Mozambique AML Obligations for Accountants and Auditors: Law 14/2023

Mozambique's current anti-money laundering framework is Law No. 14/2023 of 28 August 2023, published in the Boletim da República (Series I, No. 166). It sets out the legal regime and measures to prevent and combat money laundering and terrorist financing, and it repealed Law No. 11/2022 of 7 July. This guide explains what the law says about accountants and auditors, using the official text published on the Bank of Mozambique's website. It is written for accountants and finance students who want to see how a Portuguese-language regime compares with the UK and Ireland. For the shared concepts, our firm-wide AML risk assessment guide is a useful companion.

Please read "What we could not confirm" at the end. The text we could access stops in Chapter VI, so we did not read the penalties chapter.

Who is covered

Article 5(2) names accountants and auditors among the non-financial obliged entities. They are subject to the law when they take part in transactions for clients in the activities the article lists, such as buying and selling real estate and managing funds or valuables. Lawyers and notaries are covered on similar terms. Article 5(3) covers company service providers, including those who form and manage legal persons, act as directors or shareholders for others, or provide a registered office.

Who supervises

Article 55 allocates supervision by sector. The Bank of Mozambique supervises financial institutions, the Order of Lawyers supervises lawyers, and the Mozambican Order of Accountants and Auditors (Ordem dos Contabilistas e Auditores de Moçambique) supervises accountants and auditors. The financial intelligence unit, GIFiM, supervises residually any entity without another supervisor.

Customer due diligence

Article 15(1) requires identification and verification on starting a business relationship, for occasional transactions, and where there is suspicion or doubt. For occasional transactions, the article sets a threshold of MT 900,000 or more, and also covers domestic and international transfers. Other thresholds in the law apply to casinos (MT 190,000), social gaming (MT 60,000) and cash dealings in precious metals and gems (MT 900,000), which are less relevant to accountants.

Beneficial owners

Articles 15(7), 18 and 19 require the beneficial owner to be identified and verified with supporting documents and an independent, credible source. For legal persons, this means the natural person who holds shareholder control or exercises control by other means or, failing that, the senior manager. A client declaration alone is accepted only where the risk is demonstrably low (Article 19(3)). Our guide to ultimate beneficial ownership explains the wider idea.

Politically exposed persons

Articles 23 and 24 require approval from top management, proof of the origin of assets and funds, and enhanced monitoring. Under Article 23(3), PEP status ends two years after the event that gave rise to it, subject to paragraph 4. Our guide to politically exposed persons sets out the concept for UK readers.

Reporting suspicions

Article 44(1) requires suspicions to be reported to GIFiM "immediately", and the text we read sets no deadline in days. The duty also covers attempted transactions (Article 44(2)). Article 44(3) requires mandatory reporting of cash transactions of MT 250,000 or more, and a separate MT 750,000 threshold that our reading says applies even if the transaction is split, so check the exact wording. Lawyers are exempt for information obtained in legal advice or in defending a case (Article 44(5)).

Confidentiality

Article 53 prohibits obliged entities, their bodies and employees from revealing to the client or third parties that a suspicion has been reported. Breach attracts criminal liability, treated as for public officials, as well as disciplinary liability. The article's cross-reference to Article 45 looks like a drafting slip, since the reporting duty sits in Article 44.

Record keeping and training

Article 43(1) requires identification documents and transaction records to be kept for 10 years after the account is closed or the relationship ends. Risk assessment documents are also kept for 10 years (Article 12(5)). The results of the examination of operations are kept for at least 5 years (Article 48(3)), and training records for 5 years (Article 51(2)).

Our suggestions for a Mozambican practice

These are our own suggestions, not legal requirements. Build a single retention schedule around the 10-year rule and a separate shorter line for training records. Because the law says "immediately" without a day count, set an internal same-day escalation rule so staff know whom to tell as soon as a doubt arises. For structured study, see our CPD courses.

Frequently asked questions

Are auditors covered as well as accountants?

Yes. Article 5(2) names both, in the activities it lists.

Who supervises accountants?

According to Article 55, the Mozambican Order of Accountants and Auditors.

How long are client records kept?

Ten years after the account is closed or the relationship ends, under Article 43(1).

What we could not confirm

The text we read ended in Chapter VI (Article 65), so we did not read the sanctions regime, the final provisions or the glossary annex, and we state no fine amounts. We did not check amendments after 2023, regulations made under the law, or any guidance from the Order of Accountants and Auditors or GIFiM. We read the Portuguese text through a summary, so check article wording against the official Portuguese original. This post is general information, not legal advice.