Transparency International Zambia (TI-Z) welcomes the release of the 2023 Financial Intelligence Centre Trends Report. While TI-Z is currently analysing the specific case studies presented in the report, our overall view thus far is that the 2023 FIC Trends Report shows increased capacity to identify illicit financial transactions in Zambia and therefore provides a good basis for law enforcement agencies (LEAs) to act on those transactions. The increase in the number of Suspicious Transactions Reports (STRs) analysed by the FIC from 155 in 2022 to 15,696 in 2023 and the dissemination of 923 intelligence reports in 2023 as compared to 129 reports in 2022 is a clear turning point in the FIC’s capacity to identify illicit financial transactions and potentially a turning point in combating those transactions if LEAs act decisively in taking action.
According to the 2023 Trends Report, the FIC received and analysed 15,696 STRs in 2023 compared to 155 STRs analysed in 2022, out of 5,745 STRs received. The FIC attributes this significant increase to a special exercise it undertook in the fourth quarter of 2023 aimed at reducing the backlog of STRs and supporting the identification of sectors of high-risk concentration. TI-Z therefore commends this drive as it implies the FIC analysed all the STRs it received in 2023 compared to only 2.7% in 2022 and only 8.4% in 2021. Further, during the period under review, the FIC disseminated a total of 923 reports to LEAs, compared to 129 in 2022, representing a 133 percent increase while the values attributed to the disseminations also increased to K13.58 billion in 2023 from K5.83 billion in 2022.
It is also a notable concern that the abuse of corporate vehicles was a continuing trend in 2023, characterized by the masking of beneficial ownership through various schemes such as usage of
fronts and falsified documents. This is worrying, given that there are limited STRs received from professional enablers or gatekeeper such as law firms and accounting firms. The compliance barometer presented in the report indicates that 82% of accounting firms and 60% of law firms have either partially developed or not developed their compliance programmes, compared to 96% of commercial banks having compliance programmes developed but requiring some improvements.
Further as we noted in our statement following the publication of the 2022 FIC Trends Report, there is need for LEAs to provide comprehensive reports on the status of cases disseminated to them by the FIC. Although the 2023 Trends Report notes that feedback received from LEAs on disseminated reports indicated that the cases were at investigation and prosecution stages, there are no quantitative statistics provided in the report. It is indeed commendable that some of the disseminated cases have led to convictions and non-conviction-based forfeiture of assets. However, the public is interested in evaluating the efficiency of LEAs in taking action on the issues raised in the FIC report through the quantifying of these outcomes.
TI-Z therefore calls upon the FIC to enhance its efforts in improving compliance among professional enablers, as this will increase the scope of illicit financial transaction monitoring. TI-Z further calls on LEAs to whom STRs have been disseminated to provide quantitative reports on the status of any cases arising from those transactions as this will demonstrate their efficacy in dealing with the rising cases of illicit financial transactions in Zambia.
As stated, TI-Z’s analysis of the specific case studies presented in the 2023 report is currently ongoing and we will issue a follow-up statement focusing on those cases once the analysis is completed.
Maurice K. Nyambe (Mr.)
EXECUTIVE DIRECTOR
Progressive analysis. Yes we appreciate the effort and path taken by FIC to be able to identify the illicit transactions. The way forward is to have and efforce laws that will help us apply justice ⚖️ which is balanced to prevent further damage caused by corruption in our country.