Angola’s Effective Risk Management Model: A Game-Changer in Combating Financial Crime
In an effort to combat money laundering, terrorism financing, and proliferation of weapons of mass destruction, the Angolan government has implemented a robust risk management model. This comprehensive framework ensures that financial institutions and businesses subject to anti-money laundering controls are equipped with the necessary tools to identify and report suspicious activity.
Recordkeeping and Reporting Requirements
Subject entities in Angola must adhere to strict recordkeeping and reporting requirements to prevent financial crime. Key requirements include:
- Reporting all transactions exceeding USD 15,000 or more in physical currency to the UIF
- Reporting wire transfers ordered by individuals without a bank account, valued at USD 5,000 or more, bound for foreign countries
- Mandatory suspicious transaction reporting, regardless of amount
Customer Identification and Due Diligence
Financial institutions and other businesses subject to anti-money laundering requirements must comply with customer identification and due diligence procedures. These include:
- Verifying the identity of natural persons, legal entities, and trusts
- Identifying ultimate beneficiaries
- Obtaining information on business relationships and transactions
- Maintaining continued monitoring of client activities
Special or Enhanced Due Diligence
Enhanced due diligence is required in high-risk situations, such as:
- Distance operations
- Operations involving politically exposed individuals
- Situations that may facilitate anonymity
- Financial institutions must also verify the identity of clients’ representatives and ultimate beneficiaries
Shell Banks Prohibition
Banks and payment service providers are prohibited from establishing correspondent relationships with shell banks, which have no physical presence in their licensed countries and lack effective supervision.
Reporting Suspicious Activity
Subject entities in Angola are obligated to report all suspicious activity connected with money laundering, terrorism financing, proliferation of weapons of mass destruction, or any other criminal offense. This includes:
- Committed, attempted, or ongoing activities that may be linked to these offenses
- Financial institutions and businesses subject to anti-money laundering controls must provide requested information promptly to the UIF, supervisory authorities, and judicial authorities
Information Sharing Mechanisms
Financial institutions and businesses subject to anti-money laundering controls must provide requested information promptly to:
- The UIF
- Supervisory authorities
- Judicial authorities
- While there are no formal mechanisms for sharing information between financial institutions, subject entities are obligated to share information with government authorities.
Beneficial Ownership and Control
Accurate information about beneficial ownership and control of legal entities is crucial in Angola. This information can assist:
- Financial institutions with anti-money laundering customer due diligence responsibilities
- Government authorities in their investigations
- A Central Beneficiary Register does not yet exist in Angola, but it is essential that accurate information be maintained and available to government authorities.
Originators and Beneficiaries Information
Accurate information about originators and beneficiaries must be included in payment orders for funds transfers, as well as in payment instructions to other financial institutions.
In conclusion, Angola’s effective risk management model is a significant step towards combating financial crime. By implementing robust recordkeeping and reporting requirements, customer identification and due diligence procedures, and prohibiting shell banks, the country is better equipped to identify and prevent money laundering, terrorism financing, and proliferation of weapons of mass destruction.