In the context of criminal investigation, the National Criminal Investigation Service (SERNIC), created by Law No. 2/2017, of January 9, is the auxiliary body of the Public Ministry responsible for criminal investigation, among other crimes, including TF and its main predicate offenses. The Public Ministry, in turn, directs the preparatory instruction and exercises criminal action and the instruction of criminal cases in the country. In this regard, the creation of the Central Office for Combating Organized and Transnational Crime stands out, a body of the Public Ministry specialized in the prevention, direction of instruction, and exercise of criminal action against, among others, TF crimes.
35. Given the operational resource limitations of GIFiM, it was verified that financial analysis activity is still not produced satisfactorily. Similarly, although there are information sharing channels between GIFiM and law enforcement authorities, the coordination of activities between these bodies still needs improvement, eliminating some bureaucratic aspects, in order to impart speed to the start of TF case investigations.
36. Within the Public Ministry, despite the existence of magistrates trained in terrorism financing crime investigation, the number of TF and predicate offense cases successfully closed is still not significant given the current national scenario, due to the lack of prioritization in the investigation and prosecution of cases, in accordance with the risks identified in the country.
37. Despite investments in human, technical, technological, and financial resources, the challenge of expanding the staff cadre, including their training, to achieve satisfactory results in the investigation of TF crimes and predicate offenses throughout the national territory remains. On the other hand, it was found that law enforcement and investigation authorities, based on statistical data, face challenges in clarifying TF crimes.
38. In this context, measures must be adopted to increase the effectiveness of law enforcement authorities' actions in their prevention, detection, investigation, and response activities regarding TF cases.
39. The capacity of GIFiM must also be improved, equipping this entity with human and material resources so that it can effectively execute the processes of evaluation and monitoring of Suspicious Transaction Reports (STRs), with the rapid and effective exchange of information with law enforcement authorities and other bodies with competencies in TF matters.
40. On the other hand, it is indispensable to carry out training actions for members of judicial and law enforcement authorities, so that they adequately possess technical and operational knowledge for the regular exercise of detection, investigation, and prosecution activities of TF cases.
41. The participants in the TF process, in this case, SERNIC and the Public Ministry as the director of procedural instruction, have specialized personnel and offices for the investigation of crimes of this nature, leaving the challenge of creating specialized sections in the Courts for the processing of TF crime cases.
42. Finally, necessary measures must be adopted aiming at the creation of multi-sectoral technical groups and specialized action units in the different law enforcement authorities and the promotion of adequate measures to reinforce the integrity and independence of law enforcement and judicial authorities acting in the CFT sector.

Intervention Area 1: Improve the capacity to prevent and detect TF crimes

Lines of Activity	Responsible Authority
1. Train supervisory authorities and obligated entities in matters of prevention and combating TF.	AAL and supervisory authorities
2. Facilitate adequate training for competent authorities to reinforce the use of Mutual Legal Assistance mechanisms to obtain information and evidence, as well as for the pursuit and recovery of assets.	MJACR
3. Increase cooperation mechanisms between supervisory authorities and obligated entities in combating TF.	AAL and supervisory authorities
4. Evaluate the vulnerabilities of the prevention systems of supervisory authorities and obligated entities, create, maintain, and monitor the adoption of corrective measures to strengthen the TF prevention system.	AAL and supervisory authorities
5. Equip supervisory authorities and obligated entities with financial, human, and technological resources for combating TF.	AAL and supervisory authorities
6. Strengthen financial intelligence dissemination mechanisms to law enforcement authorities, for the prevention, detection, and combating of TF.	GIFiM, PGR, AT, and SERNIC
7. Improve the process of monitoring transactions and increase the quantity and quality of TF-related Suspicious Transaction Reports.	AT, BM, and GIFiM

Intervention Areas

Intervention Area 2: Promote specific training and capacity-building activities for judicial and law enforcement authorities to investigate and prosecute TF matters, including the application of provisional measures and asset forfeiture.

Lines of Activity	Responsible Authority
1. Train and capacitate law enforcement and investigation authorities in parallel investigation matters, based on financial intelligence, mutual legal assistance, and asset recovery.	CFJJ (Resp.)<br>PGR, SERNIC
2. Equip and capacitate law enforcement and investigation authorities for the use and application of mutual legal assistance in the domain of investigation and asset recovery.	PGR (Resp.)<br>SERNIC
3. Capacitate law enforcement authorities in TF matters identified in the ANRFT.	CFJJ, PGR, and GIFiM
4. Capacitate law enforcement authorities on the vulnerabilities of the Flora, Fauna, and Fisheries Sector in TF.	PGR (Resp.)<br>SERNIC, ANAC, and AT

Intervention Area 3: Increase the interoperability of data and document filing systems to allow free access of investigation authorities to such information

Lines of Activity	Responsible Authority
1. Reduce security vulnerabilities by increasing interoperability between all data control systems among all supervisory authorities and obligated entities.	MJACR (Resp.) PGR
2. Create mechanisms and instruments that allow the dissemination of statistical data regarding the effectiveness of TF prevention, detection, and combating policies.	PGR and MJACR

Intervention Area 4: Increase the effectiveness in the application of patrimonial precautionary measures and confiscation

Lines of Activity	Responsible Authority
1. Develop training actions for Investigators, Magistrates, and AAL, on financial and patrimonial investigation.	PGR, FDS, and GIFiM
2. Improve mechanisms for the collection, processing, and conservation of statistical data on frozen and confiscated assets.	PGR, FDS, and GIFiM

Intervention Area 5: Increase the effectiveness in the application of Financial Sanctions measures for Designated Persons and Entities.

Lines of Activity	Responsible Authority
1. Improve mechanisms for the dissemination of National Designated Lists and UNSC Lists.	MINEC, MJCR, PGR, and Supervisory Authorities
2. Establish an internal procedure on the implementation of the sanctions regime applicable to designated lists.	MINEC, MJCR, PGR, and Supervisory Authorities

Strategic Objective 4: Infrastructure and Information Availability

Expected Result
43. Strengthen border control infrastructures for the entry and exit of cash and bearer negotiable instruments, and ensure the availability of information.

Context
44. One of the indispensable factors for an efficient system of prevention and combating TF is the effective control of borders, so that national authorities are aware of the entry and exit of persons and goods that may be used for TF. On the other hand, terrorism financing can be effectively combated if criminals face difficulties in circulation and movement of goods, through prevention and detection mechanisms.
45. In the case of Mozambique, some vulnerabilities have been identified in this component, hence the need to implement measures to strengthen border controls.
46. Similarly, the national identification infrastructure constitutes one of the indispensable vectors for combating TF. In fact, if obligated institutions have ease in detecting forged or fraudulent documents and other identification instruments, they can, with greater efficiency, detect situations of attempted abuse of the financial system for TF purposes. The ANR identified that the Country needs to implement a swift system for the verification of identification documents, namely through computerized means.
47. Since legal persons are one of the vectors for concealing resources to be collected and moved for TF purposes, it is essential that the country has a system for registering and making available information on beneficial owners.

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In this case, this registration system is still not operational, so one of the identified weaknesses is the non-existence of updated information on the beneficial owners of legal entities.
48. The control of the production, entry, marketing, circulation, and use of strategic goods also constitutes an element to be considered for the improvement of internal capacity to combat TF, as facilitated access to this category of goods increases the terrorist threat.
49. Finally, high economic informality also constitutes a vulnerability, as it reduces the State's capacity to identify economic agents and monitor their respective activity. In this case, the INE categorized the Country as having high levels of economic informality, making it imperative to take measures aimed at accelerating the formalization of the economy.

Intervention Areas

Intervention Area 1: Reinforce the effectiveness of border controls, with greater emphasis on the transit (entry and exit) of cash and BNI

Lines of Activity	Responsible Authority
1. Reinforce border control and inspection mechanisms.	MINT and AT
2. Train border control officers and agents in the identification of cash and Bearer Negotiable Instruments.	MINT and AT
3. Equip authorities responsible for border control with auxiliary means for the identification of cash and Bearer Negotiable Instruments.	MINT and AT

Intervention Area 2: Provide reliable identification infrastructure;

Lines of Activity	Responsible Authority
1. Allow interoperability of infrastructures between national identification authorities and credit institutions for the certification of the authenticity of identification documents.	MINT and CREL (Resp.)<br>MIC
2. Consolidate the computerization of public institution databases.	MCTES (Resp.)<br>INTIC and INAGE

Intervention Area 3: Create and provide an effective system for the identification of the beneficial owner

Lines of Activity	Responsible Authority
1. Finalize the legal mechanism for the implementation of the beneficial owners tool.	MJCR (Resp.)<br>CREL
2. Design and operationalize a system for the identification of the beneficial owner.	MJCR (Resp.)<br>CREL
3. Raise awareness among existing societies about the need to update information on beneficial owners.	MJCR (Resp.)<br>CREL
4. Raise awareness and train obligated entities on the use of the beneficial owner identification system.	MJCR (Resp.)<br>CREL and Supervisory Authorities

Intervention Area 4: Establish effective mechanisms for the control of the provisioning of equipment, goods, and strategic services for conflict zones

Lines of Activity	Responsible Authority
1. Reinforce mechanisms for the inspection and control of strategic goods in the country and their declaration by companies and entities.	MINT and AT

Intervention Area 5: Adopt measures to increase the level of formalization of the economy.

Lines of Activity	Responsible Authority
1. Adopt political, legislative, and economic measures to accelerate the formalization of the economy.	MEF (Resp.)<br>MIC and AT

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Strategic Objective 5: Strengthen measures to combat terrorism financing in the sectoral context

Expected Result
50. That the evaluated sectors, namely the banking, electronic money, fauna, flora and fisheries resources, and mineral resources sectors, understand the TF risks to which they are exposed and that supervisory and inspection authorities apply adequate risk mitigation measures to prevent and detect TF operations.

Context
51. Supervisory and inspection authorities develop efforts to disseminate the legal framework on CFT and to mobilize actors of obligated sectors in compliance with preventive measures provided for in the Law on Prevention and Combating TF.
52. Although these efforts have resulted in better application of CFT obligations in the evaluated sectors, subsequent steps must be taken to improve the understanding of risks in some domains, namely, the illegal exploitation of metals and precious stones, fauna, flora, and fisheries resources. In these latter sectors, there is a lack of human resource capacity, reflected in the ineffectiveness of the TF prevention and combating system.
53. According to the ANR, the sectors for the purchase and sale of metals and gems and faunal resources are particularly exposed to TF and special attention will be given to supporting the implementation of risk mitigation measures, through greater awareness of their vulnerabilities. Additionally, training activities for competent regulators and supervisors in these sectors will be organized for the application of measures to monitor these sectors in the effective compliance with CFT measures.
54. Supervisors/regulators should issue guidelines, promote capacity-building and more effective supervision actions, contributing to the effective implementation of legal requirements in TF prevention.
55. The effectiveness of prevention and combating systems is essentially measured by the presentation of reliable and updated statistical data in various aspects. Thus, the existence, maintenance, and updating of extensive statistical databases that allow measuring the effectiveness of CFT actions are of special importance.

Intervention Area 1: Banking Sector

Lines of Activity	Responsible Authority
1. Improve the level of knowledge and understanding of applicable legislation in TF matters.	BM (Resp.)<br>AMB
2. Improve control and supervision mechanisms of financial institutions regarding financial flows and international trade.	BM (Resp.)<br>AT
3. Improve the process of evaluation and monitoring of suspicious transactions regarding TF.	BM (Resp.)<br>GIFiM and AMB
4. Improve the quality of TF-related Suspicious Transaction Reports.	GIFiM (Resp.)<br>BM and AMB

Intervention Area 2: Electronic Money Sector

Lines of Activity	Responsible Authority
1. Improve the level of knowledge and understanding of applicable legislation in TF matters.	BM (Resp.)<br>Electronic Money Institutions
2. Improve the process of evaluation and monitoring of suspicious transactions regarding TF.	BM (Resp.)<br>GIFiM
3. Improve the quality of TF-related Suspicious Transaction Reports.	GIFiM (Resp.)<br>BM
4. Strengthen the capacity of the compliance function in TF matters.	BM (Resp.)<br>Electronic Money Institutions

Intervention Area 3: Informal Sector – Alternative Fund Transfer Channels

Lines of Activity	Responsible Authority
1. Creation of mechanisms for the legalization and formalization of activity.	MEF (Resp.)<br>MIC, MJACR, and BM
2. Creation of mechanisms for the awareness of Hawala System Operators regarding the formalization of activity.	ANAC (Resp.)<br>MADER and MINT

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Implementation Calendar of the National Strategy

Short-term Actions – 1 year	Medium-term Actions – 3 years	Long-term Actions – 5 years

Intervention Area 4: Flora, Fauna, and Fisheries Resources Sector

Lines of Activity	Responsible Authority
1. Improve licensing, inspection, and inspection mechanisms for the exit and entry of faunistic, fisheries, and forest products.	ANAC (Resp.)<br>MADER and MINT

Intervention Area 5: Mineral Resources Sector

Lines of Activity	Responsible Authority
1. Improve licensing, inspection, and inspection mechanisms for the exit and entry of mining products.	INAMI and UGPK (Resp.)<br>MIREME and MINT
2. Adopt mechanisms for Risk-based Supervision.	UGPK (Resp.)<br>INAMI, IGREME, and MIREME

List of Acronyms

Acronym	Full Name
AJM	Mutual Judicial Assistance
AAL	Law Enforcement Authorities
AM	Mutual Evaluation
ANAC	National Administration of Conservation Areas
ANEA	National Atomic Energy Authority
ANR	National Risk Assessment
ANRFT	National Assessment of Terrorism Financing Risks
APNFD	Designated Non-Financial Activities and Professions
AT	Tax Authority
BM	Bank of Mozambique
BC/FT	Money Laundering and Terrorism Financing
CBC	Combating Money Laundering
CEC	Executive Coordination Committee
COS	Suspicious Transaction Report
CSNU	United Nations Security Council
CFT	Combating the Financing of Terrorism
ESAAMLG	Eastern and Southern Africa Anti-Money Laundering Group
GAFI	Financial Action Task Force
GCCC	Central Office for Combating Corruption
GIFiM	Financial Intelligence Unit of Mozambique
GCPCD	Central Office for Prevention and Combating Drugs
GTM	Multi-sectoral Technical Group
IGJ	General Inspection of Games
IMF	Microfinance Institutions
INAMI	National Institute of Mines
INAE	National Inspection of Economic Activities
IGREME	General Inspectorate of Mineral and Energy Resources
ISSM	Mozambique Insurance Supervision Institute
MEF	Ministry of Economy and Finance
MCT	Ministry of Science and Technology
MIC	Ministry of Industry and Commerce
MINEC	Ministry of Foreign Affairs and Cooperation
MINT	Ministry of Interior
MTA	Ministry of Land and Environment
MJCR	Ministry of Justice, Constitutional Affairs and Religious Affairs
MIREME	Ministry of Mineral Resources and Energy
OAM	Order of Lawyers of Mozambique
OCAM	Order of Accountants and Auditors of Mozambique
OSFL	Non-Profit Organizations
ONU	United Nations Organization
PGR	Attorney General of the Republic
PEP	Politically Exposed Persons
RC	Commercial Register
SA	Public Limited Company
SERNIC	National Criminal Investigation Service
SISE	State Intelligence and Security Service
TS	Supreme Court
UGPK	Kimberley Process Management Unit
UNSRC	United Nations Security Council Resolution

Resolution No. 57/2023 of December 29

Given the need to create the Executive Coordination Committee for Policies on Prevention and Combating Money Laundering and Terrorism Financing, the Council of Ministers, under the provisions of paragraph b) of paragraph 2, of Article 203 of the Constitution of the Republic, determines:

Article 1
(Nature and Scope)
The Executive Coordination Committee, abbreviated as CEC, is created, with the objective of implementing policies for the Prevention and Combating of Money Laundering, Terrorism Financing, and the Proliferation of Weapons of Mass Destruction, and it functions under the tutelage of the Minister of Economy and Finance.

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Article 2
(Mission)
The Executive Coordination Committee for the Prevention and Combating of Money Laundering and Terrorist Financing has as its mission to monitor and coordinate the identification, assessment, and response to Money Laundering and Terrorist Financing (ML/TF) risks to which Mozambique is or may become exposed, contributing to the continuous improvement of technical compliance and the effectiveness of the national system for combating ML/TF.

Article 3
(Attributions)

The attributions of the Committee are:
a) propose the adoption of policies necessary for the pursuit of the national strategy for the prevention and combating of money laundering and terrorist financing; b) carry out the identification and periodic assessment of ML/TF risks specifically associated with non-profit organizations; c) evaluate, on a continuous basis and in light of identified risks, the technical compliance and effectiveness of the national system for the prevention and combating of money laundering and terrorist financing, defining the necessary instruments, procedures, and mechanisms; d) contribute to the improvement of the quality, completeness, coherence, and reliability of relevant statistical data in the field of prevention and combating of money laundering and terrorist financing; e) propose the legislative, regulatory, and operational measures necessary to ensure:
i. the proper execution of the Strategy and national policies for the prevention and combating of money laundering and terrorist financing;
ii. the technical compliance and effectiveness of the national system for the prevention and combating of money laundering and terrorist financing, in light of identified risks;
iii. compliance with the international obligations of the Mozambican State in matters of prevention and combating of money laundering and terrorist financing, particularly those derived from the 40 Recommendations of the Financial Action Task Force (FATF) and other sources of International Law that bind the Mozambican State; and
iv. compliance with international best practices for the prevention and combating of money laundering and terrorist financing, namely those resulting from the standards and guidelines defined by the Financial Action Task Force (FATF);
f) promote, whenever necessary, the carrying out of consultation procedures that must precede the adoption of the legislative measures referred to in the previous subparagraph; g) promote and coordinate the exchange of information and the carrying out of reciprocal consultations between the entities that make up the committee and between these and other entities with responsibilities in the field of prevention and combating of money laundering and terrorist financing, defining adequate and effective instruments, mechanisms, and procedures for information exchange; h) propose the joint carrying out, by the competent authorities, of supervisory or inspection actions regarding regulated entities, as well as any other joint initiatives relevant to the pursuit of the attributions referred to in the previous number; i) prepare assessments of the national system for the prevention and combating of money laundering and terrorist financing requested by the Financial Action Task Force (FATF) or other supranational bodies with competence in the matter; j) prepare and coordinate responses to requests or demands made by supranational bodies with competence in matters of prevention and combating of money laundering and terrorist financing, whenever so requested, namely those coming from the FATF; k) issue opinions and formulate concrete recommendations within the scope of their attributions and competences; l) direct and coordinate the Focal Points Group (GPF) indicated by the Ministers and Heads of the Justice Administration System (SAJ); m) evaluate and propose the adoption of policies necessary for the pursuit of the national strategy for the prevention and combating of ML/TF; n) contribute to the improvement of the quality, completeness, coherence, and reliability of relevant statistical data in the field of prevention and combating of ML/TF; and o) prepare assessments of the national system for the prevention and combating of ML/TF requested by supranational bodies with competence in the matter.

Article 4
(Functions)
The Executive Coordination Committee is competent to:
a) approve its internal regulations and strategic guidelines for its activity; b) approve the annual activity plan; c) approve the annual activity report; d) approve the assessment report and proposal of policies necessary for the pursuit of the national strategy for the prevention and combating of money laundering and terrorist financing, which must be submitted for approval by the Council of Ministers each year; e) approve the instruments, procedures, and mechanisms referred to in subparagraphs b), c), and j) of the previous number; f) approve the final report of the updates of the national assessment of money laundering and terrorist financing risks; g) take note, in particular:
i. of the updates of existing sectoral risk assessments;
ii. of the response measures to money laundering and terrorist financing risks that may be proposed by the Commission, as well as their state of execution;
iii. of the results of the assessments to which Mozambique may be subject, as well as any follow-up measures determined as a result thereof;

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h) approve the creation of a Permanent Technical Secretariat, working groups, or specialized sections for the study or resolution of issues of special relevance or complexity; i) approve the inclusion of representatives of other bodies in the composition of this body; and j) pronounce on any other matters that are submitted to its consideration.

Article 5
(Direction and Mandate)

The Executive Coordination Committee is presided over by a National Coordinator, with the status of Permanent Secretary, appointed by the Council of Ministers.
The National Coordinator is appointed from among persons with recognized professionalism, of notorious integrity, and with relevant professional experience for the attributions and requirements of the function, and they exercise their functions for a term of five years, renewable.

Article 6
(Powers of the National Coordinator)
In the exercise of their functions, the National Coordinator is competent to:
a) ensure the proper execution of the Strategy and national policies for the prevention and combating of money laundering and terrorist financing; b) ensure compliance with the international obligations of the Mozambican State in matters of prevention and combating of money laundering and terrorist financing, particularly those derived from the 40 Recommendations of the Financial Action Task Force (FATF) and other sources of International Law that bind the Mozambican State. c) promote, whenever necessary, the carrying out of consultation procedures that must precede the adoption of the legislative measures referred to in the previous subparagraph; d) direct and coordinate the Focal Points Group (GPF) indicated by the Ministers and Heads of the Justice Administration System (SAJ); e) contribute to the improvement of the quality, completeness, coherence, and reliability of relevant statistical data in the field of prevention and combating of ML/TF; f) represent the CEC within and outside the Country; g) guide, coordinate, and supervise the activities developed by the CEC; h) request, directly, from any entities, public and private bodies, the necessary information that the CEC needs to perform its functions; i) submit to the appreciation of the Minister who superintends the area of Finance the policy and strategy proposals of the CEC; j) submit to the appreciation of the Minister who superintends the area of Finance the proposals for the activity plan and budget of the CEC; k) coordinate the execution of the policies and strategies of the CEC approved by the Council of Ministers; and l) coordinate the execution of the activity plan and budget of the CEC;

It is also incumbent upon the National Coordinator:
a) present to the High-Level Committee proposals for administrative and legislative measures regarding their attributions and competences for approval by the competent bodies; b) Promote and coordinate the exchange of information and the carrying out of reciprocal consultations between the entities that make up the Committee and between these and other entities with responsibilities in the field of prevention and combating of money laundering and terrorist financing, defining adequate and effective instruments, mechanisms, and procedures for information exchange.

Article 7
(Bodies of the CEC)
The bodies of the CEC are:
a) National Coordinator; b) Focal Points Group; c) Secretariat.

Article 8
(Composition)

The Focal Points Group is composed of representatives from each of the following entities:
a) Ministry that superintends the area of Finance; b) Ministry that superintends the area of Foreign Affairs; c) Ministry that superintends the area of National Defense; d) Ministry that superintends the area of Interior; e) Ministry that superintends the area of Justice; f) Attorney General's Office; g) National Criminal Investigation Service; h) State Intelligence and Security Service; i) Bank of Mozambique; j) Executive Coordination Committee; k) Mozambique Insurance Supervision Institute; l) National Directorate of Registries and Notary; m) General Inspectorate of Games; n) Mozambique Tax Authority; o) Bar Association; p) Mozambique Order of Accountants and Auditors; q) Kimberley Process Management Unit; r) National Administration of Conservation Areas; s) Mozambique Financial Information Unit; t) Technical Assistance Coordination Committee (Technical Assistance Partners are integrated); and u) Private Sector and civil society.
It is incumbent upon Cooperation Partners and the Private Sector to indicate their representatives.
The Committee meets, ordinarily, once a month and, extraordinarily, whenever convened by the National Coordinator.
The National Coordinator may invite representatives of other institutions due to the subject matter.

Article 9
(Technical Secretariat)

The Technical Secretariat is composed of:
a) employees of the Ministry of Economy and Finance; b) representative of the Bank of Mozambique; c) representative of the Mozambique Insurance Supervision Institute; d) representative of the General Inspectorate of Games; and e) representative of the Mozambique Financial Information Unit.

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It is incumbent upon the Minister of Economy and Finance to appoint the Coordinator of the Permanent Technical Secretariat, upon proposal of the National Coordinator.

Article 10
(Operation)

The Executive Coordination Committee enters into operation within 30 days from the date of publication of this resolution, and the entities referred to in number 6 must indicate their representatives, respectively, to the Ministry of Economy and Finance.
It is incumbent upon the members of the Executive Committee to provide the necessary human and technical means for the pursuit of their attributions, with the Ministry of Economy and Finance being responsible for ensuring the indispensable logistical means for its operation.
The entities that make up the Committee provide, in accordance with the law, the collaboration requested by the Committee for the pursuit of its attributions.
The Committee may, in accordance with the law, request any person or entity the information necessary for the pursuit of its attributions.
The entities that make up the Committee, the Focal Points Group, the Permanent Technical Secretariat, working groups, and specialized sections, as well as their respective representatives, are obliged to keep secret the facts of which they become aware in the exercise of their functions, and the provision of information, collaboration, and assistance to the Committee must be carried out, in accordance with the law, in strict respect of the duties of legal secrecy applicable and obligations in matters of personal data protection and professional secrecy.
In the exercise of functions in the Coordination Committee, in the Focal Points Group, in the Permanent Technical Secretariat, in working groups, and in specialized sections, [remuneration/allowances] shall be fixed by Dispatch of the Minister who superintends the area of Finance.

Article 11
(Entry into Force)
This Resolution enters into force on the date of its publication.
Approved by the Council of Ministers, on December 19, 2023.
Publish.
The Prime Minister, Adriano Afonso Maleiane.
Price — 150.00 MT
NATIONAL PRESS OF MOZAMBIQUE, E.P.

Resolution No. 56/2023: Approves the National Strategy to Combat Terrorist Financing, 2024-2029

Lineage: In force