FACULTY OF LAW

A CRITICAL ANALYSIS ON THE INEFFECTIVENESS OF ANTI MONEY

LAUNDERING LAWS IN ZAMBIA AND MOZAMBIQUE

By
SIMIAO MUCAVELE
(000-748)

A Dissertation submitted to the Faculty of Law of the Cavendish University in partial fulfilment
of the requirements for the award of the Degree of Bachelors of Laws (LLB).

Cavendish University Zambia

P.O Box 34625

LUSAKA

Aug, 2019

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 DECLARATION

I, SIMIAO EMILIO MUCAVELE, do hereby declare that this dissertation is my authentic work,
and to the best of my knowledge, information and belief, no similar piece of work has previously
been produced at Cavendish University Zambia or any other institution for the award of Bachelor
of Laws Degree. All other works in this essay have been duly acknowledged.

…………………………………………………

Candidate’s signature

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 I recommend that the Directed Research Essay prepared under my supervision by:

SIMIAO EMILIO MUCAVELE

(000-748)

Entitled:
A CRITICAL ANALYSIS OF THE INEFFECTIVE ANTI MONEY LAUNDERING
LAWS IN ZAMBIA AND MOZAMBIQUE

Be accepted for examination. I have checked it carefully and am satisfied that it fulfills the
requirements pertaining to format as laid down in the regulations governing Directed Research
Essays.

Supervisor…………………………. Date…………………………………
MISS. KAFWILU CHINAMBU

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DEDICATION

To my parents “Emilio Zefanias Mucavele & Julia Jamiao Mucavele” for all the opportunities you
have created for me leading to my completion of law school and for your endless belief in my
potential I can not thank you enough.

To HLB Zambia for your endless support in my education having aided me in my studies more
ways than I can to reach the finish line, I am forever thankful.

I appreciate you all.

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ABSTRACT

Money laundering has proven to be a continuous growing concern to Southern African most
especially in the two jurisdictions of Mozambique and Zambia. This is evident in the rapid rise in
foreign development projects funded through vast amounts of foreign direct investments in the
countries for many developmental projects. The sources of these foreign direct investment funds
brought into the country for the purpose of covering up the illegal nature of the investment capital
through large scale investment venture such as real estate projects, illegal mineral mining and other
illicit trade activities. The growing incidents involving acts of misappropriation and embezzlement
of tax payers money publicly presented in the Auditor General’s annual reports illustrates the
magnitude of the problem relating to money laundering crimes also within public offices by
government officials. The large presence of such illicit activities even in government is as a result of
the lack of effective anti-money laundering laws, a common feature Zambia shares with Mozambique
and other developing states. There are numerous other cases of ineffective money laundering policies
which will be discussed in this study.
This dissertation will investigate the rapid spread of this epidemic of money laundering due to
ineffective money laundering laws on the jurisdiction of Mozambique and Zambia, placing
recommendations on how to better combat the growth and spread of money laundering through the
enhancement of domestic anti money laundering laws.

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ACKNOWLEDGEMENTS

First and foremost, it is my pleasant duty to express profound gratitude to my family and all friends
and loved ones who have helped me in several manners to reach this stage of my academic studies
and to this victorious completion of the research and the paper. An exceptional expression of
gratitude goes to my Parents, for your understanding, devotion and constant support always
through my academic studies. You have always led by example and awarded me the best of
opportunities, for that I express my endless gratitude to you. I further wish to recognise my utmost
gratitude to my Inonge Mwiya & Nzali Mwazembe who were always there to read and provide
feedback of my progress in the most critical moments when writing my research paper.

I lastly wish to acknowledge my profound gratitude to my Supervisor Madam KAFWILU

CHINAMBU, for the counsel and direction in the preparation of my dissertation. I am grateful for
all you have touch me throughout my studies with Cavendish.

I award you all my sincerest gratitude.

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LIST OF ABBREVIATIONS

(FATF ) - Financial Action Task Force

(AML) - Anti Money Laundering
(SADC) - Southern African Development Community
(A.G office) - Office of the Auditor General of Zambia
(ACC) - Anti Corruption Commission of zambia
(DEC) - Drug Enforcement Commission of Zambia
(FIC) - Financial Intelligence Centre
(BOZ) - Bank of Zambia
(ZP) - Zambia Police Service.
(PRM) - The Police of the Republic of Mozambique “Policia da Republica de Mocambique”
(PIC) - The Criminal Investigation Police “Policia de Investigacao Criminal de Mocambique”
(PPS) - The Public Prosecution Service
(SISE) - State Intelligence Service Mozambique
(IFFs) - Illicit Financial Flow
(WGI) - Worldwide Governance Indicators
(VAT) - Value Add Tax
(PLAC) - Anti-Corruption package
(GCCC) - Central Public Ethics Commission of Mozambique
(RVC) - Reception and Verification Committee of Mozambique
(AMLA) - Anti-Money Laundering Authority of Zambia
(STR) - Suspicious Transactions Report
(DPP) - Director of Public Prosecution

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TABLE OF CONTENTS

RESEARCH TOPIC…………………………………………………………………...…….I
DECLARATION………………………………………………………………………..…..II
SUPERVISORS’ APPROVAL…………………………………………..……………..….III
ABSTRACT………………………………………………………….……………………..IV
ACKNOWLEDGEMENTS……………………………………..………………….….……V
DEDICATION……………………………………………..………………………….…….VI
LIST ABBREVIATIONS……………………………………………………………………VII
TABLE OF STATUTES…………………………………………………………………...VIII
TABLE OF CONTENTS…………………………………………………………………….XI

CHAPTER 1 INTRODUCTION
1.0 INTRODUCTION 1

1.1 BACKGROUND 1

1.2 STATEMENT OF THE PROBLEM 2

1.3 OBJECTIVES OF THE STUDY 3

1.3.1 GENERAL OBJECTIVE 3

1.3.2 RESEARCH OBJECTIVES 3

1.3.3 SPECIFIC OBJECTIVES 4

1.3.4 RESEARCH QUESTIONS 4

1.4 SIGNIFICANCE OF THE RESEARCH 4

1.5 RESEARCH METHODOLOGY 5

1.6 ASSUMPTIONS 6

1.7 CONCLUSION 6

CHAPTER 2: LITERATURE REVIEW

2.1 INTRODUCTION 8

2.2 THE CONCEPT OF MONEY LAUNDERING 8

2.3 MONEY LAUNDERING IN ZAMBIA 10

2.3.1 Bribery & Corruption 10

2.3.1.1 Public Procurement Activities 10

VIII
2.3.1.2 Use of shell Corporate mechanisms 11

2.3.1.3 Use of Professional firms as “Gatekeepers” 11

2.3.1.4 Use of Domestic Financial Institutions 11

2.3.1.5 Ineffective controls in public institutions 11

2.3.1.6 Tax Evasion 11

2.4 MONEY LAUNDERING IN MOZAMBIQUE 12

2.4.1 The informal economy 12

2.4.2 Corruption 13

2.4.3 Trade Mis-invoicing 14

2.4.4 The Mining Sector 14

2.4.5 Poaching and smuggling 15

2.5 MONEY LAUNDERING AT INTERNATIONAL LEVEL 16

2.6 MONEY LAUNDERING IN THE WAKE OF THE SEPTEMBER 11, ATTACKS 16

2.7 MONEY LAUNDERING SYSTEM 17

2.8 METHODS OF MONEY LAUNDERING 18

2.9 CRUCIAL COMPONENTS OF THE CRIME OF MONEY LAUNDERING 19

2.10 FRAMEWORK OF THE ANTI - MONEY LAUNDERING STRUCTURES IN ZAMBIA 20

2.10.1 ANTI MONEY LAUNDERING INSTITUTIONAL FRAMEWORK 20

2.10.1.1 Anti-Money Laundering Authority ( AMLA) 20

2.10.1.2 THE DRUG ENFORCEMENT COMMISSION OF ZAMBIA (DEC) 20

2.10.1.3 THE OFFICE OF THE AUDITOR GENERAL OF ZAMBIA 21

2.10.1.4 Task Force of Senior Officials on AML matters 21

2.10.1.5 The Financial Intelligence Centre (‘the Centre’) 21

2.10.1.6 Law Enforcement Agency (LEAs) 22

2.10.1.7 Supervisory Authorities 22

2.10.1.8 Reporting Entities 23

2.10.1.9 Judiciary of Zambia 23

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2.10.1.10 Others Relevant Government Agencies 23

2.11 INSTITUTIONAL FRAMEWORK OF THE ANTI - MONEY LAUNDERING

STRUCTURES IN MOZAMBIQUE 23

2.11.1 Domestic legal framework 24

2.11.1.1 Anti-corruption law 24

2.11.1.2 Penal Code 24

2.11.1.3 Public Probity law 24

2.11.1.4 Political funding 24

2.12 LEGAL AND INSTITUTIONAL FRAMEWORKS AGAINST MONEY LAUNDERING IN

MOZAMBIQUE 25

2.12.1 Central Office for Combating Corruption (Gabinete Central de Combate à Corrupção,
GCCC) 25

2.12.2 Prosecutor General’s Office (Procurador- General da República) 26

2.12.3 Judiciary of Mozambique 26

2.12.4 Central Public Ethics Commission (GCCC) 26

2.12.5 Reception and Verification Committee (RVC) 26

2.12.6 Financial Intelligence Unit of Mozambique 26

2.13 CONCLUSION 27

CHAPTER 3: METHODOLOGY AND DESIGN

3.1 INTRODUCTION 29

3.2 RESEARCH METHODOLOGY AND APPROACH 29

3.3 JUSTIFICATION FOR USING QUALITATIVE RESEARCH 30

3.4 RESEARCH DESIGN 31

3.5 RESEARCH STRATEGY 31

3.5.1 PARTICIPANT OBSERVATION 32

3.5.2 IN-DEPTH INTERVIEWS 32

3.6 Reliability and Validity 32

3.7 Ethical Consideration 33

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3.8 SUMMARY AND CONCLUSION 33

CHAPTER 4; DATA ANALYSIS

4.1 INTRODUCTION 34

4.2 MOTIVES FOR INEFFECTIVENESS OF AML 34

4.2.1 Vulnerability of Foreign Direct Investments 34

4.2.2 BRIBERY & CORRUPTION OF KEY PLAYERS IN THE FIGHT AGAINST MONEY
LAUNDERING 35

4.2.3 POLITICAL INTERFERENCE IN THE PROCEEDINGS 36

4.2.4 Lack Of Political Will To Prosecute 37

4.2.5 SOCIO-ECONOMIC FACTORS 38

4.2.6 WEAK INSTITUTIONAL FRAMEWORK 39

4.2.7 Poor record keeping 39

4.2.8 Unbalanced composition of the Anti-Money Laundering Authority 40

4.3 CONCLUSION 40

CHAPTER 5: CONCLUSION AND RECOMMENDATION

5.1 INTRODUCTION 41

5.2 GENERAL CONCLUSION 41

5.3 RECOMMENDATIONS 42

CHAPTER 6: BIBLIOGRAPHY
6.1 ARTICLES 44

6.2 BOOKS 44

6.3 CASES 44

6.4 STATUTES 44

6.5 REPORTS 45

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CHAPTER 1 INTRODUCTION
1.0 INTRODUCTION
The purpose of this dissertation is to examine the inefficiencies in the legal framework regulating
money laundering actives in the economies of both Zambia and Mozambique. The study further
will further establish the reasons to why such proceeds of crime are increasingly entering these
economies undetected. The adverse growth of development entering these economies through foreign
direct investment and other business actives such as large real estate projects in creation of
employment are some of the vast ways in which such proceeds are concealed1. The core purpose of
this dissertation is to investigate the legislative regulatory framework of money laundering created in
effort to eliminate this phenomenon, with a comparison between the two economies of Zambia and
Mozambique. In Chapter 1 of the dissertation Introduces the background on the study & statement of
the problem of money laundering in its major growth.

1.1 BACKGROUND
The dissertation arrises from the growing international and domestic problems of large levels of
laundering money. The notion extends into common law felonies such as embezzling, forgery
together with uttering which is putting forged money into circulation and other statutory felonies
such as corruption. At a global level there exists a measure of resemblance and conformity amongst
the different laws which relate to money laundering crimes2. This conformity can be associated to the
influence of international instruments that create duties regarding the criminal offence of money
laundering. At regional level this study is motivated by the escalated cases of money laundering
activities in Zambia Specifically involving public funds often disclosed in the Auditor General’s
Annual reports, such as In Mozambique this crimes are driven by similar cases of misappropriation
of state funds, kidnappings, human trafficking, Narcotics trafficking and wildlife trafficking which
are all also disclosed in the auditor generals report3. Both these nations Auditor general report disclose
alarmingly high levels of laundering of public funds. It is for those reasons for which the study is
prompted in the determination and legal regulation of the problem of such crimes of money
laundering in within the Southern African region with the concrete focus on the two nations. This
study ergo will examine both nations legal framework in the war against combating money
laundering. The vast focus will be in the capacity these two nation are at in combating such fraudulent
crimes through legislative and institutional capacity of these states in the emergence of technological
developments in the domains of commerce, trade and industry. Thereby the study scrutinise the

1
Global Financial Integrity. 2015. “Issues: Illicit Financial Flows”.
2
OECD. 2014. “Illicit Financial Flows from Developing Countries: Measuring OECD Responses”.
3
Wolf, A. and E. Klein. 2016. “Mozambique: Overview of Corruption and Anti-Corruption”.
1
mechanisms in place but also considers the best international practices and frameworks in combating
money laundering. The research too takes notice of some of the publications by other researchers in
this particular field of study and in the same stratification encourages for more investigation and study
in the sphere of money laundering elimination.

The Sentencing of a number of distinguished politicians in both Zambia and Mozambique as a result
of the high levels of embezzlement of state funds which has become a common Section of the
Auditors General’s annual reports, certifies the need for the continuation of enforcement of stronger
governmental and procedural structure in irradiating money laundering in efforts of protecting state
resources. The Financial Action Task Force also Commonly abbreviate as FATF is the global body
which set international standers for anti money laundering abbreviated as ‘AML’. This task force
offences a wide rage of offences that are provided for under the United Nations Convention Against
Illicit Traffic in Narcotic Drugs and Psychotropic Substances of 1988. The definition of money
laundering under the FATF comprises of crimes such as fraud, kidnapping and theft. Money
laundering entails of a mechanism involving earnings of criminal activities which are concealed in
illegal proceeds. Such

1.2 STATEMENT OF THE PROBLEM

Money laundering has been a continuous concern to the Southern African region most especially in
the two nations of Mozambique and Zambia. This is seen within the rapid growth in development in
both these nations as these countries were severely under developed but in the latest past have come
to see a vast amount of foreign direct investment in the countries for many developmental projects.
The sources of these foreign direct investments are many from large scale corporate financing through
legitimate Realestate project profits converted into new investments and also internal debt
incorporations, although some of these foreign direct investments are illegally obtained funds brought
into these countries for the purpose of concealing the illegal origins of the investment capital through
large scale investment venture such as real estate projects, illegal mineral Mining and other illicit
activities. Such illicit actives have a massive effect on economic, social, political and cultural shells
of these two Nations. Such activities manifests themes in various forms particularly by funds acquired
through criminal or illicit activities Such if which comprise of drug trafficking; illegal arms deals;
illegal smuggling of precious stones; and such related environmental crimes, cyber crimes; fraud; and
armed robberies. Remarkably within Zambia, the growing reporting of misappropriation or theft of
public funds as publicly presented in the Auditor General’s annual reports illustrates the magnitude
of the problem relating to money laundering crimes also within public offices by government
officials. The large presence of such illicit activities money laundering even in government is largely
2
as a result of the lack of a rigorous anti-money laundering legal control, a feature Zambia shares with
many developing states4. To further demonstrate the degree of this problem of ineffective anti money
laundering laws within these jurisdictions, An ideal example would be the fraudulent use of
Mozambique’s financial system to conceal capital of illicit origin at the cost of the Mozambican State,
causing estimated loss of 1.887 billion Mozambican meticais in 2016 from revenue, as the authority
of the Public Attorney’s Office of Mozambique (PGR)5. There are numerous other cases of ineffective
money laundering policies which will be discussed in this thesis illustrating the severity of the
situation and the colossal rapid concern of its growth among these two jurisdictions. This dissertation
accordingly inquires into the epidemic of money laundering due to ineffective money laundering
policies with a consecrated forces on the jurisdiction of Mozambique and Zambia further of which
will implement recommendations to how to better combat the growth and spread of money
laundering.

1.3 OBJECTIVES OF THE STUDY

1.3.1 GENERAL OBJECTIVE

The widespread motive of this thesis is to effectively evaluate the effectiveness of the legislative and
governmental configuration in the fight against money laundering within Mozambique and Zambia.
Ergo, the paper shall explore the notion of money laundering within the two jurisdictions in
identifying the pros and cons of the anti money laundering structures. Likewise, the paper shall
examine the international anti-money laundering strategies for recommendation of implementation
in the fight against this crime.

1.3.2 RESEARCH OBJECTIVES

This investigation is targeted towards assessing and evaluating the status of the increasing money
laundering cases and the legal instruments and structures in place to restrict and illuminate these illicit
activities. Secondly, the paper will identify the obstacles present in the struggle towards the
illumination and control of such illicit actives of money laundering within these jurisdictions,
including cases successful prosecution case of such activities. Thirdly the paper fundamentally
focuses on some of the inefficiencies in existence with the current anti money laundering laws of each
of the two respective jurisdictions.

4
Per the Honourable Chief Justice of the Republic of Zambia, Mr Justice E. L Sakala, during his speech on the Call
Day for the Newly Admitted Advocates on 19 December 2008 at the Lusaka Supreme Court of Zambia. Available from
the Chief Justice‟s Chambers, Lusaka.
5
“Mozambique Loses Millions of Dollars to Money Laundering.” Edited by Club of Mozambique, Maputo, Flora De
Maputo, 18 Apr. 2017, clubofmozambique.com/news/mozambique-loses-millions-of-dollars-to-money-laundering/.
3
The research question is accordingly: “Is the cause of the rapid growth in money laundering activities
in Mozambique and Zambia, as a result of the ineffective anti money laundering laws and structures
within these nations ? and how best can we strengthen them”

1.3.3 SPECIFIC OBJECTIVES

I) To study the institutional along with the judicial structures on anti money laundering between
the jurisdictions of Zambia and Mozambique.
II) To study the existing established Anti Money Laundering systems both in Zambia and
Mozambique.
III) To study other international anti money laundering practices.
IV) To critically examine these two countries international adherence with International anti
money laundering conventions.
V) To Recommend way in which these countries may strengthen their Anti Money Laundering
Laws.

1.3.4 RESEARCH QUESTIONS

The dissertation searches to nourish specific solutions to the questions below:
I) Is there a functional legal framework in order to effectively eradicate money laundering in
these two jurisdiction of Zambia and Mozambique ?
II) Are the institutional Anti money laundering bodies in existence in both these jurisdictions
effectively combating the vice?
III) Have the anti money laundering laws in the two jurisdictions managed to adhere to
International anti money laundering standards and practices?
IV) Lessons these to countries can take from other countries on the fight against money
laundering.

1.4 SIGNIFICANCE OF THE RESEARCH

The significant of this thesis is to bring out the shortfalls and obstacles in the legislative and
institutional controls to the vice of money laundering in Mozambique and Zambia, Thus furthermore
the paper will attempt to postulate how best to better eliminate and reduce the emerging growth of
this vice, Through strengthening existing anti money laundering controls. Specifically focusing on
the illicit activities which occur with public funds through acts of embezzlement and
misappropriation by government officials throughout their time in office. This thesis distinguishes
itself from pervious monographs as it fundamentally faces on anti moony laundering structures in
place between two completely different jurisdictions, as it will be comparing and contrasting the
4
differences between the two. The eventual target of this paper is to hearten and incite both students
and legal practitioners to contribute more towards the fight against all forms of money laundering in
their countries. It is of vital importance that the anti money laundering laws of these two counties be
tightened and brought up to speed with other international investment and monetary laws. This paper
consequently is aim toward adding a meaning and impactful endorsement in form of knowledge to
Government, society, the private and public sectors of the economies of both Mozambique and
Zambia. As this knowledge is deliberated to aim in eliminating the problem of money laundering in
both counties and also at continental levels. The study also is also aimed at subscribing knowledge
with the determination of enhancing awareness and understanding needed in addressing the complex
question of money laundering. It is critically vital that these two counties anti-money laundering
regulations be brought abreast of efforts undertaken by other countries in the Southern African
Development Community (SADC) to give effect to regional agreements reached on combating
money laundering in the African sub-continent.

1.5 RESEARCH METHODOLOGY

The study is based on an analysis of the jurisprudence handed down by both Mozambican and
Zambian courts. The paper contrasts case law from both jurisdictions with European and Asian anti
many laundering case law. Although large portions of the research is heavily drawn from
international and regional anti money laundering instruments such as Regional legislation within the
SADC region, International treaties, plus academic publications of research conducted by the
University of Zambia which has proved to be a vital source of information. The research method used
for data collection in this learning was the qualitative research method which included entrant
observation from the selected groups which were specifically established to include members of the
seven (7) law enforcement agencies in both Mozambique and Zambia. In collecting the research, the
study used symposiums, Review and pivot dialogs with the law enforcement agencies of both
Jurisdictions, Which specifically entailed of the following agencies in Zambia; the Anti-Money
Laundering Investigations Unit, office of the Auditor General of Zambia (A.G office), Anti
Corruption Commission of Zambia (ACC), Drug Enforcement Commission of Zambia (DEC), the
Financial Intelligence Centre (FIC), the Bank of Zambia (BOZ) and the Zambia Police Service (ZP).
From the Jurisdiction of Mozambique the agencies looked into when conducting the research were
the following: Multi-Disciplinary National Task Force (for coordinating efforts and promoting
cooperation amongst law enforcement agencies) chaired by the Ministry of Finance and consists of
representatives from the Ministry of Justice, Ministry of the Interior, the Attorney General’s office
and the Central Bank. Its primary responsibility is to advise the government on AML/CFT matters.

5
The paper also conducted data collection from other mozambican money laundering regulators such
as the following;
- The Police of the Republic of Mozambique (Policia da Republica de Mocambique - PRM)
- The Criminal Investigation Police (Policia de Investigacao Criminal - PIC)
- The Public Prosecution Service (PPS)
- The Mozambican Revenue Authority
- State Intelligence Service (SISE)
- Central Cabinet for Prevention and Fight Against Drugs
- General Inspectorate of Gambling
- Ministry of Mineral Resources
- Registry for companies and other legal persons, and for legal arrangements
- Bank of Mozambique

1.6 ASSUMPTIONS
This study is premised on the following assumptions:
1. The Anti money laundering laws are ineffective in controlling nor combatting the growth of this
epidemic in both Mozambique and Zambia.
2. There are no functional enforcement mechanisms in the anti money laundering laws of both
Mozambique and Zamia.
3. There are allot of lessons both the governments of Mozambique and Zambia can learn from
continental and global Anti money laundering Laws.

1.7 CONCLUSION
In conclusion, this study has drawn out the basic widespread of the research. It has specifically
focused on numerous research objectives under the concept of anti many laundering laws.
Additionally the study strived to establish the cause of the problem of illicit money laundering and
legislative origins. The Zambian and Mozambican jurisdictions have evidently taken sever decisive
step in aim to undertake and strengthen the legislative including the institutional framework for
combating money laundering.
The problem of money laundering is known to have intensified at the stage of the 911 terrorist attack.
This further establishes the money laundering is a crime an offence which exists along side or criminal
activities such as human trafficking, drug traffic, domestic terrorism and corruption.

6
The evolving complexity in the detection and prevention not forgetting prosecution of money
laundering crimes is what makes the legislative instruments ineffective in their desired purpose.
Consequently, states must also do their part by ensuring enactment of effective public policies
reflecting international best practices against money laundering.
The following Chapter discusses the concept of money laundering from both prospectives of Zambia
and Mozambique.

7
CHAPTER 2: LITERATURE REVIEW

2.1 INTRODUCTION
The aim of chapter two will be to look into the topic of money laundering from both the Mozambican
and the Zambian prospectives and practices. The paper will also focus on the emergence of money
laundering and introduction of anti money laundering mechanisms and laws in the two countries.
The subject matter of money laundering borders around majority of this chapter looking at it from
its several angels from its definitions to its elements to the offences constituted under the commitment
of the vice.

The study also explains the money laundering processes. The discussion outlines the basic offences
of money laundering and essential elements of this offence. The study further explains some notable
techniques used as vehicles for money laundering syndicates. The study concludes by examining the
rationale for combating money laundering and explains why countries such as Zambia must take
effective measures to eradicate this vice. This discussion is vital to this research in that it underscores
what constitutes the offence of money laundering in Zambia and at international level. The study
explains the concept of money laundering in general so as to appreciate the challenges faced by states
in the fight against this vice.

2.2 THE CONCEPT OF MONEY LAUNDERING

This section of the study will evaluate the essence of the concept of money laundering, Through
analysis of the meaning and significance of the problem of money laundering as interpreted by various
the legislative statutes. The focal point of the study elucidates on the many functions held by the and
the many rile exam various anti one laundering laws within these two jurisdictions. The theory of
money laundering takes place in various configurations, one of these theories was brought to light by
British authors Mandinger and Zalopany who advocated that the origins of money laundering
emerged back in the 17thCentury century in England through pirates vessels, Due to the high cost of
maintaining a ship, such as crew, arms, ammunition and other expenses, the pirates ended up looting
and robbing other ships6. It is believed that the Pirates would deposit the stolen good with esteemed
merchants in America, who exchanged the merchandise for money and the collection of these values
of money obtained would take place at the period the pirates would decide to retire. With this, the
pirates contributed with a true fortune that appeared to be coming from carrying out legitimate
businesses. The modern day use of the term money laundering originates from the United Stated of

6
Origin of money laundering in the 17th century

8
America in years 1986, which came from the mafia ownership of Laundromats7 in the country. On
of the major authors to explore the concept of money laundering and its effects on nations was
Rodrick Parlour, in his book International Guide on Money Laundering: Law and Practice of which
his material has been an essential to money laundering. In this book he Further explains How the use
of establishments with coin operating washing machines and dryers for public us were highly used
by the mafias for laundering illegally obtained funds. Such businesses were infamously used by the
mafias because they were cash business and not easy to account.The washing and drying machines
function in a way which the user inserts coins into it for the machine to begin washing or drying, this
direct physical coin dependency for the machine to function was seen as a perfect mechanism for the
mafias to launder their illicit monies in that it was almost impossible to account the exact amounts
generated by the machines. The mafias opted this kind of business because it was purely cash based
as previously stated above, providing them with the upper hand advantage it was almost impossible
of the authorities to trace the illegal cash flows. The mafias operated just like gangs in the United
states who were generating large amounts of money from illicit activities which included things such
as illegal Drug trafficking, blackmail, illegal gambling, illegal sex trade and also unauthorised alcohol
trade 8 . The first attempt the American government took to regulating illegal trade and money
laundering they introduced a law known as ‘Financial Crimes Enforcement Network Act, 1970’
which required that all businesses and their owners to produce valid sources of their business
proceeds. In retort the mafias constructed alternative methods to conceive their funds one of which
was by purchasing seemingly licit businesses of which they laundered their unlawful earnings with
their legal funds9.

AL CAPONE, known as one of the most famous money launder to ever exist in the United State of
America, acquired several laundromats in effort of cleaning illicit earnings of criminality. The term
“money laundering” transpired from the prosecution of the mafia leader Al Capone as the prior to
this there was no law yet drafted against this crime10. His prosecution was as a result of tax avoidance
for illicit earnings11.

The definition of money laundering takes various forms. The difficulty of the offence of money
laundering is that it does not occur independently of other offences such as drug trafficking. There
has been as a result of the advanced global technology, this offence has further been complicated in

7
Laundromats defined as automated machines used to automatically do laundry through inserting of cash in the
machine to activate the machine to do laundry for an express period which is automated. This business was operated by
criminal units as a way of disguising their illicitly acquired funds.
8
Rodrick Parlour, International Guide on Money Laundering: Law and Practice (London: Butterworths,1995) 23
9
Rodrick Parlour, International Guide on Money Laundering: Law and Practice (London: Butterworths,1995)17
10
J. Fisher, Money Laundering Law and Practice, (Oxford: Oxford University Press, 2001) 42-43
11
Rodrick Parlour, International Guide on Money Laundering: Law and Practice (London: Butterworths,1995)25
9
detection and prosecution of offenders. The introduction of telephone banking for example entails
that one could transfer funds from one account to another within a short space of time. These
developments have not been corresponding with the law reforms particularly in emerging economies
and least developed countries. The illicit activity of washing dirty money into clean money is called
“money laundering” for the reason that it ideally lays out the occurrences of the process involved in
washing illicit earnings in other word known as ‘dirty money’ which is run through a loop of
transactions, so that it comes out legal.

Money laundering activities occurs outside the use of a financial system in laundering their funds,
but through several other alternative ways of such as acquiring properties and also incorporating off
shore companies.

2.3 MONEY LAUNDERING IN ZAMBIA

In Zambia the institution which monitors money laundering activities is the financial intelligence
center; this centre disseminates and promulgates reports regarding suspicious illicit financial flows
of money laundering within Zambia. In the year of 2018 the financial intelligence published findings
of suspicious transactions valued at the worth of 6.1 million Zambian kwachas. Such activities are
largely attributed to the increase in the value of illicit financial transactions, in the following Sectors;

2.3.1 Bribery & Corruption

In Zambia one of the most widespread form of corruption involve activities of bribery and self
conflict of interest of which last year recorded an estimated 4.9 billion kwacha in value lost within
the Zambian economy. Forms of corrupt acuities which have dominated the Zambian jurisdiction
have included the following ;

2.3.1.1 Public Procurement Activities

- Often such procurements activities within public institutions are often significantly vulnerable
to the involvement of corruption and conflict of interest through the issuing bodies. The public
asset purchasing procedures involve strict stages and structures of which are to be followed in
the awarding of government contracts and tenders to applicants. The tender process in Zambia
refers to the process whereby governments invite bids for projects that are submitted within a
determined time frame, following which the placement of an offer, finalized with awarding of
the tinder by the awarding to a relevant neutral corporation or body. Although this is often not
the case at hand when it comes to such procedures because executives often illustrate a conflict

10
 of interest by awarding to corporations which they are a personal stake in. These awards are also
awarded to inflated invoices in the interest of personal benefits.

2.3.1.2 Use of shell Corporate mechanisms

- These are legally incorporated companies that are non operational. Such companies are
commonly used in the bidding for government tenders but executives within governments itself.
Shell corporations in Zambia are commonly used for the purpose of obtaining government
contracts and laundering illicit proceeds, through concealing of true owners of the business .

2.3.1.3 Use of Professional firms as “Gatekeepers”

- The financial Intelligence Centre have in their past reports published findings of large uses of
gatekeepers such as law firms and accounting firms to launder illicit proceeds. This is
specifically one through the purchases of properties and distributing the ownership of such
properties among the beneficial owners of the funds. The perpetrators often involving executives
in senior public offices.

2.3.1.4 Use of Domestic Financial Institutions

- Money laundering in Zambia is also a common phenomenon conducted within monetary
institutions, thus this is evidently visible in the vast numbers of micro financial institutions,
Pension funds and insurance companies.

2.3.1.5 Ineffective controls in public institutions

- Money laundering in Zambia further occurs with the involvement of illegally riding companies
which are not registered with the relevant statutory body uncharge of company incorporation and
registration (the patent and companies registration agency ‘PACRA’). This situation is so sever
that one could even find these companies being awarded government contracts.

2.3.1.6 Tax Evasion

Many Laundering in Zambia is also present through illicit practices of tax evasion of which involves
the misrepresentation of income to the local domestic revenue authority. Various of these occurrences
have to do with the involvement of small to medium sized enterprises which majority of such
enterprises are not compliant with statutory obligations such as taxes. Methods commonly used in
Zambia to launder illicit proceeds, consist of untruthful accounting of sales for a reduction in their
11
tax obligations. Another method used for to launder illicit proceeds are group company loans and the
use of alternative personal accounts for company business transactions for purposes of concealing the
precision of the financial records in effort of paying less taxes.

2.4 MONEY LAUNDERING IN MOZAMBIQUE

Within this jurisdiction money laundering is classified under the concept known as illicit financial
flows ( IFFs) which is a term that was introduced in the 1990s which associates with the countries
cross boarder movement of capital associated with criminal activities. Money laundering in the
jurisdiction of Mozambique has seen a severely large increase within the past years between early
2000s and 2014 the county’s Attorney General has estimated average of U$138 million to U$289
million dollars fraudulently left the county as IFFs12. Money laundering activities in this jurisdiction
is reported to be relatively common and linked to drug trafficking, criminal abductions and customs
fraud13. Such proceeds of illicit activities have financed several commercial real estate development
projects within the country most especially in the capital city. Money laundering in the financial
sector is also cited to be a critical problem in the country with a rapidly growing number of illegal
forex houses and cash carriers who play significant roles in the money laundering activities in the
country. Moreover black markets in the country also severely common for laundering illicit proceeds
through the smuggling of goods and informal financial services undermining the formal sector14.
Some of the main sources of Illicit financial flows in Mozambique include the following;

2.4.1 The informal economy

The country continues to deal with “fraudulent schemes involving circulation of large sums
of money outside the financial system”15, Although informality is a common problem across
the southern region16. Even so Mozambique, is included in countries with highest ranking
ratios of informality17. These informal activities make up more than 60% to the country’s
gross domestic product. As the case with numerous African countries, the informal economy
in Mozambique includes:
• street Vending
• home manufacturing of goods and services

12
(APA News 2017)
13
US Department of state 2014.
14
Ibid
15
Ibid
16
According to the International Labour Organization, “the percentage of the informal economy ranges between 45%
and 90%” in Africa.
17
Roughly 80% of the people are informally employed in the agricultural sector or work in informal trade in cities (US
Department of State 2017)
12
 • people working in informal businesses
• informal and unregulated transport of goods and passengers (both by road and artisanal
shipping)

2.4.2 Corruption
Corruption is another ubiquitous complication in the country18. The country also fares poorly
on all six dimensions of governance measured by the World Bank’s Worldwide Governance
Indicators , and has been progressively declining19. A period study was conducted on the
value of corruption within the county throughout a period of 2000 - 2012 amounted up to an
astonishing US$ 4.9 billion20. Corruption is one of the direct sources of illicit financial flows,
illicit activities such as bribing and misappropriation of government financial resources
makes up almost 5% of the criminal outflow in Mozambique21. The alarmingly high levels
of corruption in this country can develop fertile soil for money laundering as illustrated in
the case where the government illegally obtained loans of amounting to US$ 1.4 billion which
was further hidden from public knowledge. The loans were facilitated by two banks Credit
Suisse and the Russian bank VTB, moreover the money was allowed to three companies
controlled by the Mozambican State security services (SISE). Later an audit financed by the
government of Sweden, undertook efforts to determine how the borrowed money was spent
but due to a lack of collaboration by the government and the auditors the audit was
incomplete22. It was later brought to light that some of the loans intended for “kickbacks” for
personal use & enrichment in additional political funding knead of their intended purpose23.
In addition the credit granted to the their state owned companies were illegally granted
government guarantees by the then Minister of Finance, who needed to have obtained the
legislative approval for the loan24.

18
Transparency International’s Corruption Perceptions Index gives the country a score of 25 on a scale from 0 (most
corrupt) to 100 (least corrupt).
19
Wolf, A. and E. Klein. 2016. “Mozambique: Overview of Corruption and Anti-Corruption”. U4 Expert Answer.
20
Centro de Integridade Pública and Chr. Michelsen Institute. 2016. “The Costs of Corruption to the Mozambican
Economy: Why It is Important to Fight Corruption in a Climate of Fiscal Fragility”, CMI Report Number 6 December
2016.
21
Goga, K. 2015. “Addressing Corruption May Act as a Significant Step to Limit Illicit Financial Flows from Africa”.
22
De Renzio, P. and Nuvunga, A. 2016. “Bankrupting Mozambique: From Poster Child to Cautionary Tale”. African
Arguments. 12 July 2016.
23
Ibid
24
Williams, A. and J. Isaksen. 2016. “Corruption and State-Backed Debts in Mozambique – What Can External Actors
Do?”

13
 This case in particular set a direct precedent on how corruption can reproduce illicit financial
flows through unconstitutional procedures supporting private debts to a foreign creditor of
which in addition, had broke a domestic budget appropriation bill as well as rules in foreign
financial services jurisdictions25.

2.4.3 Trade Mis-invoicing

This deals with the deliberate misstating of the cost, quantity, or configuration of chanties on
customs assertion forms and account statements, Normally for the motive of evading taxes
and laundering illicit proceeds.
- Merchants often under-report the quantity of imports in a consignment in order of
avoiding related tariffs and Value Add Tax (VAT).
- Import over invoicing conceals the movement of funds out of a country. This is known
as a mechanism of overcoming capital controls, leaving companies with the ability of
deducting that investment value from the annual revenue report to the government,
lowering the amount of taxes payable to the government.
- Export under-invoicing entails under-declaring the quantity of exports leaving a country
for the purpose of eluding or evading duty on company’s earning in the country of export
and having the dissimilarities accumulated into an unfamiliar account.
- Export over-invoicing entails over-stating costs of exports, often allowing the retailer to
secure additional export credits, one may in addition employ this trade mis-invoicing for
concealing inflows of money to doge capital anti-money laundering scrutiny.
Collective total illicit flows from trade mis-invoicing in Mozambique amounted an
astonishing US$ 5.27 billion over the period 2002 to 2012 26.

2.4.4 The Mining Sector

Majority of Mozambiques Economic affluence in the past has been influenced largely by the
Mining of natural resources industry, specifically coal mining, agroforestry and following the
2012 discovery of natural gas in the coast of the country, its exploitation. The Mining sector
in Mozambique often is vulnerable becoming reproductive grounds for illicit financial flows
specifically money laundering, this is due to the close association between the plentifulness
of natural resources and some of the inherent characteristics of the mining industry. The

25
Ibid
26
Global Financial Integrity. 2015. “Issues: Illicit Financial Flows”.
14
 Mining sector is particularly susceptible to illicit financial flows for some of the following
motives:
- The mining industries fall under high-degree of discretionary political command,
example a president or executive minister, and are often susceptible to confidentiality.
- State owned corporations in resource extractive industries at times obstruct focus
between their own personal interests and public interests.
- The lack of competition within the extra time sector results in little to none proper
structures and procedures ( checks & balances).
On the authority of the Environmental Investigation Agency, almost 76% of domestic timber
exports durning the year of 2013 were illegally cut in surplus of the proclaimed harvests. The
illicit logging is often attributed to widespread corruption and poor governance (EIA 2013).
Evidence shows that bribery and fraud among public officials and timber agents have
facilitated illegal timber trade; including corrupt relations between Senior government
officials and the timber trade agents aid them in the avoidance of command and illegally
secure timber trade permits27.

2.4.5 Poaching and smuggling

Wildlife related crimes have seen a significant increase in the recent past specifically in the
area of cross boarder organized crimes driven by a driven by “high demand and facilitated
by a lack of effective law enforcement and low prioritisation as a serious crime, weak
legislation, and non-commensurateUS$ 7 penalties”. It is a highly profitable criminal trade,
with wildlife products of extremely high cost on the black market, and global earning
guesstimated to quantify to approximately US$ 7 billion and 23 billion yearly and is thus a
pilot of money laundering. Illegal hunting operations in Mozambique has seen an
increasingly modernised growth in the recent years with the pumping in of enormous
financial support from criminal international ivory traffickers. Consequently this has
resulted in an increase of criminal illegally hunting Gangs geared with sophisticated rifles.
Moreover as a result of the increasingly high amount of poaching the elephant inhabitation
in Mozambique has been an alarming decline from an estimated population of 12,000 in 2011
to just 3,675 in the year 2016. No public information has been published on the exact value
of illegal elephant tusks and rhino horns trade in the country but the wealth is visibly

27
Environmental Investigation Agency (2013)

15
 noticeable in the ‘Massinga’ region of the country through the large houses and expensive
cars, with anecdotal evidence that these are financed through criminal illegal hunting28.

2.5 MONEY LAUNDERING AT INTERNATIONAL LEVEL

The vice of money laundering occurs globally throughout international financial systems with the
involvement of large sums of cash distributed among several bank all over the world some of which
located in special jurisdictions such as free economic zones29, financial offshore centers30 and tax
heavens31. Such proceeds are later converted to legitimate monetary instruments into forged highly
inflated payments of goods & services by holding corporations of which are under ownership of the
beneficiaries under third parties such as their lawyers of accountants. The laundered proceeds are
later reassembled at their destination then at a later stage remitted back to their jurisdiction of origin
as foreign direct investment. This is the simple but complex procedure used globally in laundering
illegal proceeds at a global scale, which consists of little to no paper trail involved with accounts
always liquidated and no evidence trails.

2.6 MONEY LAUNDERING IN THE WAKE OF THE SEPTEMBER 11,

ATTACKS
In light of the September 11th attacks on the United States of America in 2001, privacy and
confidentiality policies within banks were watered down. Collaboration with foreign banks were
made illegal. Financial institution were essentially transformed into law compliance firms vested with
the roles of verifying identities and origins of non American clients and more importantly the source
of origin of their monies32. Cash transactions also became to a certain extent criminalised further the
securities and monetary commerce, insurance, and money transfer industries became exposed to
increased scrutiny as a trench for "dirty cash”. One bank in America had apparently reported a
suspicious transaction in the account of one of the September 11 hijackers only to be ignored. Since
the unfortunate occurrence of the 911 attacks the United States of America established an
international money laundering investigative Unit, charged with the mandate of monitoring charities,
NGO's, credit card fraud, cash smuggling, counterfeiting, and the Hawala networks33. Following the
attack more than 150 nations pledged to co-operate with the American Government in the global
fight against the money laundering and terrorism financing. 81 of the Nations of which composed of

28
Oxpeckers. 2017. “Mozambique’s Poaching Castles Are Crumbling”.
29
Free Economic zones
30
Financial offshore centre
31
Tax heaven
32
Money Laundering in the Wake of the September 11 Attacks
33
A system or agency for transferring money traditionally used in the Muslim world, whereby the money is paid to an
agent who then instructs a remote associate to pay the final recipient.
16
the Bahamas, Argentina, Kuwait, Indonesia, Pakistan, Switzerland, and the EU. Actually ceased
assets of suspicious individuals with links to money laundering through suspected charities, and
unreliable firms around the globe. Other nations such as (Germany, UK and The Philippines)
introduced new anti money laundering laws which consisted of stricter regulations. Further to which
the European Union introduced a directive which legally obligated lawyers to reveal implicating
information to authorities regarding their clients illegal money laundering activities. The magnitude
of this international collaboration in combating money laundering and terrorism financing had never
existed or been witnessed before.

2.7 MONEY LAUNDERING SYSTEM

The practice of laundering money is one of complex and sophistication, articulated in three of the
following stages which take illicit earnings and convert them into lawfully attained funds entering the
economy34.

(1) Setting; This is the point of entry of the illegally obtained funds into the economy with the direct
intent of cleaning the money from its criminal origin of generation. This is the point of which
the cash is distributed into several businesses fronts disguised as income of those businesses. At
this stage the illicit earning are in cash form

(2) Coverage, concealing the origin of the money. This stage involves the creation of complex
coating of transactions in effort to conceal the trail origin of the money. The purpose of this stage
is to make impossible for detection of the criminal origin of the funds. This is done through a
number of transactions which include investments in various entities, such as companies and trust
funds, various financial assets such as stocks or insurance policy institutions , etc. This phase is
also called masking.

(3) Integration, this stage involves the pumping of the criminal proceeds into the economy undetected
in order to be converted into goods of value. This stage is also refer to as the washing machine
because it is where the income is cleaned and further transferred into legal economic activities.
The criminals are simply left to create the illustration of wealth in society which reflects
legitimate earnings through their businesses and purchases of many expensive vehicles and
luxurious houses.

It is noticed that in the first phase the money circulates closely around the origin at the location where
the illicit economic activity is conducted. While the second stage of the laundering process is the

34
Walker, J. (1999). ‘How Big is Global Money Laundering?’.Journal of Money, Laundering Control, Vol. 3, No. 1
17
isolation of the proceed through moving them abroad preferably to a location with a large economic
market. Specifically at this specific phase of the process the illicit proceeds are distributed in to
several different banks all over the world, for the purpose of ensuring there are no clues left behind
regarding the origins of the funds.

2.8 METHODS OF MONEY LAUNDERING

There exists various ways of which criminals and corporations unitise to clean their illicit funds, some
of the many channels used are the following;

1) Direct retail business is one way of which money launders launder their money through the use
of such retail businesses as mere appearances where published sales are fabricated to appear as
true35. The proprietors of these businesses use such retail establishments in order to convert the
illegality of them into legally obtained proceeds of the business. While fully complying with all
statutory obligations of the retail business in itself in filing the relevant taxes.

2) Non Profit organisations and events, are also one of the mostly used methods of laundering
illicitly obtained proceeds. This method is done through fraudulent donations towards the charity
and fraudulent ticket sales during charity fundraising events36.

3) Gambling, this includes activities such as lottery and several other gambling games which involve
direct cash transactions. One example of how launders open lottery business with the sale of many
tickets and a grand prize, once the winner is picked they award the winner the prize money
through the illegitimate monies while the also launder their money back to them through ticket
sales. Another example of gambling is Sport betting, where the illicit proceeds are legitimised
through ticket sales.

4) Gambling Establishments, this is another manner in which criminals use in legitimising their
illicit funds in the investment of such monies into bodily structures where people come to
gamble.37 The laundering in this methods takes place trough the construction and the illusion of
wins in the casino.

35
Nugue, J. E. (1990). Crafts: Methodological Guide to the Collection of Data on
Crafts. UNESCO.
36
Laundering money through charity organizations.
37
Horridge, Kevin. “How Money Laundering Really Works. Casino.org Blog, 4 Oct. 2017,
www.casino.org/blog/how-money-laundering-really-works/.
18
5) Real estate, this form of money laundering is done through the purchase various low valued
estates at absorbent prices as a form of legitimising the illicit proceeds. The higher the higher
inflated the purchase price the larger the money laundered.

6) Stock Exchanges, The conversion of income of assets into capital or vice versa is another method
highly unitised in the laundering of illicit proceeds. This is the capitalisation of exchange markets
with the dependency on the fluctuation of share values, the parties in the maker make back or
loss their money either way laundering their illicit money into levitate proceeds.

7) Insurance corporations are also infamously utilised by criminals to laundering their criminal
earnings. This is more specifically done through they launders investing their illicit funds into
exorbitant insurance policies following the payment of the first few premiums filing for early
encasement of their policy38. The money is passed as legitimate on receiving of the payout.

2.9 CRUCIAL COMPONENTS OF THE CRIME OF MONEY LAUNDERING

In order for the successful prosecution of the criminal act of money laundering it is of immense
importance that the criminal component of the crime is clearly identified. This driving us to the
components of the direct intention of the criminal of doing to conceal illicit proceeds, this is in other
words known as the mens rea39. On the other hand the aspect of the Actus Reus, refers to the direct
knowledge of the criminal acts of concealing the illicit proceeds. Both the components directly fall
under the act of legitimising illegally obtained funds as an attempt of legally introducing those funds
into the economy legally. Moreover the use of the illicit funds in procuring assets such properties
and vehicles also amounts to Actus Reus. The intent of the criminal act is also fulfilled through the
act of concealing the origin of such proceeds.
This study accordingly recognises the criminal act of money laundering consisting of two elements
one of which includes the possession, concealing and importing into these nations any effects
acquired from criminal activities. The affirmation assembled during this inquiry proves that the
misdemeanour of money laundering incorporates the continued possession of earnings of crime and
use of such earning with the knowledge that such earnings have been obtained from illicit criminal
activities. The interpretation above establishes five offences prosecutable criminal offences under
money laundering.

38
Atty. Dennis B. Funa. “Money Laundering in the Insurance Industry. BusinessMirror, 3 May 2016,
businessmirror.com.ph/2016/05/03/money-laundering-in-the-insurance-industry/.
39
Mens rea of money laundering
19
2.10 FRAMEWORK OF THE ANTI - MONEY LAUNDERING STRUCTURES
IN ZAMBIA
The fight against money laundering Zambia and around the world is important to protect our citizens
and to ensure the integrity of financial institutions and national Security. Strong and effective Anti-
Money Laundering framework promote financial integrity by making it difficult to conceal illegal
activities. Below is the outline of the Zambian AML framework.

2.10.1 ANTI MONEY LAUNDERING INSTITUTIONAL FRAMEWORK

2.10.1.1 Anti-Money Laundering Authority ( AMLA)

This is the AML Policy making body established under Section 3 of the Prohibition and Prevention
of Money Laundering Act40. The Anti money laundering Authority is constituted by a number of
selective bodies consisting of the Attorney General, Governor-Bank of Zambia (BOZ), the
Commissioner General of the Zambia Revenue Authority (ZRA), the Inspector General of Police, the
Commissioner-Drug Enforcement Commission (DEC), the Director General-Anti Corruption
Commission (ACC). The institution is vested with the mandate to provide policy directives and advise
Government on measures required to prevent and detect money laundering in Zambia.

2.10.1.2 THE DRUG ENFORCEMENT COMMISSION OF ZAMBIA (DEC)

Another instrumental player Introduced by the Zambian Law in the fight against money laundering
is the Drug enforcement commission which sits under the same commissioner as the Anti Money
Laundering Unit. This institution was established through the tight connection between money
laundering and drug trafficking within the country. DEC was created with the decree of effectively
putting a stop to illegal production, trafficking and abuse of narcotic drugs and psychotropic
substances41. Furthermore the commission is also vested with the powers to investigate any complaint
of alleged breach of the Act42 in addition to mandated to provide rehabilitation services to victims of
drug abuse as part of the contribution towards social economic development. The Drug Enforcement
Commission also advices the Government and its statutory bodies/corporations on ways of curbing
illicit activities in relation to drugs abuse providing course of action to reduce prohibited activities43.

40
No 14 of 2001, amended Act, No. 44 of 2010.
41
Section 22 of the Prohibition and Prevention of Money Laundering Act, 2001.
42
Section 5 of the Prohibition and Prevention of Money Laundering Act, 2001.
43
Ibid
20
2.10.1.3 THE OFFICE OF THE AUDITOR GENERAL OF ZAMBIA
This statutory office established under law is the supreme audit institution of the land vested by law
with the charge of accounting for all public funds belonging to Government in ensuring that they are
used for their allocated purposes, revealing misappropriation and theft in the public sector. The
functions of the Auditor Generals Office among to audit all public expenditures is to investigate the
public sector of the effective use of tax payers money and favourable service delivery. The functions
of this office in addition includes to audit and report illogical use of public funds 44 , reproduce
misappropriation of the public funds, restore public confidence that the tax paid is being used for the
intended purpose45 and create certainty lability and compliance by public institutions46.

2.10.1.4 Task Force of Senior Officials on AML matters

The Zambia Government is cognisant about the importance of coordination among key stakeholders
for the effective functioning of the anti many laundering system. For this reason, Cabinet Office set
up the National Task Force of Senior Officials on AML. The overall mandate of the National Task
Force of Senior Officials is to coordinate AML matters among key stakeholders with a view to
improving the effectiveness of existing policies to combat money laundering, financing of terrorism
and other serious offences.

2.10.1.5 The Financial Intelligence Centre (‘the Centre’)

The Financial Intelligence Centre was established to be the sole designated agency responsible for
the receipt, requesting, analysing and disseminating of the disclosure of suspicious transaction reports
to Law Enforcement Agencies (LEAs) and other foreign designated authorities pursuant to the
Financial Intelligence Centre Act 47 . The establishment of the Financial Intelligence Centre was
brought into existence during Zambia’s interaction with the international Community on Money
laundering especially the Egmont Group of Financial Intelligence unit48. The Group provides a forum
for Financial Intelligence Units around the world to improve cooperation in the elimination of the
global vice of money laundering with the purpose of improving co-operation and foster the
implementation of domestic projects against money laundering. The functions of the Financial
Intelligence Centre. is provided in the a requesting, analysing and dissemination of the disclosure of
Suspicious Transaction Reports including information from any suspicious entity or individual . In
addition, the Centre is mandated to analyse and evaluate suspicious transaction classified. The centre

44
Section 9 of the Public Audit Act, Chapter 378 of the Laws of Zambia
45
Section 4 of the Public Audit Act, Chapter 378 of the Laws of Zambia
46
Section 3(a) of the Public Audit Act, Chapter 378 of the Laws of Zambia
47
No 46 of 2010
48
Group was formed in 1995 in Brussels, Belgium as one of the largest international network against money
laundering.
21
is entrusted with the function of facilitating collaboration agreements with foreign assigned
authorities in putting an end to money laundering. Other than that the Centre is allowed under the Act
to perform such other functions as are necessary to give effect to the Act.

2.10.1.6 Law Enforcement Agency (LEAs)

The Financial Intelligence Centre Act vests the following as Law enforcement Agencies with the
mandated of contributing towards the irradiation and control of illicit financial crimes of money
laundering in Zambia49, which include the following;
i. The Zambia Police Force, established under the Constitution;
ii. The Zambia Security Intelligence Service50
iii. The Immigration Department51
iv. The Drug Enforcement Commission52
v. The Anti-Money Laundering Investigations Unit53
vi. The Anti-Corruption Commission54
vii. The Zambia Revenue Authority55
viii. Any other Investigative Institution that the Minister may, by statutory Instrument designate.

2.10.1.7 Supervisory Authorities

The Financial Intelligence Act establishes the Supervisory powers as:-
1. The Governor of the Bank of Zambia, appointed under the Bank of Zambia Act;
2. The Registrar of Co-operatives, appointed under the Co-operatives Act, 1998;
3. The Registrar of Pensions and Insurance, appointed under the Pension Scheme Regulation
Act, 1996;
4. The Commissioner under the Securities Act;
5. The Registrar appointed under the Patents and Companies Registration Agency Act, 2010;
6. The Commissioner of Lands;
7. The Zambia Development Agency, established under the Zambia Development Agency Act,
2006;
8. The Licensing Committee, established under the Tourism and Hospitality Act, 2007;
9. The Registrar of Estate Agents appointed under the Estate Agents Act, 2001;

49
Section 2 of the Financial Intelligence Centre Act
50
Zambia Security Intelligence Act
51
Immigration and Deportation Act, 2010
52
Narcotic Drugs and Psychotropic Subsistence Act;
53
Prohibition and Prevention of Money Laundering Act, 2001
54
Anti-Corruption Act, 2010
55
Zambia Revenue Authority Act
22
 10. The Law Association of Zambia, established under the Law Association of Zambia Act;
11. The Zambia Institute of Chartered Accountants established under the Accountants Act, 2008

2.10.1.8 Reporting Entities

Reporting entities are institutions regulated by Supervisory Authorities and are required to draw up
suspicious transaction reports concerning Money Laundering, Terrorist Financing and any other
serious offences to the Financial Intelligence Centre.
Among other things, reporting bodies consist of the following:
(1) Financial institutions such as Banks and Non - Financial Institutions e.g. micro finance firms
(2) non-financial businesses (NGOs)
(3) Casinos, estate agents, Accountants & Legal Practitioners
(4) National Prosecution Authority

2.10.1.9 Judiciary of Zambia

The Judiciary is considered to be a relevant stakeholder on AML/CFT related issues as it provides
efficacy to the process by being an impartial arbiter in proceedings. All prosecuted cases and claims
for forfeiture must come before the courts of law.

2.10.1.10 Others Relevant Government Agencies

The Office of the Auditor General, Ministry of Home Affairs, Ministry of Mines, Ministry of
Defence, Zambia Air Force, and Registrar of Societies among others are considered very critical for
the provision of intelligence Information on Money Laundering, Terrorist Financing and other serious
offences.

2.11 INSTITUTIONAL FRAMEWORK OF THE ANTI - MONEY

LAUNDERING STRUCTURES IN MOZAMBIQUE

Mozambique has a significant number of laws regulating requirements of international anti-money

laundering and corruption agreements, there are significant shortfalls in the observance and
compliance in some the anti money laundering laws as this is attributed to a lack of capacity in tight
accounts, restricted workforce, corruption in the judiciary itself and insufficient separations of powers
practices in especially the judiciary.

23
2.11.1 Domestic legal framework
Mozambique’s domestic anti-corruption and money laundering legislation has seen significant
betterment from the introduction of country’s first governmental Anti-Corruption package (PLAC)
regulating illicit acts of money laundering which saw its creation by legislature in 2012. As of then,
the legislature has passed public ethics law, the witness, whistleblower and victim protection law and
significantly amended the criminal code.

2.11.1.1 Anti-corruption law

This anti-corruption law56 of Mozambique were introduced in 2004 in charge of the stopping and
criminalising acts of corruption. As a part of the 2012 Anti Money Laundering package through the
office of the Public Prosecutions was mandated with the control of the Public prosecution to
investigate and prosecute corruption of money laundering57.

2.11.1.2 Penal Code

On top of the anti-corruption regulations, the Mozambican penal code58 which came into effect on
July 2015, strengthens the criminalisation of acts such as bribery, graft, embezzlement,
misappropriation of state funds and assets, criminal enrichment, influence-trading and fraud.

2.11.1.3 Public Probity law

The public probity law59 came into force in October 2012 and incorporates all government officials,
including the Presidentially elected and appointed personals. Although does not, Blanket members of
the judiciary. The law establishes a set of set regulatory conditions that come with the public office;
for example, public officials are embargoed from receiving payments for any ministerial
responsibility or decision making which personally work to their advantage. Furthermore the act
make it a criminal offence to use confidential government intelligence for ones private gain. The
Public Probity also forbids the receiving of payments from numerous institutions or companies60.

2.11.1.4 Political funding

Concerning political funding, the law provides regulations applicable to both public and private
Sector contributions. Political parties are often awarded constant state funding for their management
and operation plus additional financial assistance for campaigning prior to elections. In addition, they

56
Anti - corruption Act of Mozambique (Law no. 6/2004)
57
Bertelsmann Stiftung. 2016. Mozambique Country Report. http://www.bti- project.org/en/reports/country-
reports/detail/itc/moz/ity/2016/itr/esa/
58
Mozambican penal code (Law 35/2014)
59
Public Probity Act of Mozambique (Law no. 16/2012)
60
Article 25 of the Public Probity Act of Mozambique (Law no.16/2012)

24
receive in-kind donations from the state in the form of free airtime and free use of public premises
during the campaign61.

2.12 LEGAL AND INSTITUTIONAL FRAMEWORKS AGAINST MONEY

LAUNDERING IN MOZAMBIQUE

There are several institutions responsible for the prevention, detection and curbing of Money
laundering in Mozambique. However, researcher have pointed to the fact that, in spite of recent
improvements, corruption and money laundering related felonies still largely occur unpunished62,
most especially crimes involving senior ranking government officials. Law enforcement bodies and
anti money laundering bodies in the country further need more self rule, along with adequate human
and financial resources and minimum political interference in order to effectively put an end to
corruption. All inclusive, being institutions accountable for enforcing the law are not independent this
lessens greatly the effectiveness of anti-money laundering Laws.

2.12.1 Central Office for Combating Corruption (Gabinete Central de Combate à Corrupção,
GCCC)
The Central Office for Combating Corruption (GCCC) was established within the Attorney General's
Office in 2005, replacing the anti- corruption unit created in 2003. The agency is responsible for
awareness-raising activities and for investigating corruption-related complaints ex officio or based
on information from the public. The agency does not, however, have the mandate to prosecute
corruption, and cases have to be referred to the public prosecutor’s office.

As part of the anti-corruption package in 2012 new powers were given to the office (Freedom House
2016). In addition to its preventive and investigative mandate, the office now also has a coordinating
function, as it is responsible for gathering all the intelligence and information on corruption-related
cases investigated by other government bodies. Its institutional structure was also extended to the
provincial level through the establishment of provincial offices for combatting corruption.

61
International IDEA. 2013. Regulating Political Party Funding: Some Insights from the Praxis.
http://www.idea.int/publications/catalogue/regulating-political-party-financing-some-insights- praxis?lang=en
62
Freedom House. 2016. Mozambique. Freedom in the World 2016. https://freedomhouse.org/report/freedom-
world/2016/mozambique
25
2.12.2 Prosecutor General’s Office (Procurador- General da República)
The Prosecutor General’s Office plays an important role in the fight against corruption. In addition
to following up on the investigations of the GCCC and conducting its own, since 2013 the office has
also been tasked with receiving and overseeing asset declarations submitted by senior public officials.

2.12.3 Judiciary of Mozambique

The judiciary of Mozambique is composed of the Supreme Court, which hears all appeals and ranks
at the apex for all courts. The provincial and district courts follow after under the Supreme Court.
The Mozambican judicial system further comprises of specialised courts such as administrative,
customs, fiscal, maritime, and labor courts. Moreover the lower ranking courts of the judicial
system is further is made of the local customary courts, which deal with estate, divorce, and other
social and family matters. In the year 1990 an amendment to Mozambican constitution was enacted
establishing an independent judiciary.

2.12.4 Central Public Ethics Commission (GCCC)

Created by the Law on Public Probity, the central commission coordinates the work carried out by
local public ethics commissions. It is mandated to establish norms, procedures and mechanisms, to
avoid or prevent potential conflicts of interest. It is made up of nine members, elected for a three-year
term with the possibility of re-election for one additional term. There are also 77 sectoral commissions
spread around the country, which report to the GCCC.

2.12.5 Reception and Verification Committee (RVC)

Public Probity Law established the responsibility of the Public Prosecutors of Mozambique to
evaluate, verify and investigate issues arising from asset disclosures of public officials63. A committee
was established within the Prosecutor General’s Office to coordinate from the capital city of Maputo,
and to receive, verify and investigate asset disclosures from Maputo. There are in total 12 provincial
committees (including the committee in Maputo), with five members each. There is a representative
from the PGR in each of the provincial committees.

2.12.6 Financial Intelligence Unit of Mozambique

Locally this institution is abbreviated as GIFIM in the Portuguese language, established in 2008 to
collect, consolidate, scrutinise and promulgate information to law enforcement agencies on potential
cases of money laundering. It is staffed with 18 people, eight of whom are operational. The GIFIM
is responsible for investigating suspect or illicit financial transactions. Before Financial Intelligence
came into operational existence, the attorney general’s office was responsible for handling

63
Article 63 of the Law on Public Probity Act of Mozambique
26
investigations related to money laundering. In 2011, the government created a multi-sector task force,
chaired by the Ministry of Finance and comprising the ministries of justice, interior, the attorney
general’s office, the central bank and Financial Intelligence Unit.

2.13 CONCLUSION
This Chapter has dismantled the concept of money laundering from its many angles, explaining the
vexation of the growingly large rates of money laundering and the immediate need to combat the
further spread of this vice. Furthermore the Chapter provides a brief history on the origin of the vice
and an outlook of the magnitude of the establishment of such illicit activities in both jurisdictions.
From the research is evidently visible that the present of this vice is largely present in both
jurisdictions in several sectors. Money laundering has illustrated itself in many forms as visible in its
manifestation in various form in the jurisdiction of Mozambique, involving the misappropriation of
donor state funds. Other than that, the study has shown that money laundering fuels several other
activities criminal activities such as drug trafficking, poaching of endangered animals, tax evasion,
illegal arms dealing, illegal dealing of minerals, and piracy on the high sea. All above deliberations
on the ramifications of money laundering makes clear the importance of nations creating tough laws
to aid in the local and international elimination of money laundering.

It has been observed that Zambia including Mozambique have many institutions in place for
combating money laundering within their boarders. The Anti Money Laundering Investigations Unit
in Zamia is the primary institution in the complete destruction of money laundering in Zambia.
Further to which the enactment of a laws personally and directly targeting at combatting this vice was
a major for Zambia towards the fight against money laundering. The Drug Enforcement Commission
is yet another agency created in Zambia with a view to effectively combat the scourge of money
laundering through drug trafficking. The Financial intelligence Centre came about as brainchild of
the international Egmont convention which demands member states to form financial intelligence
units.

The study among other things also visited the legislative Anti money laundering institutions of the
jurisdiction of Mozambique, Which constituted the Central Office for Combating Corruption
established within the Attorney General, Prosecutor General’s Office, The judicial authors of the
country, Central Public Ethics Commission, Reception and Verification Committee established under
Public Probity act and the Financial Intelligence unit. There is no doubt that these institutions play
key role in the fight against all forms of money laundering activities particularly by those entrusted
with the administration of public funds. As evident from the above the mozambican jurisdiction does
not have as money legislative antimony laundering laws as seen in the jurisdiction of Zambia. But

27
institutions in both jurisdiction subject their functions on integrity in public life, demonstrating the
long desire to combat illicit financial practices by those that breach the law. The study examined the
intensive powers of the Commission and their legislative backing of their functions.

28
CHAPTER 3: METHODOLOGY AND DESIGN

3.1 INTRODUCTION
This chapter outlines the prescribed methods utilised in collecting data for this research paper, further
expounding on why these selective methods were used. The paper will in addition break down how
this research was conducted as well as the challenges faced through the investigation. This research
will promptly narrow its concentration on the following elements:

- The identification of anti many laundering laws in existence in Zambia and Mozambique

- The determination of the effectiveness of Anti money laundering laws in Zambia &
Mozambique

- Evaluate the roles Zambian and Mozambican organisations play the war against money
laundering activities.

- Provide recommendations to increase effectiveness of such ineffective anti money laundering

laws in both Zambia and Mozambique.

This Chapter presents the description of the research process. It provides information concerning the
method that was used in undertaking this research as well as a justification for the use of this method.
The Chapter also describes the various stages of the research, which includes the selection of
participants, the data collection process and the process of data analysis. The Chapter also discusses
the role of the researcher in qualitative research in relation to reflexivity. The Chapter ends with a
discussion of validity and reliability in qualitative research and discusses the way in which these two
requirements were met in the current study.

3.2 RESEARCH METHODOLOGY AND APPROACH

The methodology used for data collection in this study is the qualitative research method which
involved participant observation from the selected sample which were deliberately identified to
encompass the law enforcement agencies in Zambia and Mozambique. The rationale under the
qualitative approach is through the in depth understanding of the anti money laundering institutional
organs in charge of the implementation and interpretation of such money anti laundering laws. This
method is considered ideal and most applicable given the sensitivity of anti corruption and money
laundering investigations of a state. This specific method of research focuses in understanding the
research query as a humanistic or idealistic approach. Qualitative method is used to understand

29
people's beliefs, experiences, attitudes, behaviour, and interactions. It generates non-numerical data.
The integration of qualitative research into intervention studies is a research strategy that is gaining
increased attention across disciplines64. In clinical research, qualitative approach can help view the
data more extensively. It strengthens clinical trials by enhancing user involvement in it.Three broad
categories of qualitative research of interest exists in clinical research: Observational studies,
interview studies and documentary/textual analysis of various written records. Qualitative research
gives voice to the participants in the study65. It permits the participants to share their experiences of
the effects of the drug of interest. This can open our eyes to new aspects of the study and help modify
the design of the clinical trial. Qualitative study enhances the involvement of everyone related to the
study. Qualitative research can have a great impact on data collection, its analysis and the
interpretation of results66.

3.3 JUSTIFICATION FOR USING QUALITATIVE RESEARCH

Qualitative research is characterised as a multidimensional research method involving an
interpretative, realistic approach to subject matter 67 . The multidimensional nature of qualitative
research allows researchers to develop a comprehensive image of the phenomenon of ineffective
money laundering in question. The following principles are characterised under qualitative research:
- Qualitative research is holistic; looks at the vast picture and begins with a search for understanding
of the whole.
- Qualitative research looks at the relationships within the anti money laundering systems.
- Qualitative research demands time consuming analysis; as it requires ongoing analysis of the data.
- Qualitative research design requires the researcher to become the research instrument. It also
incorporates room for description of the researcher's own prejudice and ideological preferences.
- Qualitative research design incorporates informed consent decisions and is responsive to ethical
concerns.
Essentially the objective of qualitative research is investigative and illustrative rather than
explanatory 68 . The descriptive nature of qualitative research allows the researcher to provide a
description of the experiences of the participants, which will either sustain or confront the theoretical

64
Gibson G, Timlin A, Curran S, Wattis J. The scope for qualitative methods in research and clinical trials in dementia.
Age Ageing. 2004;33:422–6. [PubMed] [Google Scholar]
65
Ibid
66
Pope C, Mays N. Qualitative Methods in Health and Health Services Research. In: Mays N, Pope N, editors. BMJ.
London: Qualitative Research in Health Care; 1996. [Google Scholar]
67
Denzin and Lincoln (2005)
68
(Ferreirra, Mouton, Puth, Schurink & Schurink, 1998)

30
assumptions on which the study is about. The descriptive nature of qualitative research enables
readers to understand the meaning attached to the experience, the distinct nature of the problem and
the impact of the problem69. Qualitative research was deemed suitable for this research as the purpose
of this study was to explore the reasons for the ineffectiveness of the anti money laundering laws.
The research aim was to explore a particular meaning without presenting the findings as the absolute
truth but as one way in which dual-career marriages are constructed.

3.4 RESEARCH DESIGN

This kind of research takes a formal, objective and systematic approach in the investigation of the
subject matter. The method is one of which often used to describe test relationships and analyse the
cause and effect relationship in gaining more insight in the exploration of the problem of the inherent
phenomenon of illicit money laundering activities. Qualitative reproach is more about with the
features, attributes and characteristics of a phenomenon that can be interpreted thematically. For
example, a claim that pilots demonstrate intelligence that is visual-spatial in nature rather than verbal.
This study therefore, can be referred to as an analytical research because the study is devoted to the
scrutiny and analysis of data to do with money laundering activities in the jurisdiction of Zambia and
Mozambique. Further consisting of the analysis as to why these laws are ineffective in their intended
purposes. The present study undertaken is to critically examine the anti money laundering laws in
both countries of Zambia and Mozambique and established the reason for their ineffectiveness in
controlling the growth and spread of the vice.

3.5 RESEARCH STRATEGY

The three qualitative methods used in this study are participant observation, in-depth interviews,
and focus groups. Each method was used particularly in the obtaining of specific type of data at
different stages of the investigation. Participant observation is appropriate for collecting data on
naturally occurring behaviours in their usual contexts. In-depth interviews are optimal for collecting
data on individuals’ personal histories, perspectives, and experiences, particularly when sensitive
topics are being explored. Focus groups are effective in eliciting data on the cultural norms of a
group and in generating broad overviews of issues of concern to the cultural groups or subgroups
represented. These different qualitative research methods allowed for collection of data and
information for the study.

69
(Meyer, 2001)
31
3.5.1 PARTICIPANT OBSERVATION
This is one of the means of which was used for data collection in the study. It is a widely used
methodology in many disciplines, particularly in sociology, communication studies, and social
psychology. The purpose of this method is to gain a close understanding with a given group of
individuals (in this case were anti money laundering enfoncement agency bodies) and their practices
through the intensive involvement with people in their environment, usually over a specified period
of time. The defined research period means that the researcher was able to obtain more detailed and
accurate information about the the vice of illicit money laundering laws and their ineffectiveness in
their regulation under study. Noticeable details and more other not so noticeable details were more
easily observed and interpreted over a longer period of time70.

3.5.2 IN-DEPTH INTERVIEWS

Another type of data collection method used in this research is the interview, which consisted of
Structured interviews made up of a number of questions that are answered in a particular order. In
this type of interview the order of the questions can be changed depending on the direction of the
interview. This research adopted a semi-structured interview approach. In attempt to also obtain first
hand information directly from reliable informants the research interviewed well informed
anonymous anti money laundering law enforcement agents and partners in financial institutions. A
number of people were interviewed in this study including Financial intelligence officers and bank
managers, members of the judiciary and Zambia Police officers as to the regulations of illicit financial
flows.

3.6 Reliability and Validity

Reliability and Validity are vital theories in investigative reports as they enhance the preciseness
of the analysis of a paper. They consist of a distinct significance under the
form of investigative method used if
either quantitative or qualitative research. Reliability Under quantitative research sets mention to
the consistency, stability and repeatability of the finding are considered reliable if all these
elements are met. The research validity considers the means used in surveys relates to the extent
at which the survey measures right elements that need to be measured. In simple terms, validity
refers to how well an instrument as measures what it is intended to measure. In this case this refers
to reliability as to the measures which needs to be reliable and as well also valid. Research validity

70
DeWalt, K. M., DeWalt, B. R., & Wayland, C. B. (1998). "Participant observation." In H. R. Bernard (Ed.),
Handbook of methods in cultural anthropology. Pp: 259-299. Walnut Creek, CA: AltaMira Press
32
may be split into two groups: internal and external validity. It can be said that “internal validity
refers to how the research findings match reality, while external validity refers to the extend to
which the research findings can be reproduced to other environments”71. The qualitative research,
connect to reliability refers to researcher consistent approach towards different investigations.
Validity refers to when a researcher’s use of certain procedures to check for the accuracy of the
research findings. In order to strengthen the validity of the research data, the researcher applied
the method of surveying. This often involves processes of collecting data through several different
sources: questionnaires, interviews and participant observation. Collecting data through one
method can be doubtful, biased and weak. However, collecting information from a variety of
sources and with a variety of techniques can further verify findings. This study involved the use
of constructive validity to determine whether the reasonings made about the results of the
assessment are significant and serve the purpose of the assessment72.

3.7 Ethical Consideration

Given the importance of ethics in conducting research and the challenges around conducting
research, universities go to great lengths to protect the dignity and safety of research participants73.
Several ethical considerations were taken into account to ensure that the study was conducted in
an appropriate manner. To comply with ethical considerations in conducting research all parties
provided verbal consent to be interviewed and to participate in the research. While it is common
practice to request written consent, its is stated that highly formalised ways of securing consent
should be avoided in favour of encouraging relationships in which ongoing ethical regard for
participants is sustained. Therefore this study verbal consent was deemed appropriate74.

3.8 SUMMARY AND CONCLUSION

This Chapter outlined how the research was conducted, illustrating the process used to select the
participants, the method used to collect data as well as the approach that was used in analysing the
texts. The aim of this study was to understand the large increase in the phenomenon of illicit
financial flows of money laundering despite the existence of anti money laundering laws. The next
Chapter details the motives for the ineffectiveness of these anti money laundering laws in the
respective jurisdictions of Zambia and Mozambique.

71
(Pelissier, 2008, p.12).
72
Garrison, 1994; Moss, 1992; Cronbach & Meehl, 1955).
73
(Silverman, 2009)
74
Silverman (2009)
33
CHAPTER 4; DATA ANALYSIS

4.1 INTRODUCTION
Several cases of money laundering occur and go infected, unpunished or even ignored within both
these jurisdictions due to several elements which influence the ineffectiveness of these legislative
institution exercising their powers. Money laundering by individuals, banks and other financial
entities are serious offences with significant negative consequences for especially Developing
countries alike such as Zambia and Mozambique. Governments have ensured for the implementation
of legislation to curb the growth of the vice of money laundering and illicit financial flows both within
and outside boarders. However the anti money laundering laws are more inadequate than their
intended purpose, this comes as a result of lack of governmental will to prosecute and large scale
corruption among other things. The auditor generals reports have continuously identified the
following weaknesses to the anti money laundering laws effectiveness;
- Vulnerability to foreign direct investment
- Bribery and corruption
- Political interference in the proceedings;
- Lack of political will to prosecute;
- Socio-economic considerations;
- Weak institutional framework;
- Poor record keeping;
- Unbalanced composition of the Anti-Money Laundering Authority (AMLA).
These above listed are the inadequacies in the enforcement of anti money laundering regulation, under
reporting of financial institutions and others. All of the above, contribute to the ineffectiveness of
Anti money laundering laws and institutions. This chapter will divert attention on the reasons for
ineffectiveness of AML framework.

4.2 MOTIVES FOR INEFFECTIVENESS OF AML

4.2.1 Vulnerability of Foreign Direct Investments
This is in reference to developing countries such as Zambia and Mozambique, Such nationals are also
ways in search and welcoming to foreign direct investment to promote their economy and enhance
their development. Although the problem of money laundering arises when investigative measures
are overlooked in the initial stages of receipt of the investment on the origins of the funds. This is one
of the most critical and essential parts of the vetting procedure for foreign direct investments as the

34
foreign direct investment may in certain cases be proceeds of crime been being brought to be
laundered through legitimate investments into that country’s economy. Investors usually disguise FDI
as a means of money laundering as this is evidently seen Mozambique through large real estate
projects and political party funding. The origins of such investment proceeds go largely over looked
in that they are to the nations benefits through infrastructure development and even to the political
party in power’s favour. Such investors often desire to hide there connections with the illicit proceeds
through undocumented channels.
For large sums of money criminals often resort to foreign direct investments as it a cost effective and
safe way of meeting their objective to legitimise their money. This thus leaves anti money laundering
laws in effective as some time when the governing bodies outweigh their odds not acting on money
launders because they are bringing in large scale investment is a simpler and easier option for such
governments to push forward their development agenda.

4.2.2 BRIBERY & CORRUPTION OF KEY PLAYERS IN THE FIGHT AGAINST MONEY
LAUNDERING
The fight against corruption in these two countries has become a frequent monument for the political
profession. Recently, the President o Mozambique acknowledged that corruption exists all sectors of
government, in both the public and private sectors 75 . Central obstacles hampering the promised
progress in the fight against grand corruption are the continued immunity of public officials involved,
the lack of coherent strategic approach, as well as the inability to recover stolen state funds76. In other,
anti money laundering laws appear as ineffective in the sense that most of the senior government
officials who grant such investors permits and all other investor related documentation are easily
bribable because they are able to get away with such crime. Money laundering is then made easier
because the criminals are able to simply pay off senior government officials in effort of laundering
their money peacefully within that jurisdiction. Nonetheless, according to the centre of Public
Integrity of Mozambique (CIP) “careless involvement by political elites in state economic matters
and the severe lack of transparency” is the standard which state bodies have created granting them
conditions in which high-level officials possess a large amounts of discretionary powers77. This is
clearly seen in the recent news involving the chairman of the state-owned corporation Mozambique
Airlines, CEO Jose Viegas, demanded a conditional bribe of US$ 1 million in return for his aid and
influence in the purchase of two aircraft from Brazilian manufacturer Embraer78.

75
Hanlon, J. 2016c. Mozambique News Reports and Clippings: Issue 350. 19 December 2016.
76
Ibid
77
Hanlon, J. 2016c. Mozambique News Reports and Clippings: Issue 350. 19 December 2016.
78
allAfrica. 2016b. Mozambique: Embraer Guilty of Bribing Officials, including in Mozambique. 26 October 2016.

35
On the other end of the border, bribery of influential individuals and witnesses in Zambia for money
laundering purposes is a serious offence, this was established in the case of Bellwood Clinic Limited
v Drug Enforcement Commissioner and Attorney General79. The fact of the case were as follows;
One Lindon Mfungwe set up nine contracting and supplying companies which he jointly
owned with his family. It was established during trial that the said companies were intended
to defraud the government as at one particular moment more than US$250, 000 was deposited
into Mfungwe‟s account on the pretext that his companies has supplied foodstuffs to the
Ministry of Defence when in fact not. In a bid to launder this dirty money, he created more
front companies which became one of the most powerful laundering chains in the history of
Zambia, capable of bribing both financial and non financial institutions to get its way. It was
proved in this line that Mfungwe had bribed officers at the Patents and Companies
Registration Office (then known as PACRO) to help him form front companies registered in
the names of minor children below the age of 10 years as shareholders and directors in breach
of the Companies Act of Zambia.
Such companies included, inter alia, hotels (Capital Hotels Ltd), a financial lending company
(Capital Holdings Ltd) and a clinic (Bellwood Private Clinic) which became the appellant in
this case. On 16 January 2004 Mfungwe transferred an equivalent of US$ 250, 000 from one
of his front companies into Bellwood‟s account and three days later withdrew part of it (US$
6, 250). These transactions raised suspicions leading to Bankers filing Suspicious
Transactions Report (STR) against him which resulted in institution of money laundering
proceedings and the subsequent seizure of Bellwood‟s assets. In his obiter dicta, Judge,
Tamula Kakusa, bemoaned the rampant corrupt practices in both financial non financial
institutions, whereby officers are bribed by launderers to keep quite and not report the crime.
4.2.3 POLITICAL INTERFERENCE IN THE PROCEEDINGS
The involvement in money laundering prosecutions by influential political members is another crucial
issue which critical undermines the anti money laundering legislation and institutions. The
interference of political members occurs in two manners. First of which is the direct political
interference of the accused who holds an influential political position in public which is known as
direct interference. The secondly exists the indirect interference of a public political official indirectly
using their influence to manipulate the out come of the money laundering proceeding. Indirect
political interference is illustrated the 2002 Zambia Case of The People v Katele Kalumba & Others.
The facts of the case were as follows;

79
Bellwood Clinic Limited v Drug Enforcement Commissioner and Attorney General HCZ Appeal No. 169/99.
36
 The case commence in the year 2002 but yet dragging on with repeated adjournments and
bail extensions on the motion of the accused. Through this long process, instrumental
witnesses have since even passed away, incriminating evidence has in addition even lost its
probative value and the public interest in the matter has disappeared80. This form of soft
unfair treatment was towards the accused, a powerful political figure and plentiful funder of
majority of the campaigns in the ruling MMD Party since its beginning; and in addition a
man constantly seemed advice from on all constitutional and high-profiled appointments
including Judges, DPP and Magistrates.

On the other hand, the other case which may provide a clearer picture to the political interference to
the inefficiencies of anti money laundering laws is illustrated in the case of The People v Ryan
Chitoba & Others, the facts of this case were as follows;
In this case the former Anti- Corruption Commission boss, Ryan Chitoba, together with a
team of his subordinates was charged with abuse of public office and fraud as well as money
laundering. It was alleged that on different occasion, they had drawn large sums of money
from the forfeiture account which they successfully laundered into their other business. Their
case was proceeding at a normal rate then suddenly ordered for a special speedy trial even to
the extent that continued trials held on Saturdays outside working time,138 and yet concerned
magistrate had so many cases of remandees in prison whose cases had been dragging for
many years owing to purported excessive workloads. Such an order was unprecedented as
the Zambia law does not allow resuming of court sessions on Saturdays. There was media
frenzy over this matter and it was later discovered that some government leaders had been
pressing for a quick conviction of Ryan Chitoba so as to discredit him from his being the
chief prosecution witness in the on-going corruption and money laundering cases against
them81.

4.2.4 Lack Of Political Will To Prosecute

The indirect lack of political will to prosecute money laundering crimes is one of the worst setbacks
faces within the jurisdictions. The decision to prosecute is vested int the Director Of Public
prosecution which is in theory under the judiciary, although this office in either jurisdiction has
proven to be politically controlled since the Director of Public Prosecution ( DPP) is appointed by the
President in his own personal capacity. This matter has since worsened through the courts seeking
conditional consent of the DPP in any prosecution matter of corrupt money laundering government

80
The People v Katele Kalumba & Others SSP Case filed in 2002.
81
The People v Ryan Chitoba & Others
37
officials. Furthermore the Direct of Public Prosecution is vested with the liberty of applying their full
discretion, in that they are no where legally obligated to disclose their reasons to why they decided to
or not to prosecute a case. The lack of political will to prosecute emerges from the case of Chiluba
London Judgement in 2007 in the London High Court.
This was in a bid facilitate execution of the judgement namely; the forfeiture of the London
- held ZAMTROP account where hefty sums of money stolen from the Zambian treasury
have been hidden. Due to lack of political will a simple process registering the said foreign
judgement has been delayed unnecessarily by the Attorney General‟s office which is the only
office conferred with powers and discretion to do so. Over two and half years have since
lapsed and the government is simply stalling in registering this judgement, with the account
remaining frozen since 2002 when the matter commenced82 The public is now demanding an
explanation in the wake of the blossoming close friendship between Dr Chiluba and President
Rupiah Banda, with 18 civil society groups (NGOs and mother church bodies) under the
representation of Transparency International (Zambian Chapter), organising country-wide
demonstrations and press conferences over these delays, inter alia83.

The lack of political will to prosecute illicit financial flows through money laundering is a clear abuse
of their immunities granted to these senior political officials. Nothing Encourages money laundering
like the abuse of the impunities, which in these jurisdictions politicians are enriching themselves
through illicit means without any chance of facing punishment for breach of the laws.

4.2.5 SOCIO-ECONOMIC FACTORS

The prosecution of large scale foreign investors practicing money laundering in an Either one of these
jurisdictions is from one aspect a rather interesting dispute. Developing nations have and will always
be vulnerable to foreign investment and the development of their economies certain countries even
ague that it is more harmful than good to a developing economy such as Mozambique to prosecute
foreign investors come to invest largely for the purpose of laundering their illicit proceeds84. Several
scholars have actually argued that the prosecution of money laundering offences work more against
the receiving economy than in their favour85.

82
Lusaka Times Newspaper, “Registration of London High Court Judgement Stalls” (Thursday 26 February 2009).
83
Lusaka Times Newspaper, “Don‟t Cause Alarm over FJT‟s London High Court Judgement-Malila” (Thursday 26
February 2009)
84
M. Pieth et al, op cit, 232. See also Sheshu, op cit, 2.
85
.D. Schaap, “Money Laundering: A Prosecutors‟ perspective” in Journal of Money Laundering Control (1999) 3,
127. See also, Fernandez, “Introduction to the Study of Money Laundering”.
38
These factors contain two restrictive circumstance in the prosecution of the illicit financial crimes.
First of which, is the considerable section of the people that are against the prosecutions of money
laundering on the basis that the government has so far spent too much money on hiring private
prosecutors without justification as the proceedings have taken far too long without quantifiable
sentencing. Furthermore, fairly large sections of the nationals in Mozambique perceive money
laundering to be of financial advantage to their economy, as the criminal practitioners through this
illicit practice have jobs for them.

4.2.6 WEAK INSTITUTIONAL FRAMEWORK

Studies have shown that money launderers select their place to launder the money through assessment
of the legislative structure together with the effectiveness of their enforcement and their capacity to
monitor money laundering activities within that country. Criminals will make ultimate use of any
weakness they find within the anti money laundering legislation forming it to their convenience,
specific weaknesses such as poor supervision, lack of adequate Funding to the anti money laundering
institutions and improper communication facilities. This motive is most reflective in the jurisdiction
of Zambia, where it is evident in the number of cases of money laundering involving a number of
countless parties such as police and foreigners, the police and courts, court staff and immigration
office staff majority of the times found in a conflict of interest in relation to some form of money
laundering. This comes as a reflection of the tired institutional framework of money laundering
legislation and institutions in the country.

4.2.7 Poor record keeping

Adequate account of evidence is crucial to the successful prosecution of money laundering offences.
Such evidence of records are essential in the identification and tracking of properly safeguarded
records of forfeited or seized proceeds of crime. Money laundering is a secretive crime thus making
it more important for the authorities to critically preserve evidence properly; keeping proper records86.
The absence of comprehensive evidence as a result of poor record keeping of the money laundering
offence committed almost completely weakens the accused case again them. The unavailability of
inclusive recording keeping of evidence relating to the laundering offence remains a weakness in both
Zambia and Mozambique in attaining successful prosecutions of criminal of such illicit financial
activities.

86
Madinger, op cit, 277
39
4.2.8 Unbalanced composition of the Anti-Money Laundering Authority
The anti money laundering authority set ups a group of top government officials which make the
members of the institution. This formation of the high level officials may ben high beneficial towards
the institution but not for the public or effectiveness of the anti money laundering laws. This is visibly
evident in the hinderance present in the prosecution of equally senior ranking political officials
allegedly involved illicit financial crimes, in case where these political officials equally protect their
colleagues, rending ineffective the prosecution.

4.3 CONCLUSION
In comparing and contrasting the jurisdictions of Zambia and Mozambique, the anti money
laundering systems are almost equally ineffective in sever manners they are highly undermines by
senior political figures in government in the use of their influence and power to get away with such
financial crimes without being answerable to any measure of punishment. One motives of which I
would attribute to this are applicable numbers of flaws weaknesses parts of the anti mow laundering
structures such as the criminal concern of the prosecution. Such would be attributable to a number of
controversial legal and political socio-economic issues. Thus it is clear that the root of the problem
in the inefficiency of anti money laundering crimes is at the stage of the prosecution of the crime; the
wording of statutes should be clear and exact because abstract and ambiguous formulation of words
may cause the statute to be useless and fail to reflect the nature and gravity of the offences involved.
As for the case of anti moony laundering legislation in Zambia and Mozambique.

40
CHAPTER 5: CONCLUSION AND RECOMMENDATION

5.1 INTRODUCTION
The widespread objective of this academic paper was to critically asses the shortfalls of laws created
to control money laundering with the critical focus on Zambia and Mozambique. The study identified
the inadequacies of existing anti money laundering laws in Zambia as well as in Mozambique.
Through the focus on existing laws yet there still being high levels of money laundering; this of which
chapter 4 established the motives of such inefficiencies within their established legislative anti money
laundering institutions. This chapter will provide the reader with a general conclusion and
recommendation to our findings as to the ineffectiveness of anti money laundering laws within both
Zambia and Mozambique.

5.2 GENERAL CONCLUSION

The study is packaged with five Chapters with the first Chapter being the initial part. In the opening
Chapter, the study provides a background on the problems of ineffective money laundering
regulations including the statement of the problem and the objectives of the research. Further, Chapter
One further examines the methodology for research and literature review leading to the concluding
with a summary. Chapter two of the study examines the theories of Money Laundering in Zambia
and Mozambique and at International level. This Chapter, the elements and historical factors such as
the September 11th attacks in America and their links to money laundering. Chapter Three, explores
the established legislative and institutional framework anti money laundering in Zambia and
Mozambique. In this Chapter, we invaluably among others discuss the various statutes and institutions
mandated to combat money laundering in Zambia. Some of the Vital laws examines include the
Prohibition and Prevention of Money Laundering Act and the capital laundering app of Mozambique
including the legislative institutions such as the Anti Money Laundering agency and the Financial
Intelligence unit of both jurisdictions .

Chapter Four of the study examines the motives for the ineffectiveness of these established anti
money laundering Laws. In this Chapter, the study considers factors such as the Vulnerability of
Foreign Direct Investments and political interference in the monitoring of anti money laundering
laws. Lastly, Chapter Five draws a conclusion to the study and follows with a list of recommendations
for better practices for enhancing the effectiveness of money laundering laws in both Zambia and
Mozambique.

41
5.3 RECOMMENDATIONS
Money laundering has become an international outbreak and threat that causes economic havoc at
both national and international level. Therefore, a combination of international cooperation and
domestic legal reforms may mitigate the threat of this epidemic. The study will further prescribe the
following recommendations for the case of Zambia and Mozambique:

(I) The current anti money laundering laws are rather vague and unclear on various material
matters such as the establishment of the offences, aggravating the prosecutorial problems.
Indeed, most of the impediments in the successful prosecution of money laundering in Zambia
are associated with lack of clarity in the statutory law itself. Therefore, it is recommended
that both Zambia and Mozambique consider reviewing their anti money laundering laws to
make them more understandable and effective.
(II) There is need for the anti money laundering regulations to be brought up to speed with more
current international anti money laundering structures of which this may be attained by the
legislature expanding their scope duties of reporting all kinds of businesses and professions
including non-financial institutions and non-compliance to be subjected to the consequence
of compulsory liquidation of their businesses. This recommendation would be more effective
in the fight against money laundering as this is seen in other jurisdictions where governments
have liquidated companies which have transacted with parties who have purchased goods
with the purpose of laundering their money.
(III) The need for the anti money laundering legislative controls to be more vigorous and
responsive towards the constantly changing process of money laundering, this would be to
ensure that the anti money laundering laws do not become outdated and ineffective. This may
be attained by constant emendation of the laws through statutory instruments and directives
from executive ministers in government.
(IV) The introduction of Central Bank curriculums which would adequately account with
money laundering issues such as regulation policies of bank secrecy and constitutional law
concerning customers confidentiality. The recommendation would be on the basis that
financial institutions and their staff should be assess and rewarded on the basis of their
scrutiny to compliance with money laundering provisions of such Central bank regulations.
Further to which the laws should so be revised to incorporate incentives for witness
protection.
(V) The anti money laundering legislative and institutional structure should be made easier to
understand in order to encourage the public to come forward with confidence that they will
be treated with respect. The current composition of the anti money laundering authority may
42
 be seen as intimidating to ordinary individual informers to the extent one would assume that
the ordinary person is totally segregated from reporting illicit financial practices.
(VI) The introduction of conducting regular public debates and forums on which relevant
information to do with anti money laundering may be circulated. Such public forms would
incorporate delicate subjects regarding money laundering such as the recognitions and
consequences of money laundering as well as the reporting procedures of suspicious illicit
financial flows to authorities.
(VII) The jurisdictions of Zambia and Mozambique anti money laundering institutions
should work with other well established jurisdictions in conjointly coaching enforcement
agencies on basic subjects of better anti money laundering controls internationally. Training
such institutions to value the role of the public as providers of information and teammates in
prevention of such financial crimes.
(VIII) These jurisdiction should introduce a regional anti money laundering centre for better
coordination in effective data collection and record-keeping systems in relation to the crime
of money laundering and its dependent offences.
(IX) The severe need for the financial and legislative fortification of fundamental
institutions such as police and the judiciary in ensuring that these are in line with the doctrine
of “The Separation of powers”, free and adequately funded. This recommendation would be
to ensure that these respective institutions are run objectively and fair as possible in tackling
money laundering.
(X) The introduction of a complete listing of all forms of illegal activities that could be considered
to be grounded offences of money laundering crimes. Such listing could be provided within
the anti money laundering legislation.
(XI) Ultimately, it is recommended that both Zambia and Mozambique uphold the
necessary institutional and legislative framework required in the fight against money
laundering by committing sufficient political will, necessary to overcome the ineffectiveness
of these laws observed in this Study. It is vital that these jurisdictions act to include
international best practice within their money laundering regulations in order to stand in
solidarity with the international community in the fight against money laundering.

43
CHAPTER 6: BIBLIOGRAPHY
6.1 ARTICLES
I. “Mozambique Loses Millions of Dollars to Money Laundering.” Edited by Club of Mozambique,
Maputo, Flora De Maputo, 18 Apr. 2017, clubofmozambique.com/news/mozambique-loses-
millions-of-dollars-to-money-laundering/.
II. Horridge, Kevin. “How Money Laundering Really Works. Casino.org Blog, 4 Oct. 2017,
www.casino.org/blog/how-money-laundering-really-works/.
III. International IDEA. 2013. Regulating Political Party Funding: Some Insights from the Praxis.
http://www.idea.int/publications/catalogue/regulating-political-party-financing-some-insights-
praxis?lang=en
IV. Freedom House. 2016. Mozambique. Freedom in the World 2016.
https://freedomhouse.org/report/freedom- world/2016/mozambique
V. Lusaka Times Newspaper, “Registration of London High Court Judgement Stalls” (Thursday 26
February 2009).
VI. Lusaka Times Newspaper, “Don‟t Cause Alarm over FJT‟s London High Court Judgement-
Malila” (Thursday 26 February 2009)

6.2 BOOKS
I. Rodrick Parlour, International Guide on Money Laundering: Law and Practice (London:
Butterworths,1995) 23
II. J. Fisher, Money Laundering Law and Practice, (Oxford: Oxford University Press, 2001) 42-43
III. Rodrick Parlour, International Guide on Money Laundering: Law and Practice (London:
Butterworths,1995)25
IV. Reuter, P. 2017. “Illicit Financial Flows and Governance: The Importance of Disaggregation”.
World Development Report 2017.
V. allAfrica. 2016b. Mozambique: Embraer Guilty of Bribing Officials, including in Mozambique.
VI. D. Schaap, “Money Laundering: A Prosecutors‟ perspective” in Journal of Money Laundering
Control (1999) 3, 127. See also, Fernandez, “Introduction to the Study of Money Laundering”.
VII. Madinger, op cit, 277

6.3 CASES
I. Bellwood Clinic Limited v Drug Enforcement Commissioner and Attorney General HCZ Appeal
No. 169/99.
II. The People v Ryan Chitoba & Others
III. The People v Katele Kalumba & Others SSP Case filed in 2002.

6.4 STATUTES
I. Prohibition and Prevention of Money Laundering Chapter 96 of the Laws of Zambia
II. Capital Laundering Act (Law 14/2013) of Mozambique
III. Prohibition and Prevention of Money Laundering Act No 14 of 2001, amended Act, No. 44 of
2010 of the laws of Zambia.
IV. Prohibition and Prevention of Money Laundering Act, 2001 of the Laws of Zambia.
V. Public Audit Act, Chapter 378 of the Laws of Zambia

44
VI. Financial Intelligence Centre Act of the Laws of Zambia
VII. Zambia Security Intelligence Act
VIII. Immigration and Deportation Act, 2010
IX. Narcotic Drugs and Psychotropic Subsistence Act of The Laws of Zambia
X. Zambia Revenue Authority Act the laws of Zambia
XI. Anti - corruption Act of Mozambique (Law no. 6/2004)
XII. Penal code of the Laws of Mozambique (Law 35/2014)
XIII. Public Probity Act of Mozambique (Law no. 16/2012)

6.5 REPORTS
I. Global Financial Integrity. 2015. “Issues: Illicit Financial Flows”.
II. OECD. 2014. “Illicit Financial Flows from Developing Countries: Measuring OECD
Responses”.
III. Wolf, A. and E. Klein. 2016. “Mozambique: Overview of Corruption and Anti-Corruption”.
IV. US Department of state 2014.
V. Wolf, A. and E. Klein. 2016. “Mozambique: Overview of Corruption and Anti-Corruption”. U4
Expert Answer.
VI. Centro de Integridade Pública and Chr. Michelsen Institute. 2016. “The Costs of Corruption to
the Mozambican Economy: Why It is Important to Fight Corruption in a Climate of Fiscal
Fragility”, CMI Report
VII. Goga, K. 2015. “Addressing Corruption May Act as a Significant Step to Limit Illicit
Financial Flows from Africa”.
VIII. De Renzio, P. and Nuvunga, A. 2016. “Bankrupting Mozambique: From Poster Child to
Cautionary Tale”. African Arguments.
IX. Williams, A. and J. Isaksen. 2016. “Corruption and State-Backed Debts in Mozambique – What
Can External Actors Do?”
X. Global Financial Integrity. 2015. “Issues: Illicit Financial Flows”.
XI. Oxpeckers. 2017. “Mozambique’s Poaching Castles Are Crumbling”.
XII. Walker, J. (1999). ‘How Big is Global Money Laundering?’.Journal of Money, Laundering
Control, Vol. 3, No. 1
XIII. Bertelsmann Stiftung. 2016. Mozambique Country Report. http://www.bti-
project.org/en/reports/country- reports/detail/itc/moz/ity/2016/itr/esa/
XIV. Hanlon, J. 2016c. Mozambique News Reports and Clippings: Issue 350. 19 December 2016.

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