Further to our previous newsflash on the topic Botswana Compliance Update: FATF Grey List, we hereby give a compliance update on Botswana’s current situation and progress as at 7 July 2021 with respect to addressing the strategic technical compliance deficiencies in its AML/CFT regime.
It is to be noted that in an effort to be removed from the FATF grey list, Botswana appeared virtually at a plenary session of the FATF in June 2021 for reassessment of progress made in addressing her AML/CFT technical deficiencies. What follows is the outcome.
How did Botswana acquit herself at the FATF plenary?
To Botswana’s credit, FATF noted that Botswana has ‘substantially completed its action plan and warrants an on-site assessment to verify that the implementation of Botswana’s AML/CFT reforms has begun, is being sustained, and that the necessary political commitment remains in place to sustain implementation in the future’.
The following key reforms were noted. Botswana has developed a comprehensive national AML/CFT strategy and policy informed by national risk assessment results. Further, Botswana has developed risk-based supervision and monitoring programmes; and there is improvement in the dissemination and use of financial intelligence by the Financial Intelligence Agency and other stakeholders to identify and investigate money laundering cases.
Is Botswana still grey listed?
Yes. Botswana remains grey listed. However, as noted above, FATF has undertaken to conduct an on-site visit at the earliest possible date for verification that Botswana’s AML/CFT reforms are implemented and sustained. Should the reforms be verified, Botswana may then be removed from the FATF grey list, which in turn will see Botswana removed from the EU and UK blacklist.
Considering that Ghana recently received FATF on-site visit, and successfully managed to get herself out of the FATF grey list, the expectation is that Botswana will follow suit when the FATF conducts an on-site assessment.