Introduction

Zambia has successfully launched the pilot implementation of the Anti-Illicit Financial Flows (IFFs) Policy Tracker following a two-day workshop held on 18–19 May 2026 in Lusaka.
This initiative, led by the African Union Commission (AUC) in collaboration with Tax Justice Network Africa (TJNA) and the African Tax Administration Forum (ATAF), aims to identify policy gaps and vulnerabilities in the country’s frameworks for curbing IFFs.

Zambia joins Namibia, Uganda, Ghana, Côte d’Ivoire, and Liberia as one of the pilot countries. The launch marks a significant milestone in strengthening the national response to illicit financial flows and enhancing domestic resource mobilisation (DRM).

For multinational groups, local companies, financial institutions, and other entities operating in Zambia, this development signals a heightened government focus on transparency, cross-agency coordination, and enforcement in tax, anti-money laundering (AML), and anti-corruption matters. RSM advises clients to closely monitor the outcomes of the pilot and the forthcoming country report.

What are Illicit Financial Flows (IFFs) and the Anti-IFFs Policy Tracker?

Illicit Financial Flows refer to cross-border movements of money, assets, or value that are illegally earned, transferred, or used. In the African context, common sources include tax evasion and avoidance (especially transfer mispricing), corruption, trade mis-invoicing, money laundering, and other criminal activities. These flows cause substantial revenue losses that undermine public services and sustainable development.

The Anti-IFFs Policy Tracker is a structured self-assessment and monitoring tool that helps African countries evaluate their national frameworks for addressing IFFs, with a primary focus on tax-based IFFs. It is organised around four thematic clusters: policy, data systems, institutional arrangements, and inter-agency coordination.

Key features include:

  •  A participatory, multi-stakeholder assessment process.
  • Identification of gaps in legislation, administration, and enforcement.
  • Generation of actionable recommendations.
  • Contribution to continental reporting and benchmarking.

The Lusaka workshop involved senior officials from the Ministry of Finance and National Planning, Zambia Revenue Authority (ZRA), Financial Intelligence Centre (FIC), Bank of Zambia, Anti-Corruption Commission, and other stakeholders.

ZRA Commissioner General Dingani Banda, who officiated at the launch, stated that the Tracker will strengthen Zambia’s ability to systematically track, monitor, and respond to illicit financial flows. He highlighted an alarming trend, noting that the FIC had reported suspected IFFs worth $5 billion between 2023 and 2024.

Mr. Banda emphasised that the development of the Tracker demonstrates Zambia’s commitment to strengthening governance systems, improving transparency, and safeguarding domestic resources for national development.

The pilot proceeds in two phases: (1) the workshop-based assessment using the Tracker tool, and (2) the development and dissemination of a country report with findings and recommendations. Results will feed into broader African Union discussions, including the STC meeting in August 2026. Representatives from ATAF, AUC, and TJNA have committed to supporting Zambia and other member countries in strengthening domestic resource mobilisation.

Objective of the Initiative

The primary objective is to support evidence-based reforms that enhance Zambia’s capacity to detect, prevent, and curb IFFs. By identifying vulnerabilities and improving coordination among key institutions, the pilot aims to boost domestic revenue mobilisation, promote good governance, and advance Africa-led solutions for sustainable development.

Compliance Implications for Zambian Groups and Local Entities

Although the Policy Tracker is primarily a government self-assessment tool, its findings are expected to drive stronger enforcement and potential new or refined compliance obligations for the private sector. Businesses should prepare for developments in the following areas:

1.    Enhanced Tax Transparency and Reporting

  •  Increased scrutiny of transfer pricing documentation and practices.
  • Possible expansion of Country-by-Country Reporting (CbCR) or similar requirements for MNEs.
  • Tighter rules on beneficial ownership disclosure and related-party transactions.

2.    Anti-Money Laundering (AML) and Financial Intelligence

  • Greater coordination between ZRA, FIC, and the Bank of Zambia, potentially leading to more frequent information requests and joint audits.Heightened due diligence expectations for high-risk sectors (e.g., mining, commodities trade, financial services).

3.    Anti-Corruption and Governance

  • Stronger alignment with Anti-Corruption Commission requirements.
  • Emphasis on internal controls, whistleblower protections, and ethical business conduct.

4.    Data Sharing and Record-Keeping

  • Demands for improved digital record-keeping and timely information provision across agencies.
  • Potential new reporting thresholds or formats aligned with continental best practices.

Recommended Actions for Businesses

  • Review and strengthen transfer pricing policies and documentation.
  • Conduct internal risk assessments focusing on IFF exposure (e.g., trade mispricing, thin capitalisation).
  • Maintain robust AML/KYC processes and beneficial ownership registers.
  • Monitor official communications from ZRA, FIC, and the Ministry of Finance following the release of the country report.
  • Engage with industry associations or professional advisors (such as RSM) to stay ahead of emerging requirements.

RSM Commentary
This successful pilot underscores Zambia’s commitment to regional and continental efforts against IFFs. While it offers opportunities to improve the business environment through better governance and transparency, it also indicates a period of regulatory evolution and increased enforcement.
 

Proactive compliance will be essential to mitigate risks of penalties, audits, or reputational damage. RSM Zambia’s tax and advisory teams are monitoring the outcomes of the Lusaka workshop and the forthcoming country report. We are ready to assist clients with impact assessments, compliance reviews, and strategic planning in response to any resulting reforms.

 

Stephen Kangwa 
Supervisor - Tax & Advisory Services 

 

For more information or tailored advice, please contact your usual RSM advisor or reach out to the RSM Zambia Tax Team. This alert is for general information purposes only and does not constitute professional advice. Specific circumstances should be discussed with a qualified advisor.

 

 

 

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