Angola’s AML/CFT Framework Shows Promise, But Implementation Lags

First-Round Evaluation Highlights Effective Areas, but Persistent Implementation Issues

In its first-round evaluation, Angola’s anti-money laundering (AML) and counter-terrorist financing (CFT) legal framework has been deemed effective in some areas. However, the implementation of these measures remains a significant challenge.

National Policies and Strategies Still Needed

While Angola has made significant strides in understanding money laundering (ML) threats and associated risks, national policies and strategies have yet to be developed and implemented. The lack of consideration for the value of proceeds of crime undermines the relative scale of the proceeds generating predicate offenses.

Financial Information Unit: Autonomy and Operational Independence

The Financial Information Unit (UIF), Angola’s national financial intelligence unit, has been commended for its autonomy and operational independence. However, its capacity to analyze transactions reports from reporting institutions is limited by a lack of data from non-bank financial institutions and designated non-financial businesses and professions (DNFBPs).

Limited Focus on High-Risk Offenses

Angola has only pursued ML cases related to corruption offenses, with little attention given to other high-risk offenses such as:

• Human trafficking
• Drug trafficking
• Environmental crimes
• Fuel theft

The law enforcement agencies have limited understanding and capacity to conduct parallel financial investigations.

Confiscation Procedures: Limited Impact

The country’s policy objective to curb ML through confiscation procedures has been demonstrated mostly in relation to the recovery of proceeds from corruption-related offenses. However, there are no tangible efforts to pursue proceeds from other high-proceed generating offenses.

Lack of Sanctions for Legal Persons and Alternative Measures

To date, Angola has not investigated, prosecuted, or sanctioned any legal persons for ML offenses. Additionally, the country does not implement alternative measures in situations where a conviction cannot be achieved.

Failure to Pursue Restitution of Assets and Detection of Non-Falsely Declared Bulk Cash Transactions

The authorities have also been criticized for failing to demonstrate adequate efforts to pursue the restitution of assets traced and seized in other jurisdictions. Furthermore, Angola does not adequately implement measures for the detection and seizure of non-falsely declared bulk cash transactions.

Positive Developments: Asset Forfeiture Unit and Special Investigative Unit

Despite these challenges, Angola has set up an asset forfeiture unit in the Public Prosecutor’s Office (PGR) and a special investigative unit (SIC) to investigate ML, TF, and other crimes. An on-site visit by international assessors is expected to provide further insight into the country’s AML/CFT framework.

Conclusion

Overall, while Angola has made progress in understanding its ML/TF risks, implementation of policies and procedures remains a significant challenge. The government must prioritize the development and implementation of effective AML/CFT measures to combat financial crime and protect its financial system.