Botswana is racing to plug loopholes in its financial crime laws as the country prepares for a high-stakes international assessment that could once again expose it to the reputational and economic damage associated with the Financial Action Task Force (FATF) grey list.
Finance Minister Ndaba Gaolatlhe told Parliament that Government had tabled the Financial Intelligence (Amendment) Bill, 2026, as part of an urgent legislative overhaul aimed at ensuring Botswana does not backslide on its hard-won progress against money laundering, terrorist financing and proliferation financing.
The warning carries considerable weight for Botswana, which was grey-listed by the FATF in 2018 after being found to have serious deficiencies in its anti-money laundering and counter-terrorist financing regime. The country subsequently exited the FATF grey list in 2021 while it was removed from the European Union blacklist in 2022.
Gaolatlhe revealed that Botswana’s 2017 assessment painted a grim picture: none of the FATF recommendations were rated Compliant, while 23 were rated Non-Compliant and 13 Partially Compliant.
The minister said Botswana has since dramatically improved its position, reaching 98 percent technical compliance with FATF standards by August 2025.
The stakes are particularly high because Botswana is preparing for its 2027 Mutual Evaluation, where authorities will be expected to demonstrate not merely that laws exist, but that they actually work.
“FATF regularly updates its Recommendations to address emerging money laundering, terrorist financing and proliferation financing risks,” Gaolatlhe told Parliament.
Since Botswana’s last mutual evaluation in 2017, FATF has amended 12 recommendations, forcing the country to revisit its laws ahead of the next assessment.
The stakes are particularly high because Botswana is preparing for its 2027 Mutual Evaluation, where authorities will be expected to demonstrate not merely that laws exist, but that they actually work.
Gaolatlhe stressed that passing legislation will not be enough.
“Strengthening our legislation is necessary, but it is not sufficient,” he said, warning that Botswana must demonstrate that its laws and institutions are “effective in practice” and producing tangible results.
The proposed amendments seek to close gaps identified through a national AML/CFT/CPF self-assessment conducted earlier this year.
Among the most significant changes is an attempt to strengthen the operational independence of the Financial Intelligence Agency (FIA) by clarifying the administrative framework governing the appointment, deployment and management of its staff.
The Bill also seeks to strengthen Botswana’s ability to combat proliferation financing, prohibit tipping-off during certain FIA analyses and expand scrutiny beyond suspicious transactions to include suspicious accounts.
Another major change is the redistribution of responsibility for implementing United Nations targeted financial sanctions.
Parliament is also considering amendments to the Proceeds and Instruments of Crime Act and Trust Property Control Act, while amendments to the Counter-Terrorism Act, Precious and Semi-Precious Stones Act and Real Estate Act are being finalised.
Under proposed reforms, the National Sanctions Monitoring Committee created under the proposed Targeted Financial Sanctions Bill will assume responsibility for implementing and enforcing UN Security Council resolutions relating to targeted financial sanctions, removing overlapping responsibilities from existing structures.
Parliament is also considering amendments to the Proceeds and Instruments of Crime Act and Trust Property Control Act, while amendments to the Counter-Terrorism Act, Precious and Semi-Precious Stones Act and Real Estate Act are being finalised.
The country’s previous grey-listing demonstrated how weaknesses in financial controls can translate into international reputational damage. The latest legislative push is therefore less about routine legal housekeeping and more about protecting Botswana’s standing in the global financial system.
Banks, financial institutions, lawyers, accountants, property professionals, regulators, law enforcement agencies and other gatekeepers will all be expected to detect, report and disrupt illicit financial activity.
