Industry

AML screening and reporting for remittance and bureau de change operators in Zambia

Remittance companies, money transfer agents and bureaux de change in Zambia are licensed by the Bank of Zambia and are reporting entities under the Financial Intelligence Centre Act and the Prohibition and Prevention of Money Laundering Act. Every transfer has to be screened against sanctions lists, customers have to be identified and periodically rescreened, patterns such as structuring below thresholds have to be detected, and suspicious or currency transactions have to be reported to the Financial Intelligence Centre. These operators usually have small compliance teams and cannot carry enterprise-scale systems.

ERMAML, the Ontech Risk & Compliance Suite, gives them the controls without the complexity: real-time screening of each wire against UN, OFAC, EU and UK lists through OpenSanctions, scheduled rescreening of repeat customers against the FIC PEP list and adverse media, velocity, structuring and geographic-risk rules tunable in the interface, suspicious transaction reports drafted in the goAML schema, and a vendor and agent register for the branch and agent network.

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ERMAML AML dashboard with screening and alert queues

Key capabilities

Real-time screening on every transfer

Sender, receiver and counterparty are screened against sanctions lists on each wire, with fuzzy and transliterated matching and a false-match review queue.

Scheduled customer rescreening

Repeat customers are rescreened on a daily delta against the FIC PEP list and adverse media rather than by hand.

Threshold and structuring rules

Velocity, structuring and geographic-risk rules from the seven default rules, tuned in the interface without a system change.

goAML report drafting

Suspicious and currency transaction reports drafted in the goAML schema from case data, ready for the reporting officer to submit.

Cash-handling risk

Cash positions and handling exposure tracked as key risk indicators alongside the operational-loss register.

Agent network due diligence

A vendor and agent register with risk score, due diligence evidence and contract repository for the agent network.

How it works

Transfer and customer data are connected from the operator's transaction system or uploaded in batches.
Existing customers are back-loaded and screened to establish a baseline.
Each new transfer is screened in real time and monitored against the rule set.
Alerts become cases, are reviewed under maker-checker control, and are drafted as goAML reports where warranted.
Repeat customers are rescreened on a schedule and agents are reviewed through the agent register.
Cash-handling indicators and the operational-loss register feed the management report.

Benefits

Screening inside the workflow

Transfers are screened as they are processed rather than one customer at a time on a vendor portal.

Structuring caught as it happens

Velocity and threshold rules detect split transactions in real time instead of after the fact.

Reports from case data

STRs and CTRs are drafted in the goAML format from the investigation record, which removes rekeying and mis-keyed names.

Sized for a small team

The same controls a bank runs, configured for an operator with a few compliance staff.

Who it is for

Remittance and money transfer operators licensed by the Bank of Zambia.
Bureaux de change with sanctions screening and reporting obligations.
Payment service providers that settle cross-border transfers.
Compliance officers who are also the money laundering reporting officer.

Zambia-specific considerations

Money transfer and foreign exchange businesses in Zambia are licensed by the Bank of Zambia and are among the reporting entities the Financial Intelligence Centre relies on for suspicious and currency transaction reports. Cross-border transfers make sanctions screening on every transaction, not only at onboarding, the core control.

Zambia follows the FATF Recommendations as an ESAAMLG member, which is why screening covers the UN Security Council lists as well as the OFAC, EU and UK lists that counterparties abroad apply. ERMAML screens against all of them through the OpenSanctions dataset with a daily delta sync.

How ERMAML addresses this

Every wire screened in real time

The screening gate checks each transfer against the full sanctions corpus with fuzzy matching, and a four-eyes whitelist stops the same false match being reviewed twice.

Rules tuned by the compliance officer

Structuring, velocity and geographic-risk rules are adjusted from the interface and backtested, without a change request to a vendor.

goAML-ready reporting

Reports to the FIC are drafted from case data in the goAML schema, with registry-verified identity details populated where available.

Frequently asked questions

Are bureaux de change reporting entities in Zambia?

Yes. Bureaux de change and money transfer operators are licensed by the Bank of Zambia and are reporting entities under the Financial Intelligence Centre Act, so they perform customer due diligence, keep records, and report suspicious and currency transactions to the FIC.

Which sanctions lists does ERMAML screen against?

United Nations Security Council, OFAC, EU and UK lists through the OpenSanctions dataset, together with the FIC PEP list and adverse media. The dataset is synchronised daily and screening uses fuzzy and transliterated matching with a review queue for false matches.

How does it detect structuring?

Threshold, velocity and structuring rules from the seven default detection rules watch for transactions split to stay under reporting thresholds or repeated within short windows. Parameters are tuned in the interface and can be backtested against historic transfers.

Can a small operator afford enterprise AML controls?

ERMAML is configured to the size of the operator. A small team gets real-time screening, monitoring rules and goAML drafting without the modules a bank would enable, and can add them later without re-platforming.

How are agents managed?

Agents and vendors are kept in a register with a risk score, due diligence evidence and the contract repository, so agent onboarding and periodic review follow the same maker-checker discipline as customer cases.

Sources

See ERMAML on your own data

Request a demo with Ontech Solutions in Lusaka and see sanctions screening, KYC, transaction monitoring, goAML reporting and the risk register working together in one platform.