Zimbabwe is a lower risk (but still high) from a Jersey Appendix D2 perspective. What do you think?
27/05/2025
As of March 2022, Zimbabwe is no longer on the FATF grey list. On May 27, 2025, it will no longer be subject to Jersey/UK sanctions.
Although the JFSC has not recognised the May 27 changes in its Appendix D2, technically, Zimbabwe now has only 3 Jersey JFSC D2 country risk touch points.
KNOW YOUR COUNTRY [https://www.knowyourcountry.com/Zimbabwe], a source the JFSC uses, suggests the country is MEDIUM TO HIGH.
The question is, what do you think?
FATF
Zimbabwe was placed on the FATF grey list in 2019 and removed from it following an on-site evaluation in early 2022.
This 2022 decision indicates that Zimbabwe has made significant progress in addressing the strategic deficiencies in its anti-money laundering and counter-terrorist financing measures.
The FATF February 2025 grey list shows 25 countries as follows:-
- Algeria, Angola, Bulgaria, Burkina Faso, Cameroon, Côte d'Ivoire, Croatia, Democratic Republic of the Congo, Haiti, Kenya, Lao PDR, Lebanon, Mali, Monaco, Mozambique, Namibia, Nepal, Nigeria, South Africa, South Sudan, Syria, Tanzania, Venezuela, Vietnam, Yemen
- https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html
Jersey/UK sanctions
On May 27, 2025, the UK have removed the last five entities from the Zimbabwe sanctions list, leaving the country with no active sanctions from the UK.
The following entries have been removed from the UK Consolidated “sanction” List and are no longer subject to an asset freeze:
- Godwin MATANGA (Group ID: 14054)
- Isaac MOYO (Group ID: 14055)
- Owen NCUBE (Group ID: 14052)
- Anselem Nhamo SANYATWE (Group ID: 14053)
- ZIMBABWE DEFENCE INDUSTRIES (Group ID: 10734)
Source
- https://assets.publishing.service.gov.uk/media/683582959afff1b427db02ce/Notice_Zimbabwe_270525.pdf
- List of active sanctions (consolidated list) in Zimbabwe (empty list) - https://assets.publishing.service.gov.uk/media/683582a95d4f0caf4c3c8592/Zimbabwe.pdf
- 27th May Financial Sanctions notice update https://assets.publishing.service.gov.uk/media/683582959afff1b427db02ce/Notice_Zimbabwe_270525.pdf
- https://zwnews.com/zimbabwe-removed-from-fatf-grey-list/
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.