Financial Integrity Monitor

Mozambique MZ

Domains (D1–D6)

Sources

Role actions

Horizon <90d

Jurisdiction profile

CleanTier BRisk: DecreasingMixed

Mozambique's AML/CFT regime is anchored in its Money Laundering and Terrorist Financing Law, supervised by Banco de Moçambique and the national FIU (GIFiM).

<cite index="119-1">Mozambique strengthened the effectiveness of its AML/CFT regime to meet the commitments in its action plan regarding the strategic deficiencies that the FATF identified in October 2022</cite>, resulting in removal from the FATF grey list in October 2025, though capacity gaps persist in BO collection, FIU resourcing, and supervision of extractive and NPO sectors.

Key deficiencies

Nascent beneficial-ownership collection infrastructure for legal persons, only recently operationalised under the FATF action plan
Weak AML/CFT supervision of artisanal gemstone and gold mining sector, a recognised high-proceeds predicate offence
High terrorist-financing risk in Cabo Delgado amid an intensifying ISIS-affiliated insurgency, with immature NPO risk-based oversight
Limited FIU (GIFiM) analytical and human-resource capacity relative to financial intelligence volume

Recent developments (18m)

FATF removed Mozambique from the list of Jurisdictions under Increased Monitoring at the October 2025 Plenary following a successful on-site assessment
European Commission delisted Mozambique from the EU high-risk third country AML list via Delegated Regulation (EU) 2026/83 (4 December 2025)
Swiss Office of the Attorney-General charged Credit Suisse/UBS with money-laundering failures tied to the Mozambique 'tuna bonds' scandal (December 2025)
UK FCA banned two former Credit Suisse bankers, Andrew Pearse and Surjan Singh, for their roles in the tuna-bonds fraud (March 2025)
Former Mozambican Finance Minister Manuel Chang sentenced to a further prison term in the US for bond-fraud bribery (January 2025)
UBS won dismissal of the Swiss money-laundering case tied to the tuna-bond scandal (April 2026)

Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

Mozambique's exit from both the FATF list of jurisdictions under increased monitoring and the EU list of high-risk third countries is now confirmed on primary sources. FATF removed Mozambique from its list at the 24 October 2025 plenary, ending an observation period that began in October 2022, and the EU followed with Commission Delegated Regulation (EU) 2026/83, in force 29 January 2026. Read together with residual ESAAMLG technical-compliance findings, this is a structural improvement in Mozambique's sanctions-adjacent AML architecture, not merely a change of label. The EU and FATF lists moved on different dates and under different instruments, and both should be cited with their own dates rather than treated as a single event.

The improvement is not unqualified. ESAAMLG's latest re-rating exercise continues to rate Mozambique Non-Compliant on Recommendation 8, governing the non-profit sector, even after the grey-list exit. That residual gap sits alongside upgrades on Recommendations 4 and 20 from Partially Compliant to Compliant, indicating uneven technical-compliance progress across the FATF standard rather than a uniform clean bill.

Other Developments

Cabo Delgado conflict finance remains an active and evolving risk. Secondary analysis citing GIFiM and UN Panel of Experts documentation describes over MZN458.6 million, roughly USD7 million, moved between 2017 and 2024 through fragmented deposits and mobile-money layering in support of the Ahlu Sunnah Wal Jama'a insurgency, with emerging kidnap-for-ransom and resource-exploitation financing noted as evolving vectors. This is the clearest counterexample to any reading of the grey-list exit as closing Mozambique's illicit-finance exposure: sanctions-list architecture and conflict-finance risk are separate axes, and this jurisdiction now scores well on the former while remaining exposed on the latter.

A disputed VASP-registration notice leaves the crypto picture genuinely unresolved. Two comparable-standing vendor sources directly contradict each other on whether Banco de Moçambique's Notice 4/GBM/2023, requiring virtual-asset service provider registration, exists and is in force. One source describes a registration requirement; another states plainly that no VASP licensing framework exists at all. Neither source is a primary regulatory text, and Banco de Moçambique's own site was not reached this cycle to resolve the conflict. This is recorded honestly as a dispute rather than resolved in either direction.

Beneficial-ownership registration continues under a closed register. Decree-Law No. 1/2024 requires companies to register beneficial owners with CREL via the E-BAU portal within 90 days of 8 March 2024. The resulting data is held by GIFiM rather than published for public search, and secondary law-firm sources disagree on the applicable ownership threshold, variously cited as 10 percent or greater than 25 percent. The primary Decree-Law text was not retrieved this cycle to resolve the discrepancy.

Mozambique maintains no autonomous sanctions list, implementing United Nations Security Council designations only, with no evidence this cycle of Mozambique-specific EU, US, or UK designation activity.

GIFiM is pursuing full Egmont Group membership, currently holding observer status according to a single official statement reported in local press, not yet independently confirmed against Egmont Group's own membership records.

Cross-Monitor Connections

The FATF and EU delisting has a direct read-across to correspondent-banking access, a theme the World Payments Monitor tracks under its own corridor and settlement lens: reduced enhanced-due-diligence triggers for counterparties dealing with Mozambican banks should, in principle, ease de-risking pressure, though this effect is not yet directly evidenced in bank-level data this cycle. The Cabo Delgado conflict-finance channel is a natural point of contact with conflict-finance and extractive-industry monitoring more broadly, given the insurgency's documented ties to resource-rich Cabo Delgado province and the mobile-money and fragmented-deposit layering techniques described. The disputed VASP-notice question is a live item for any digital-asset or fintech-focused reader tracking Mozambique's regulatory perimeter for crypto activity.

Outlook

The near-term watch item is whether continued ESAAMLG follow-up produces an upgrade on Recommendation 8, which would close the last publicly rated technical-compliance gap tied to the grey-list exit. On the disputed VASP-registration question, resolution would require direct access to Banco de Moçambique's own publications, which was not achieved this cycle. On beneficial ownership, clarification of the actual registration threshold under Decree-Law 1/2024 would materially sharpen the transparency picture, since secondary sources currently conflict by a wide margin, 10 percent versus over 25 percent. The Cabo Delgado conflict-finance channel should be treated as an ongoing, not resolved, exposure notwithstanding the jurisdiction's improved standing-list posture.

weekly_brief_draft · JID MZ

Domain intelligence (D1–D6)

D1 Sanctions Architecture and Evasion

Sanctions Architecture and Evasion

Mozambique's sanctions-architecture standing improved structurally this cycle. FATF removed Mozambique from its list of jurisdictions under increased monitoring at the 24 October 2025 plenary, ending an observation period begun in October 2022. The EU followed with Commission Delegated Regulation (EU) 2026/83, in force 29 January 2026, removing Mozambique from the list of high-risk third countries maintained under Article 9(1) of the EU's anti-money-laundering directive framework. These are two separate instruments moving on two separate dates, and the distinction matters for compliance teams: the FATF call for action and increased-monitoring designations trigger different obligations than the EU high-risk list, and a firm relying on either list for enhanced due diligence should update both references independently rather than treating the delisting as a single event.

With both designations lifted, mandatory enhanced-due-diligence triggers tied specifically to Mozambique's listed status fall away for firms in jurisdictions whose EDD regimes are keyed to the FATF and EU lists respectively. This is a genuine reduction in the sanctions-adjacent compliance burden facing counterparties of Mozambican banks and businesses. However, delisting from a monitoring list is distinct from a finding that underlying money-laundering or terrorist-financing risk in Mozambique has been eliminated; it reflects a judgment that Mozambique's action plan commitments, verified through the FATF and ESAAMLG mutual-evaluation process, have been substantially completed.

Separately, Mozambique maintains no autonomous sanctions list of its own and implements United Nations Security Council designations only. No evidence was found this cycle of Mozambique-specific designation activity by the EU, US, or UK sanctions authorities, and no evidence of a domestic Mozambican sanctions-screening list distinct from the UN framework. This places Mozambique among jurisdictions whose sanctions exposure runs almost entirely through the international UN designation channel rather than through an independent domestic list, a structurally simpler screening picture for counterparties but one that offers no additional domestic layer of designation beyond what the UN Security Council itself publishes.

Outlook

The principal near-term item to watch is whether continued ESAAMLG follow-up monitoring, expected to continue through 2027, produces further technical-compliance upgrades or surfaces new gaps. The residual Non-Compliant rating on Recommendation 8 concerning non-profit organisations sits outside the sanctions-list architecture proper but forms part of the same follow-up process and should be read alongside the delisting rather than in isolation. No further list-status change is anticipated in the near term absent a material reversal in Mozambique's underlying AML/CFT performance.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions

Not covered

Enabler Jurisdictions is not yet covered for this jurisdiction in this report.

D4 Conflict Finance and Extractive-Industry Integrity

Conflict Finance and Extractive-Industry Integrity

Mozambique's conflict-finance exposure through the Cabo Delgado insurgency remains an active and evolving risk, and its trajectory runs in the opposite direction from the jurisdiction's improving sanctions-list standing. Secondary analysis citing GIFiM and UN Panel of Experts documentation describes over MZN458.6 million, approximately USD7 million, moved between 2017 and 2024 in support of the Ahlu Sunnah Wal Jama'a insurgency operating in resource-rich Cabo Delgado province. The financing method described is layering through fragmented deposits and mobile-money channels, a technique that exploits the same agent-based mobile-money infrastructure that has driven financial-inclusion growth in Mozambique more broadly, illustrating the dual-use character of that infrastructure.

The underlying primary sources cited for this figure, GIFiM's own analysis and the UN Panel of Experts report, were not independently retrieved this cycle; the finding rests on T3 secondary reporting that references those primary bodies. Emerging vectors noted alongside the historical deposit-layering pattern include kidnap-for-ransom financing and resource-exploitation financing, both of which would represent an evolution beyond the fragmented-deposit method documented for the 2017-2024 period, though neither is quantified in the evidence available this cycle.

This conflict-finance channel is the clearest illustration in Mozambique's current profile of the gap between formal list-based standing and substantive illicit-finance risk. A jurisdiction can exit the FATF grey list and the EU high-risk list, as Mozambique has, while an active, geographically concentrated terrorist-financing channel continues to operate through domestic payment rails. The two should not be read as offsetting each other: architecture-level list status and episodic conflict-finance activity are separate analytical axes, and Mozambique's current position is improving on one while remaining exposed on the other.

Outlook

The conflict-finance risk in Cabo Delgado should be treated as an ongoing exposure rather than a resolved or historical one, given the emerging kidnap-for-ransom and resource-exploitation vectors noted in the most recent reporting. Direct access to the underlying GIFiM and UN Panel of Experts primary documents would materially strengthen confidence in the precise scale and current trajectory of these flows; that access was not achieved this cycle. Firms with correspondent or payment-processing exposure to Mozambican mobile-money channels, particularly those serving Cabo Delgado and neighbouring provinces, should treat this as a standing typology risk independent of Mozambique's improved sanctions-list standing.

D5 Crypto, Digital Assets, and Financial Innovation

Crypto, Digital Assets, and Financial Innovation

Mozambique's crypto and digital-asset regulatory perimeter is genuinely unresolved this cycle, not merely under-documented. Two comparable-standing vendor sources directly contradict each other on a specific factual question: whether Banco de Moçambique's Notice 4/GBM/2023, said to require registration for virtual-asset service providers, actually exists and is currently in force. One source describes a registration requirement applicable to individuals or legal entities seeking to operate in this space; a second, equally weighted source states plainly that no VASP licensing framework exists in Mozambique at all. Neither source is a primary regulatory publication, and Banco de Moçambique's own website was not directly reached this cycle to adjudicate between the two accounts.

This is recorded as a Disputed finding rather than resolved in either direction, consistent with the honesty-over-coverage principle that governs this brief: an unresolved contradiction between two sources of comparable standing is a more useful signal to a reader than a confident assertion manufactured by picking one side of the dispute. For any firm assessing counterparty risk tied to Mozambican virtual-asset activity, the practical implication is that the existence, scope, and enforceability of any VASP registration obligation cannot currently be confirmed from available secondary sources, and direct outreach to Banco de Moçambique or its published notices is the only route to resolution.

No further crypto-specific development, such as a stablecoin framework, exchange licensing regime, or enforcement action against unregistered virtual-asset activity, was identified for Mozambique this cycle.

Outlook

Resolving the Notice 4/GBM/2023 dispute is the single most consequential open item in Mozambique's financial-innovation picture, since it determines whether a formal VASP registration obligation exists at all. Until Banco de Moçambique's own publications are directly reached and reviewed, this domain should be treated as a watch item with unresolved primary-source verification rather than a settled regulatory position in either direction.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

Mozambique's AML/CTF regime shows genuine but uneven progress this cycle. The exit from the FATF list of jurisdictions under increased monitoring, confirmed at the 24 October 2025 plenary, followed by the EU's removal of Mozambique from its high-risk third-country list under Delegated Regulation (EU) 2026/83 in force 29 January 2026, reflects ESAAMLG-verified technical-compliance improvement sufficient to satisfy the FATF action-plan process. Within that same ESAAMLG re-rating exercise, Recommendations 4 and 20 were upgraded from Partially Compliant to Compliant, evidencing concrete progress on specific technical-compliance measures.

Against that improving trajectory, Recommendation 8, covering the non-profit organisation sector, remains rated Non-Compliant per the latest ESAAMLG re-rating, an outstanding gap that persists notwithstanding the broader grey-list exit. This is a residual and specific weakness, not a general failing, and it should be read precisely: it concerns the adequacy of measures to prevent the non-profit sector's abuse for terrorist-financing purposes, a standard that Mozambique's ESAAMLG assessors have not yet found satisfied.

Mozambique's financial intelligence unit, GIFiM, currently holds observer status at the Egmont Group according to a statement from the Attorney General reported in local press, with an expressed intent to pursue full membership. This single-source claim has not been independently verified against Egmont Group's own membership records this cycle, and should be treated as probable rather than confirmed pending that verification. Full Egmont membership would materially improve GIFiM's capacity for international financial-intelligence exchange, a capability directly relevant to both the sanctions-architecture and conflict-finance domains covered elsewhere in this brief.

Outlook

Continued ESAAMLG follow-up monitoring is expected to continue into 2027, and the key item to watch is whether Recommendation 8 is upgraded, which would close the last publicly identified technical-compliance gap tied to the grey-list exit. Independent confirmation of GIFiM's Egmont Group status, ideally sourced directly from Egmont's own membership records, would also strengthen confidence in Mozambique's institutional AML/CTF capacity assessment.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon

In Force Pending2027 · ±year

Continued ESAAMLG follow-up monitoring of technical-compliance re-ratings

Continued ESAAMLG follow-up reporting obligations for Mozambique notwithstanding grey-list exit.

Source

1 dated · 3 pending date · baseline financial-integrity-2026-07-05

Role action cards

MLRO

Mozambique exited both the FATF grey list and the EU high-risk third-country list, while Cabo Delgado terrorist-financing flows remain active.

Mandatory enhanced-due-diligence triggers tied to Mozambique's prior listed status fall away, but ongoing terrorist-financing typology risk through mobile-money and fragmented-deposit channels linked to the Cabo Delgado insurgency should continue to inform SAR-trigger thresholds for Mozambique-linked activity.

3 evidence refs

Compliance

ESAAMLG re-rating shows uneven technical-compliance progress, with Recommendation 8 on non-profit organisations still Non-Compliant.

Policy frameworks keyed to FATF or EU list status should be updated to reflect Mozambique's delisting, but control frameworks addressing non-profit-sector exposure should not be relaxed given the persisting Recommendation 8 gap.

1 evidence refs

Legal

A disputed VASP-registration notice leaves Mozambique's crypto-asset regulatory perimeter legally unresolved.

Liability exposure for counterparties relying on either the existence or the absence of a VASP registration requirement under Notice 4/GBM/2023 cannot currently be assessed with confidence given the direct contradiction between comparable-standing sources.

1 evidence refs

Board

Mozambique's exit from the FATF and EU high-risk lists is a structural improvement in the jurisdiction's formal AML standing.

This reduces reputational and enhanced-due-diligence overhead associated with Mozambique-linked relationships at the institutional level, though the persisting Cabo Delgado conflict-finance exposure means the underlying illicit-finance risk profile has not fully normalised.

3 evidence refs

CTO

The Notice 4/GBM/2023 VASP-registration dispute has direct implications for any crypto-infrastructure exposure to Mozambique.

Technical architecture decisions premised on either the existence or non-existence of a Mozambican VASP registration regime rest on unverified, contradicting secondary sources; direct verification against Banco de Moçambique's own publications is needed before infrastructure decisions rely on either position.

1 evidence refs

Risk

Mozambique presents a mixed risk profile: improving list-based standing alongside an active, evolving conflict-finance channel.

Exposure concentration to Mozambican mobile-money and correspondent-banking channels should continue to weight the Cabo Delgado conflict-finance typology independently of the jurisdiction's improved FATF and EU list status, since the two risk axes move independently.

4 evidence refs

Operations

No material change for this persona this cycle.

No material change for this persona this cycle

Audit

Beneficial-ownership threshold under Decree-Law 1/2024 is inconsistently reported across secondary sources, and GIFiM's Egmont Group status rests on a single unverified statement.

Control-testing scope for Mozambique-linked beneficial-ownership verification should flag the 10 percent versus greater-than-25-percent threshold discrepancy as an open documentation gap, and GIFiM's stated Egmont observer status should be independently confirmed before being relied upon in audit evidence.

2 evidence refs

Decision lens

MLRO

Mozambique exited both the FATF grey list and the EU high-risk third-country list, while Cabo Delgado terrorist-financing flows remain active.

Compliance

ESAAMLG re-rating shows uneven technical-compliance progress, with Recommendation 8 on non-profit organisations still Non-Compliant.

Legal

A disputed VASP-registration notice leaves Mozambique's crypto-asset regulatory perimeter legally unresolved.

Board

Mozambique's exit from the FATF and EU high-risk lists is a structural improvement in the jurisdiction's formal AML standing.

CTO

The Notice 4/GBM/2023 VASP-registration dispute has direct implications for any crypto-infrastructure exposure to Mozambique.

Risk

Mozambique presents a mixed risk profile: improving list-based standing alongside an active, evolving conflict-finance channel.

Operations

No material change for this persona this cycle.

Audit

Beneficial-ownership threshold under Decree-Law 1/2024 is inconsistently reported across secondary sources, and GIFiM's Egmont Group status rests on a single unverified statement.

Shared evidence: 4 refs

Scenario sketches

AMLA transition and cross-border supervisory reach illustrative sketch

Illustrative orientation only: as the EU's Anti-Money Laundering Authority moves from a design phase toward direct and indirect supervision of cross-border obliged entities under the AMLA Regulation (Reg (EU) 2024/1620), alongside the directly applicable AML Regulation (Reg (EU) 2024/1624) and per-Member-State transposition of the sixth AML Directive, the supervisory perimeter for EU-linked correspondent and payment relationships could tighten in ways that indirectly affect non-EEA counterparties, including banks and payment firms with exposure to jurisdictions such as Mozambique. This is architecture-over-incident framing describing a possible structural mechanism, not an observed development specific to Mozambique this cycle, and not a prediction of how or whether it will manifest.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker	Status	Note
T1 · Russian Sanctions-Evasion Architecture	no_change
T2 · EU AML Package / AMLA	no_change
T3 · FATF Grey List	material_change
T4 · Beneficial-Ownership Register Status	no_change
T5 · Crypto & Digital-Asset Integrity	watch
T6 · Sanctions Regime Divergence	no_change

Registers

Enforcement actions

<cite index="22-2,22-3">Swiss prosecutors charged Credit Suisse with failing to prevent suspected money laundering of suspicious service fees linked to loans the lender offered Mozambique to build a fishing fleet, with Credit Suisse and parent UBS charged with not taking all required and reasonable organizational measures in 2016 to prevent the alleged money laundering.</cite> 1 Dec 2025
<cite index="27-2,27-3,27-4">The UK's financial sector regulator banned two former senior Credit Suisse bankers who pleaded guilty in the US to bribery in the $2 billion bond fraud in Mozambique; Andrew Pearse was banned after admitting wire fraud, money laundering and receiving kickbacks worth over $45 million, and Surjan Singh after admitting money laundering and accepting $5.7 million in unlawful payments.</cite> 4 Mar 2025
<cite index="29-1,29-2,29-3">A former Mozambique finance minister was sentenced to 8.5 years in prison by a US judge for his role in the $2 billion bond fraud, having already spent 72 months in custody, with an additional 30 months ordered and $7 million ordered forfeited — the amount he was paid to guarantee the fraudulent loans.</cite> 17 Jan 2025
<cite index="17-5,17-9">Following a successful on-site visit, the Plenary congratulated Mozambique for positive progress in addressing strategic AML/CFT/CPF deficiencies and removed it from the list of jurisdictions under increased monitoring after completing its Action Plan.</cite> 24 Oct 2025
<cite index="21-1">UBS Group AG won dismissal of a money-laundering case it inherited from its troubled former rival Credit Suisse linked to the so-called Mozambique tuna-bond scandal.</cite> 10 Apr 2026

Sanctions changes

<cite index="61-1,61-3">The EU delisted Mozambique (alongside Burkina Faso, Mali, Nigeria, South Africa and Tanzania) from its list of high-risk third-country AML/CFT jurisdictions, adopted via delegated regulation as the Commission monitors alignment of listed jurisdictions' progress with the FATF.</cite> 4 Dec 2025
<cite index="86-2">Under the UK's revised Money Laundering Regulations, a high-risk third country is now defined by direct reference to the FATF's Jurisdictions under Increased Monitoring and Call for Action lists as they have effect from time to time, rather than a separately maintained Schedule 3ZA list.</cite> Mozambique's removal from the FATF list in October 2025 therefore automatically removed it from UK HRTC enhanced-due-diligence scope. 24 Oct 2025

Regulatory horizon (register)

ESAAMLG post-delisting sustained-implementation follow-up
Exxon Rovuma LNG Final Investment Decision
TotalEnergies Mozambique LNG cost-dispute resolution and restart

Active schemes

[CRITICAL] Hidden-debt 'tuna bonds' sovereign fraud and layering
[HIGH] Cabo Delgado ISIS-affiliated insurgency financing
[HIGH] Illicit ruby, gold and gemstone laundering via corrupt supply chains
[HIGH] State-protected heroin transit corridor with FRELIMO-linked bribery

Sources

Coverage gaps

<cite index="32-6,32-7,32-8">Cabo Delgado has faced terroris…

<cite index="32-6,32-7,32-8">Cabo Delgado has faced terrorist attacks since 2017, displacing over one million people and killing approximately 6,500, and despite ongoing military interventions, attacks continued regularly through 2025</cite>, while NPO-sector TF risk assessment and outreach — a standing FATF action-plan item — remains at an early implementation stage even post-delisting.

<cite index="51-10,51-11">Police and members of the Mozambic…

<cite index="51-10,51-11">Police and members of the Mozambican government have taken to corruption to profit off artisanal miners' desperation, with the problem pervasive across the political elite, local police, customs agents and high-ranking officials taking cuts across the entire gemstone supply chain</cite>, undermining sectoral AML supervision of a recognised high-proceeds predicate offence.

No Mozambique-specific quantitative crypto-laundering or VAS…

No Mozambique-specific quantitative crypto-laundering or VASP-compliance dataset (e.g., a country breakdown from Chainalysis, Elliptic or TRM Labs) was located during this baseline research cycle, despite substantial mobile-money penetration creating an emerging digital-asset ML/TF vector.

<cite index="5-16">Mozambique's action-plan reforms included…

<cite index="5-16">Mozambique's action-plan reforms included providing adequate resources to the authorities to commence the collection of adequate, accurate and up-to-date beneficial ownership information of legal persons</cite> — an item only recently addressed to FATF's satisfaction, meaning registry effectiveness and data-quality maturity remain largely untested at population scale.

Evidence

Confidence-tiered claims

No structured claims published for this jurisdiction yet.