Botswana is once again under the microscope for its efforts to fight financial crime. A former senior counter-terrorism official has warned that the country risks being placed back on the Financial Action Task Force (FATF) grey list, or possibly facing the harsher black list, as international assessors prepare to review its anti-money laundering measures.
This warning comes ahead of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG)’s third-round mutual evaluation of Botswana. The upcoming assessment will test not only the country’s laws but also whether its institutions are truly delivering results.
Former Counter-Terrorism Chief Advocate Mosate told WeekendPost that Botswana’s readiness for this assessment remains uncertain, noting that this evaluation will be much more demanding. “The crisp issue, however, is how well is she prepared for this impending assessment?” Mosate asked.
Botswana was removed from the FATF grey list in October 2021 after implementing reforms to address shortcomings in its anti-money laundering and counter-terrorist financing framework. But Mosate questioned whether those improvements have been maintained. “Has the success that facilitated the grey-listing exit of 2021 been sustained this far?” he asked.
The upcoming review will focus heavily on effectiveness, whether Botswana’s financial crime controls actually work in practice, not just whether laws and policies exist on paper. Mosate said assessors will expect solid evidence, including investigations, prosecutions, convictions, asset recoveries, terrorism-financing cases, and other measurable outcomes.
“Provable statistics will certainly have to be produced, and neither the ipse dixit of those with the gift of the gab nor the authorities matter,” he noted.
This will be a critical test for Botswana’s law enforcement and financial intelligence agencies, especially if they struggle to show that their systems are producing real, tangible results.
Mosate also flagged Botswana’s counter-terrorism framework as a major vulnerability; particularly issues around coordination between agencies and the effectiveness of national measures. “The issue of the status of our counter-terrorism efforts, national coordination and cooperation will most likely rear its ugly head again,” he said.
He pointed to recent changes introduced through the Financial Intelligence Act No. 2 of 2022 and the Counter-Terrorism Amendment Act No. 11 of 2022, arguing that some of these developments have actually undermined previous progress.
Mosate described some of the changes as “regressive in-roads” into the gains made before Botswana’s removal from the grey list.
He also questioned whether Botswana has properly communicated these shifts in its counter-terrorism posture to international partners. “It appeared that there had been no diplomatic channels employed to communicate the country’s changed counter-terrorism posture, neither is it likely that this has been done to date,” he said.
The controversial “Butterfly saga” also came up, with Mosate suggesting that this case could resurface during the assessment. He criticized how the matter was handled, especially the alleged designation of a citizen as involved in terrorism financing; even though that individual was never officially listed as a terrorist under Botswana’s national regime.
Mosate said this controversy raises broader questions about how Botswana understands and applies its counter-terrorism framework, noting that the case has drawn FATF attention before.
“Is it wise therefore that we so intransigently, borrowing from His Excellency’s lexicon, hold on to the corpse refusing burial when it is more than apparent that even the Almighty God is not prepared to bring back our dear Lazarus to life again?” Mosate asked.
Botswana’s 2021 removal from the grey list was widely seen as a win for the country’s financial reputation. But a return to enhanced monitoring could bring tougher scrutiny to its financial institutions and potentially shake investor and correspondent banking confidence.
“A return to the grey list would expose Botswana to renewed enhanced monitoring and could undermine confidence in its financial system,” Mosate warned.