Zambia ZM

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.

Outlook

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.