D1 Sanctions
Sanctions is not yet covered for this jurisdiction in this report.
Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.
Zambia's AML/CFT regime rests on the FIC Act and 2017 Companies Act, assessed by ESAAMLG's 2019 MER and follow-up reports (2022, 2024).
Sanctions is not yet covered for this jurisdiction in this report.
Beneficial Ownership is not yet covered for this jurisdiction in this report.
Enabler Jurisdictions is not yet covered for this jurisdiction in this report.
Conflict Finance is not yet covered for this jurisdiction in this report.
Crypto / Digital Assets / Financial Innovation is not yet covered for this jurisdiction in this report.
Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.
The central development in Zambia's AML/CTF Regime domain this cycle is the status of the National Payment System Act, 2026 (Act No. 5 of 2026). The Act was assented to on 31 March 2026 and gazetted on 8 April 2026, but the Zambia Legal Information Institute registry entry marks it Uncommenced, meaning the statute exists in force of law as enacted text but its substantive provisions do not yet bind any obliged entity. Commencement under the Act is left to a ministerial statutory instrument appointing the date on which the Act comes into operation, and no such instrument has been located in the record retrieved this cycle. Until it is made, the National Payment Systems Act, 2007 (Cap. 359) continues to govern payment system supervision in Zambia.
The substantive change the 2026 Act carries, once commenced, is set out in section 5(1)(e), which gives the Bank of Zambia an express statutory function to monitor payment service providers for purposes of anti-money laundering, countering the financing of terrorism and countering proliferation financing. This is a notable architectural shift: the 2007 Act's supervisory focus was oriented to payment-system designation and oversight rather than to an explicit AML/CFT/PF monitoring mandate stated in those terms. The 2026 Act does not merely update the system-designation framework inherited from 2007; it writes a three-pillar monitoring function directly into the Bank of Zambia's statutory remit over payment service providers, a category that spans the payment_company and broader cross-sector obliged-entity population. Read architecture-over-incident, this is more analytically significant than any single enforcement action would be, because it changes what the supervisor is empowered to do across an entire class of regulated entities, rather than addressing one instance of non-compliance.
The practical effect of the uncommenced status, however, is that this expanded mandate is not yet operative. A payment service provider in Zambia today remains subject to the narrower 2007 framework. This is a case where the gap between legislative enactment and legal effect is itself the finding: the statute book shows an AML/CFT/PF monitoring function that does not yet exist in applied supervisory practice. Readers should not treat the gazette date of 8 April 2026 as the date from which the expanded monitoring function applies; the Act's own text requires a separate ministerial act of commencement, and the record does not establish that this has occurred or been scheduled.
Alongside this legislative development, the regime's broader trajectory continues along lines recorded in prior assessment cycles. Follow-up reporting conducted under the Eastern and Southern Africa Anti-Money Laundering Group framework records that Zambia has been re-rated toward Largely Compliant or Compliant status on a number of FATF Recommendations relevant to the AML/CTF regime, including Recommendations 10, 16 and 22, measured against the baseline set by its 2019 mutual evaluation. The FATF country-level page corroborates a general narrative of progress in addressing previously identified technical-compliance deficiencies, though no new FATF plenary action specific to Zambia — such as a change in grey-list or other list status — was identified this cycle; Zambia continues to sit outside both FATF public lists.
A further development bearing on the domestic risk-understanding infrastructure that underpins the AML/CTF regime is the publication, recorded by the Financial Intelligence Centre, of Zambia's Second National Risk Assessment Report. The record retrieved this cycle establishes the fact of this publication but does not extend to the report's substantive findings, which were not independently retrieved. A National Risk Assessment of this kind is ordinarily the evidentiary basis against which a jurisdiction's AML/CFT/PF supervisory priorities and resource allocation are periodically reset, and its publication is itself a structural marker in the regime's risk-governance cycle, distinct from any single finding it may contain.
Taken together, these three threads — an enacted but uncommenced payments statute carrying an expanded AML/CFT/PF monitoring function, continuing incremental technical-compliance re-ratings under ESAAMLG follow-up, and the periodic refresh of the national risk-assessment evidentiary base — describe a regime in a state of prospective formalisation rather than active enforcement escalation. No enforcement action, sanctions designation, or grey-list movement specific to Zambia was identified this cycle. The absence of enforcement activity in a jurisdiction that is simultaneously building out its statutory monitoring architecture is itself worth registering: a regime can be strengthening its legal foundations without yet generating enforcement volume, and the two should not be conflated when reading Zambia's AML/CTF trajectory.
The principal item to track going into subsequent cycles is whether and when a ministerial statutory instrument commences the National Payment System Act, 2026. Until that instrument is made, the Bank of Zambia's express AML/CFT/PF monitoring function over payment service providers under section 5(1)(e) remains a reserved power rather than an operative one, and payment service providers continue to operate under the narrower supervisory framework of the 2007 Act. No commencement date is confirmed by the record as at this cycle, and none should be assumed. Separately, continued ESAAMLG follow-up reporting may in time produce further Recommendation-level re-ratings, and the substantive content of the Second NRA Report, once reviewed, may surface specific typology or sectoral risk findings not yet reflected in this assessment. Both are appropriately treated as pending rather than resolved items.
Commercial Activity is not yet covered for this jurisdiction in this report.
The National Payment System Act, 2026 grants the central bank an express function to monitor payment service providers for AML, CFT and PF purposes, but this remains uncommenced pending a ministerial statutory instrument. Reporting obligations and supervisory expectations for payment service providers in Zambia continue to run under the 2007 Act until commencement occurs.
Compliance functions overseeing payment-sector exposure in Zambia should track the National Payment System Act, 2026 as a pending rather than current obligation; the 2007 Act's narrower framework remains the operative control-framework reference point until the 2026 Act is commenced.
No material change for this persona this cycle
The legislative step represents a structural strengthening of Zambia's supervisory architecture for payment service providers, material to strategic-level jurisdictional risk assessment, though it carries no immediate enforcement implication while uncommenced.
No material change for this persona this cycle
The re-rating trajectory toward Largely Compliant or Compliant on several FATF Recommendations, combined with a legislatively enacted but not-yet-commenced expansion of central-bank monitoring powers, together describe a structural rather than episodic risk trajectory for Zambia this cycle.
No material change for this persona this cycle
Publication of a Second NRA Report marks a periodic refresh point for the evidentiary basis of AML/CFT/PF supervisory priorities in Zambia; audit functions may wish to track when the underlying report content becomes available for review against current control-testing scope.
The Bank of Zambia's expanded AML/CFT/PF monitoring mandate over payment service providers under the National Payment System Act, 2026 is enacted but not yet in force.
A new statutory AML/CFT/PF monitoring function for payment service providers has been enacted in Zambia but awaits a commencement instrument.
No material change this cycle.
Zambia is formalising, but has not yet activated, a broader central-bank AML/CFT/PF supervisory mandate over payment service providers.
No material change this cycle.
Zambia continues incremental FATF Recommendation re-ratings under ESAAMLG follow-up, alongside the pending National Payment System Act AML/CFT/PF mandate.
No material change this cycle.
The Financial Intelligence Centre has published Zambia's Second National Risk Assessment Report.
Illustrative only. The European Union's move from purely national AML supervision toward a hybrid model, in which the Anti-Money Laundering Authority established under Regulation (EU) 2024/1620 assumes direct supervision of a subset of cross-border obliged entities alongside indirect oversight of the remainder, while the directly applicable AML Regulation (Reg 2024/1624) and the per-state transposed sixth AML Directive set the substantive and procedural rules beneath it, illustrates one structural pattern by which supervisory authority can be re-centralised above the national level. A jurisdiction outside this architecture, such as Zambia, is not subject to this specific mechanism, but the pattern is offered here as an architecture-over-incident illustration of how supervisory perimeters can shift when a monitoring function that was once wholly national is reallocated across a different institutional boundary, a dynamic conceptually adjacent to the domestic shift contemplated by the National Payment System Act, 2026 moving monitoring authority from a system-designation focus to an explicit AML/CFT/PF function within a single national supervisor. This is illustrative orientation, not a description of any observed development affecting Zambia, and not a prediction of how Zambia's own architecture will evolve.
Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.
| Tracker | Status | Note |
|---|---|---|
| T1 · Russian Sanctions-Evasion Architecture | no_change | No ZM-specific dark-fleet, tech-procurement or commodity-rerouting signal identified this cycle. |
| T2 · EU AML Package / AMLA | no_change | Not applicable — Zambia is outside the EEA and not bound by AMLR/6AMLD/AMLA. |
| T3 · FATF Grey List | no_change | Zambia continues to sit outside both FATF public lists; ESAAMLG follow-up reporting records re-ratings since the 2019 MER with no new plenary action this cycle. |
| T4 · Beneficial-Ownership Register Status | no_change | No new BO-register development located for Zambia this cycle; standing PACRA-administered register position carried forward. |
| T5 · Crypto & Digital-Asset Integrity | no_change | BoZ's VASP registration directive and its non-licensing clarification both predate this window; no new VASP/crypto development for Zambia located this cycle. |
| T6 · Sanctions Regime Divergence | no_change | Zambia maintains no autonomous sanctions list and implements UN sanctions only; no EU/US/UK listing action specific to Zambia located this cycle. |