Mozambique occupies a strategically important position in Southern Africa's export economy. As one of the continent's largest natural gas producers and a significant exporter of coal, aluminium, and agricultural commodities, Mozambique's financial system is subject to increasing scrutiny from international trade partners, correspondent banks, and EU importers operating under the Carbon Border Adjustment Mechanism (CBAM) and Digital Product Passport (DPP) frameworks.
The country's Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) framework is anchored in Law 14/2013 and administered through the Gabinete de Informação Financeira de Moçambique (GIFiM) — the national Financial Intelligence Unit. Mozambique is a member of ESAAMLG (Eastern and Southern Africa Anti-Money Laundering Group), the FATF-Style Regional Body that conducts mutual evaluations of member states using FATF methodology.
Legal and Regulatory Framework
The primary legislation governing AML/CFT compliance in Mozambique is Law 14/2013 (Lei de Prevenção e Combate ao Branqueamento de Capitais e Financiamento do Terrorismo), enacted on 12 August 2013. This law was supplemented by Decree 66/2014, which introduced detailed implementing regulations covering customer due diligence, record-keeping, suspicious transaction reporting, and internal compliance programme requirements for accountable institutions.
The Bank of Mozambique (Banco de Moçambique — BoM) serves as the primary prudential supervisor for financial institutions and issues sector-specific AML/CFT guidelines. The Insurance Supervisory Institute (ISSM) oversees insurance sector compliance, while the Securities Commission (CVM) supervises capital markets participants.
| Framework Element | Detail |
|---|---|
| Primary AML Law | Law 14/2013 — Lei de Prevenção e Combate ao Branqueamento de Capitais |
| Implementing Regulation | Decree 66/2014 — detailed CDD, STR, and compliance programme requirements |
| Financial Intelligence Unit | GIFiM (Gabinete de Informação Financeira de Moçambique) |
| Banking Supervisor | Bank of Mozambique (Banco de Moçambique — BoM) |
| Insurance Supervisor | ISSM (Instituto de Supervisão de Seguros de Moçambique) |
| Securities Supervisor | CVM (Comissão de Valores Mobiliários) |
| FATF Regional Body | ESAAMLG (Eastern and Southern Africa Anti-Money Laundering Group) |
| Business Registration | CONSERVATÓRIA do Registo das Entidades Legais (CREL) |
| Tax Identification | NUIT (Número Único de Identificação Tributária) — issued by AT (Autoridade Tributária) |
GIFiM: Mozambique's Financial Intelligence Unit
GIFiM was established under Law 14/2013 as Mozambique's central financial intelligence body. Its mandate covers the receipt, analysis, and dissemination of Suspicious Transaction Reports (STRs) and other financial intelligence to law enforcement agencies, prosecutors, and international counterparts through the Egmont Group network.
Accountable institutions are required to submit STRs to GIFiM within a prescribed timeframe when they have reasonable grounds to suspect that a transaction involves proceeds of crime or is connected to terrorist financing. GIFiM also coordinates with the PGR (Procuradoria-Geral da República) — the Attorney General's Office — on money laundering prosecutions and asset recovery proceedings.
Customer Due Diligence Requirements
Under Law 14/2013 and Decree 66/2014, accountable institutions in Mozambique must apply Customer Due Diligence (CDD) measures when establishing business relationships, conducting occasional transactions above prescribed thresholds, or when there is suspicion of money laundering or terrorist financing regardless of transaction value.
| CDD Requirement | Individual Customers | Legal Entity Customers |
|---|---|---|
| Identity Verification | BI (Bilhete de Identidade), Passport, or DIRE (Residence Permit) | CONSERVATÓRIA certificate, Articles of Association, NUIT |
| Address Verification | Utility bill, bank statement, or official correspondence | Registered office address, operational address |
| Beneficial Ownership | N/A (individual is the beneficial owner) | Identify all natural persons holding ≥25% ownership or control |
| Source of Funds | Employment records, business income documentation | Audited financial statements, shareholder loan agreements |
| PEP Screening | Required — Mozambique has elevated PEP risk given public sector size | Screen all directors, UBOs, and authorised signatories |
| Ongoing Monitoring | Transaction monitoring relative to stated purpose | Annual review for high-risk clients; 3-year cycle for standard risk |
Beneficial Ownership Disclosure
Mozambique's beneficial ownership framework requires legal entities to identify and disclose all natural persons who ultimately own or control the entity. The standard threshold for beneficial ownership identification is 25% or more of ownership or voting rights, consistent with FATF Recommendation 24 and ESAAMLG guidance.
Accountable institutions must obtain beneficial ownership information as part of their CDD process and maintain records for a minimum of five years after the termination of the business relationship. Where beneficial ownership cannot be established, institutions must apply enhanced due diligence measures and may be required to decline or terminate the business relationship.
National Identity Infrastructure
| Document Type | Issuing Authority | Use in KYC |
|---|---|---|
| BI (Bilhete de Identidade) | CNARJ (Civil Registry) | Primary national ID for Mozambican citizens |
| Passport | SENAMI (Migration Services) | International travel document; accepted for KYC |
| DIRE (Residence Permit) | SENAMI | For foreign nationals resident in Mozambique |
| NUIT | AT (Autoridade Tributária) | Tax ID — mandatory for all business transactions |
| CONSERVATÓRIA Certificate | CREL | Company registration certificate — primary entity ID |
Supervised Sectors and Accountable Institutions
Law 14/2013 defines a broad range of accountable institutions subject to AML/CFT obligations. The financial sector — supervised by the Bank of Mozambique — carries the most stringent requirements, but the law also extends obligations to designated non-financial businesses and professions (DNFBPs) including real estate agents, lawyers, accountants, and high-value goods dealers.
| Sector | Supervisor | Key Obligations |
|---|---|---|
| Commercial Banks | Bank of Mozambique | Full CDD, EDD for PEPs, STR reporting, transaction monitoring |
| Microfinance Institutions | Bank of Mozambique | Simplified CDD for low-risk accounts; STR reporting |
| Insurance Companies | ISSM | CDD at policy inception, beneficiary verification, STR reporting |
| Securities Dealers / Asset Managers | CVM | CDD, beneficial ownership, source of funds verification |
| Mobile Money Operators | Bank of Mozambique | Tiered KYC based on transaction limits; mKesh, M-Pesa, e-Mola |
| Real Estate Agents | GIFiM / Ministry of Justice | CDD for buyers and sellers; STR for suspicious transactions |
| Lawyers and Notaries | OAM (Bar Association) | CDD when handling client funds or property transactions |
| Accountants and Auditors | OCAM (Accountants Association) | CDD for clients; STR reporting for suspicious activity |
| Casinos and Gaming | Ministry of Tourism | CDD for transactions above MZN 50,000; STR reporting |
Mobile Money and Digital Financial Services
Mozambique has a significant mobile money ecosystem. The three dominant platforms — M-Pesa (Vodacom), mKesh (Mcel/Tmcel), and e-Mola (Movitel) — collectively serve millions of Mozambicans, many of whom are unbanked. The Bank of Mozambique has implemented a tiered KYC framework for mobile money accounts:
| Tier | KYC Requirement | Transaction Limit (Monthly) |
|---|---|---|
| Tier 1 (Basic) | Name and mobile number only | MZN 5,000 (~USD 78) |
| Tier 2 (Standard) | BI or DIRE copy, address | MZN 25,000 (~USD 390) |
| Tier 3 (Enhanced) | Full CDD including source of funds | MZN 100,000+ (~USD 1,560+) |
Export Sector KYC Obligations
Mozambique's export economy is dominated by three sectors with distinct KYC and compliance implications for international trade: natural gas and LNG, coal and mineral extraction, and agricultural commodities. Each sector carries specific due diligence requirements for correspondent banking relationships, trade finance, and EU market access under CBAM and DPP frameworks.
Natural Gas and LNG
Mozambique is home to one of Africa's largest natural gas discoveries, with the Rovuma Basin holding an estimated 100+ trillion cubic feet of recoverable gas. The Coral Sul FLNG project and the Mozambique LNG development (TotalEnergies, ExxonMobil) represent multi-billion dollar export projects. Companies operating in this sector must comply with:
- Enhanced due diligence requirements from correspondent banks due to the high-value, high-risk nature of extractive industry transactions
- EITI (Extractive Industries Transparency Initiative) reporting obligations — Mozambique is an EITI member
- Beneficial ownership disclosure requirements for all entities in the ownership chain
- FATF Recommendation 22 obligations for non-financial businesses involved in high-value transactions
Coal and Mineral Extraction
The Moatize coal basin (Tete Province) is one of the world's largest untapped coal reserves. Vale and Vulcan Resources operate major extraction projects. Mineral exporters face:
- Conflict minerals due diligence requirements for EU importers under the EU Conflict Minerals Regulation
- OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
- Carbon Border Adjustment Mechanism (CBAM) reporting obligations for coal and iron/steel exports to the EU from 2026
- Digital Product Passport (DPP) requirements for mineral traceability as EU battery and electronics regulations expand
Agricultural Commodities
Mozambique exports significant volumes of cashew nuts, sesame, tobacco, cotton, and timber. Agricultural exporters must satisfy:
- EU Deforestation Regulation (EUDR) due diligence for timber and agricultural commodities linked to deforestation risk
- FSMA (Food Safety Modernization Act) requirements for US-bound food exports
- Phytosanitary certification from IIAM (Instituto de Investigação Agrária de Moçambique)
- KYC documentation for trade finance facilities from Mozambican and correspondent banks
ESAAMLG Mutual Evaluation and FATF Status
Mozambique underwent its most recent ESAAMLG mutual evaluation in 2016, with a follow-up progress report in 2019. The evaluation identified technical compliance gaps in beneficial ownership transparency, DNFBP supervision, and international cooperation mechanisms. Mozambique is not currently on the FATF grey list (unlike South Africa, which was grey-listed in October 2023), but ESAAMLG continues to monitor progress against the 40 FATF Recommendations.
For South African exporters and financial institutions dealing with Mozambican counterparties, it is important to note that Mozambique's AML framework, while improving, may not yet meet the full standard expected under FATF Recommendation 10 (Customer Due Diligence) and Recommendation 24 (Beneficial Ownership of Legal Persons). Enhanced due diligence is therefore advisable for high-value cross-border transactions with Mozambican entities.
Three Gates Framework Relevance
For Mozambican businesses seeking to export to the European Union — particularly in natural gas, coal, minerals, and agricultural commodities — the Three Gates Framework provides a structured compliance pathway:
Gate 1: Forensic Entity Anchor
Mozambican exporters must establish a verified entity identity before accessing EU markets. Gate 1 anchors your CONSERVATÓRIA registration, NUIT, and beneficial ownership structure to a SHA-256 Forensic Entity Certificate — the foundation for CBAM reporting (Gate 2) and Digital Product Passport registration (Gate 3).
START GATE 1 — MOZAMBIQUE ENTITY ANCHOR →