Botswana was removed from the Financial Action Task Force grey list in October 2021 after reforms to its anti-money laundering and counter-terrorist financing framework. The budget speech in February 2026 scheduled the next mutual evaluation, by the Eastern and Southern Africa Anti-Money Laundering Group, for January 2027.
The evaluation will examine the effectiveness of the Financial Intelligence Act No. 2 of 2022 and the Counter-Terrorism Amendment Act No. 11 of 2022, coordination between the Financial Intelligence Agency, law enforcement and supervisors, and the handling of terrorism-financing designations.
The evaluation looks for measurable results: investigations, prosecutions, convictions, asset recoveries and terrorism-financing cases. It also examines whether accountants, lawyers, real estate agents and other designated non-financial businesses are applying customer due diligence and reporting suspicious transactions.
A return to the grey list would mean enhanced monitoring, tougher scrutiny of financial institutions and pressure on correspondent banking relationships. CIPA’s beneficial ownership register, which is being rebuilt, is one of the measures intended to satisfy the evaluators.
What this means for you
- Accounting firms, law firms and estate agents are reporting entities: check that your AML policy, risk assessment and training records are current.
- Update beneficial ownership information at CIPA for every company you control or administer.
- Boards should minute their review of the AML/CFT framework before the January 2027 assessment.
If any of these points apply to your organisation, talk to us. We will tell you what needs to change and what it will take.
Financial Action Task Force: Botswana
Financial Intelligence Agency, Botswana
Parliament of Botswana: 2026 Budget Speech
Published 19 August 2026. This article is general information, not advice for a specific situation.