AML & CFT Compliance in Zimbabwe: 2025 Guide for Fintechs and Financial Institutions

Anti-money laundering and counter-terrorist financing compliance is becoming a central priority for Zimbabwe’s financial ecosystem. Banks, fintechs, payment providers and DNFBPs now operate under tighter supervision as digital onboarding and mobile-money usage surge.
Regulators expect faster reporting, stronger monitoring and more robust identity verification, which is why many institutions adopt automated AML tools such as VOVE ID to reduce risk and remain compliant.

This guide outlines Zimbabwe’s latest AML/CFT laws, enforcement trends, main risk areas and what organizations must implement in 2025–2026 to meet FIU and RBZ expectations.

Regulatory and Legal Framework

Key legislation

Zimbabwe’s AML regime is primarily based on:

• Money Laundering and Proceeds of Crime Act (Chapter 9:24), amended in 2025
• Bank Use Promotion and Suppression of Money Laundering Act (Chapter 24:24)
• Supplementary regulations addressing targeted sanctions, terrorist financing and reporting formats

The 2025 amendments strengthened oversight of:

• virtual assets and technology-driven services
• beneficial ownership transparency
• inter-agency coordination among FIU, RBZ, ZIMRA and SECZ
• national risk assessment processes

Financial Intelligence Unit (FIU)

The FIU supervises:

• banks
• non-bank FIs
• payment providers and mobile-money operators
• DNFBPs, including real estate agents, car dealerships, lawyers, accountants, trust service providers and precious-stones dealers

It issues binding instructions on:

• cash-transaction reporting (typically USD 10,000+)
• suspicious reporting deadlines (usually within 15 days)
• sanctions and PEP screening
• CDD and enhanced due diligence requirements

RBZ remains responsible for prudential and fintech licensing oversight, while ZIMRA and SECZ supervise sector-specific AML risks.

What AML/CFT Obligations Mean in Practice

Customer due diligence (CDD)

Obligations include:

• verifying identity using accepted documents
• establishing beneficial ownership for companies and trusts
• applying risk scoring
• enhanced due diligence for PEPs and high-risk profiles

Monitoring and detection

Institutions must perform ongoing surveillance to identify unusual activity, such as:

• large or structured mobile-money transfers
• inconsistent transaction patterns
• rapid layering across multiple channels

Reporting

Organizations must submit:

• Suspicious Transaction Reports (STRs)
• Cash Transaction Reports (CTRs)
• cross-border electronic transfer reports where applicable

Sanctions compliance

Institutions are required to screen against:

• UN lists
• relevant regional and global sanctions lists
• local FIU designations

Record keeping

Minimum retention period is 5 years, covering onboarding data, monitoring logs and communication trails.

Recent Enforcement Trends (2024–2025)

Enforcement has accelerated significantly after Zimbabwe exited the FATF grey list in 2022. Regulators shifted from awareness campaigns to direct penalties.

Notable developments:

• 2024: Several banks received administrative penalties ranging USD 10,000–30,000 for outdated sanctions lists, unreviewed alerts and lax CDD refresh cycles. Один из крупных банков получил штраф USD 30,000 именно за систематическое необновление санкционных списков.
• DNFBPs, particularly real estate agencies and car dealerships, faced fines in the USD 2,500–22,000 range.
• December 2024: Exposure of a regional gold-smuggling and laundering network highlighted cross-border vulnerabilities.
• 2025: Enforcement powers expanded. Asset seizure provisions were strengthened, with several high-profile confiscation orders related to procurement fraud and misuse of public funds.
• Regulators identified weaknesses in mobile-money KYC and warned operators about sanctions-evasion patterns linked to virtual assets.

Severe AML breaches can attract escalating penalties where FIU applies multipliers for repeated violations, potentially pushing fines toward USD 500,000 for larger financial institutions.

Major AML/CFT Risk Areas in Zimbabwe

1. Cash-dependent informal economy

A large portion of economic activity occurs outside formal systems, facilitating smuggling, tax evasion and predicate crimes.

2. Illicit trade and corruption

Gold, mineral smuggling and procurement fraud create significant ML exposure.

3. Rapid digital-payments growth

Mobile money and fintech platforms handle high-volume, high-velocity transactions, creating vulnerabilities without automated monitoring.

4. DNFBP exposure

Real estate, car dealerships, precious-stone traders and legal services remain medium-high to high-risk, with low levels of AML awareness in mining and trading sectors.

5. Virtual asset risks

Although RBZ has not issued any VASP licenses to date, unregulated P2P crypto platforms and offshore exchanges are widely used to move funds, obscure transaction trails and bypass sanctions. These remain a key concern in the 2024 National Risk Assessment.

What Fintechs and FIs Must Prioritize in 2025–2026

Build strong CDD and onboarding workflows

• implement biometric verification
• integrate company and beneficial-ownership checks
• apply automated risk scoring for individuals and entities

Enhance monitoring

• deploy behaviour-based analytics
• tune rules for mobile-wallet thresholds
• track rapid or multi-channel layering

Improve sanctions and PEP controls

Real-time list integration is essential for remittances, digital wallets and payment processors.

Strengthen internal governance

• appoint a compliance officer with MLRO responsibilities
• conduct annual training and scenario testing
• update internal policies to reflect 2025 amendments

Prepare early for the 2026 ESAAMLG evaluation

The upcoming evaluation will emphasise effectiveness, not just policies on paper.
Institutions should review STR quality, alert resolution processes and cross-border monitoring capabilities.

Challenges That Remain

• incomplete beneficial ownership data
• low AML awareness in DNFBPs
• limited prosecutions, reducing deterrence
• resource constraints for both institutions and regulators
• added compliance pressure on NGOs under the 2025 PVO Amendment

How VOVE ID Helps Zimbabwean Businesses in Practice

• Instant biometric identity verification with 3D liveness detection and OCR
• Real-time AML screening against global sanctions lists, PEP databases and adverse media sources
• Automated case management and regulatory reporting tools compatible with FIU and goAML standards
• Fully scalable, API-first workflows built for fintechs, payment providers, mobile-money operators and high-risk DNFBPs (real estate, car dealerships, precious-metals traders, lawyers, etc.)

Conclusion

Zimbabwe’s AML/CFT regime is strengthening rapidly, driven by 2025 legal updates, active FIU oversight and increased enforcement across both FIs and DNFBPs. With digital payments expanding and virtual-asset risks rising, compliance in 2025–2026 requires far more automation, real-time screening and consistent monitoring.

Organizations that invest early in modern AML capabilities, such as those offered by VOVE ID, place themselves in a stronger position ahead of the 2026 ESAAMLG evaluation and reduce exposure to escalating penalties and reputational risk.