Zimbabwe should ensure that implementation of the MLPCA
is underway, combat widespread corruption that permeates government and commerce, and take steps to investigate and prosecute money launderers.
Additionally, Zimbabwe should work to ensure that across-the-board implementation of the MLPCA
Although many types of entities are covered under the MLPCA
, know your customer procedures and STR requirements are only applied to banks and foreign exchange dealers actively supervised by the National Reserve Bank of Tonga or the TRA.
The MLPCA requires covered institutions to identify their customers.
Under the MLPCA, covered institutions must report suspicious transactions, including those that may be indicative of terrorist financing, to the Barbados Financial Intelligence Unit (BFIU).
In addition to the MLPCA, the Financial Institutions (Anti-Money Laundering) guidelines of 2000 require financial institutions to establish and maintain specific policies and procedures to guard against the use of the financial system for the purpose of money laundering.
The MLPCA provides for the filing of suspicious transaction reports (STRs) with the new financial intelligence unit (FIU) authorized by the law.
Under Part II, section 12 of the MLPCA, financial institutions or cash dealers must take reasonable measures to determine to their satisfaction the true identity of any applicant seeking to enter into a business relationship.
Under the MLPCA, transaction records must be kept for a period of at least five years from the date the relevant business or transaction was completed.
and the Transnational Crimes Act 2005 criminalize acts of terrorism and terrorist financing.
The Anti-Money Laundering Authority (AMLA) was created to supervise financial institutions' compliance with the MLPCA
. Financial institutions must also report suspicious transactions to the AMLA through the Barbados Financial Intelligence Unit (FIU).
Other entities subject to the provisions of the MLPCA
, such as the three money services businesses, four finance companies and five insurance companies, are essentially unsupervised.