Risk Management Model Effective in Identifying and Reporting Suspicious Transactions

The Angolan government has implemented a comprehensive risk management model to prevent money laundering, terrorism financing, and proliferation of weapons of mass destruction. The model requires financial institutions and businesses subject to anti-money laundering controls to report suspicious transactions and maintain accurate records.

Large Currency Transaction Reporting Requirements

Financial institutions are required to report all transactions involving physical currency in excess of USD 15,000 or more, as well as transactions involving the exchange of low-value banknotes for high-value banknotes, different currencies, cheques, traveller’s cheques, or similar instruments. The reports must be filed with the Financial Intelligence Unit (UIF) and maintained for a period of 10 years.

Reports must include detailed information about the transaction, including the date, time, amount, and parties involved
Financial institutions must maintain accurate records of all transactions, including those involving physical currency

Suspicious Transaction Reporting

Financial institutions are required to report all suspicious transactions, regardless of the amount involved, to the UIF. Suspicious transaction reporting can be made through various means, including hard copy documents, email, or other methods specified by the UIF.

Financial institutions must report any transactions that appear unusual or suspicious
Reports must include detailed information about the transaction and the reasons why it is considered suspicious

Customer Identification and Due Diligence Requirements

Financial institutions and businesses subject to anti-money laundering controls must comply with customer identification and due diligence requirements. These requirements include:

Verifying the identity of natural persons, legal entities, trusts, and other legal arrangements
Identifying ultimate beneficiaries and obtaining information on the purpose and nature of business relationships
Conducting ongoing monitoring of business relationships to ensure they are consistent with the knowledge the institution has about the client

Enhanced Due Diligence Requirements

Special or enhanced due diligence requirements apply in certain cases, including:

Transactions involving politically exposed people
Distance operations
Operations involving shell banks
Financial institutions must maintain a continued monitorization of business relationships to ensure they are consistent with the knowledge the institution has about the client

Prohibition on Correspondent Relationships with Shell Banks

Banks and payment service providers are prohibited from establishing correspondent relationships with shell banks, which are banks with no physical presence in the countries where they are licensed and no effective supervision.

The prohibition aims to prevent money laundering and terrorist financing by blocking access to the financial system
Financial institutions must ensure that their correspondent banking relationships do not facilitate illegal activities

Subject entities are obligated to promptly provide information requested by the UIF, supervisory authorities, and judicial authorities. However, there is currently no mechanism facilitating information sharing between financial institutions and other businesses subject to anti-money laundering controls.

The lack of a centralized system for sharing information makes it challenging for authorities to track and prevent illegal activities
There is a need for improved coordination and communication among financial institutions and authorities

Beneficial Ownership and Control Information

There is not yet a Central Beneficiary Register in Angola, which means that accurate information about beneficial ownership and control of legal entities is not yet maintained or available to government authorities.

The lack of transparency around beneficial ownership and control makes it challenging to prevent money laundering and terrorist financing
There is a need for improved transparency and disclosure requirements around beneficial ownership and control.