Zimbabwe has commenced preparations for its third round Financial Action Task Force (FATF) Mutual Evaluation, scheduled for 2026–2027. The Mutual Evaluation will assess the country’s compliance with international standards on Anti-Money Laundering, Countering the Financing of Terrorism, and Countering Proliferation Financing (AML/CFT/CPF), including FATF Recommendation 8, which specifically relates to Non-Profit Organisations (NPOs). This process is highly consequential for civic space. Without proactive and informed civil society engagement, there is a risk that overly restrictive regulatory measures may be introduced under the banner of international compliance, further limiting the ability of CSOs to operate freely and legitimately. At the same time, the evaluation presents an important opportunity for civil society to influence risk assessments and policy responses to ensure that AML/CFT/CPF measures are proportionate, evidence-based, and consistent with international human rights standards.
As part of the preparatory phase, the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) convened a Pre-Mutual Evaluation Workshop from 12 – 16 January 2026 at Rainbow Towers Hotel in Harare. The workshop aimed to prepare key stakeholders who will be directly involved in Zimbabwe’s Mutual Evaluation, including officials working on AML/CFT/CPF matters and representatives expected to engage with FATF assessors during the evaluation process. Participation targeted institutions responsible for policy, regulation, and implementation within the national AML/CFT/CPF framework.
Civil society participation in the workshop was limited, reflecting the historically constrained involvement of NPOs in FATF-related processes. Through NANGO’s facilitation, representatives from the Zimbabwe Council of Churches (ZCC), the Alliance of Community-Based Organisations (ACBOs), and the Zimbabwe Human Rights NGO Forum attended the workshop, alongside the PVO Registrar and officers from the Ministry of Public Service, Labour and Social Welfare (MoPSLSW). In total, four representatives participated on behalf of the NPO constituency.
The workshop was particularly significant for civil society as it builds on ongoing advocacy around FATF Recommendation 8, which has frequently been misinterpreted and misapplied in ways that justify disproportionate regulation of NPOs. In Zimbabwe, such misapplication has contributed to restrictive legal and policy developments, including provisions within the Private Voluntary Organisation (PVO) Amendment Act of 2025. The limited representation of NPOs at the workshop further underscores the need for deliberate and coordinated engagement to ensure that civil society perspectives are adequately reflected throughout the Mutual Evaluation process.
Historically, Zimbabwean civil society has not meaningfully participated in previous FATF Mutual Evaluations and has largely been excluded from in-country AML/CFT/CPF processes. Many CSOs and CBOs have a limited understanding of how the Mutual Evaluation operates, the areas of focus for assessors, and the potential implications of the process for civic space and organisational operations. This knowledge gap heightens the risk of regulatory responses that may undermine legitimate civil society work.
In response, NANGO is prioritising a sector-wide sensitisation and awareness initiative aimed at strengthening CSO and CBO preparedness for Zimbabwe’s upcoming FATF Mutual Evaluation. The initiative will focus on demystifying the Mutual Evaluation process, clarifying the intent and scope of FATF Recommendation 8, and explaining the role of civil society in supporting compliance while safeguarding operational freedoms. It will also address in-country AML/CFT/CPF obligations, typical areas of assessor scrutiny, and practical measures organisations can adopt to identify compliance gaps and mitigate risk.
The overall objective of this initiative is to strengthen sectoral understanding of FATF Recommendation 8, empower organisations to engage meaningfully with the Mutual Evaluation exercise, and foster collective advocacy for risk-based, proportionate, and rights-respecting AML/CFT/CPF oversight. This is particularly important given that NPOs will be afforded an opportunity to engage directly with FATF assessors during the Mutual Evaluation process.
Based on key takeaways from the preparatory process and lessons from other jurisdictions, including Kenya, NANGO intends to establish a Zimbabwe NPO Technical Working Group (TWG) on FATF. The TWG will serve as a structured and coordinated platform to strengthen civil society engagement in FATF-related processes. It will facilitate engagement with regulators, policymakers, and other stakeholders on the implementation of a risk-based approach to AML/CFT/CPF oversight that is effective without undermining civic space.
The TWG will also monitor AML/CFT/CPF compliance trends, assess regulatory risks, and provide timely updates and technical guidance to CSOs. Through coordinated advocacy, peer learning, and capacity building, the group will support efforts to prevent the securitisation of civic space and ensure that compliance measures do not become tools for arbitrary or disproportionate restrictions on civil society. It will further enable CSOs to anticipate regulatory changes, provide informed input into the Mutual Evaluation, and contribute meaningfully to shaping national AML/CFT/CPF responses.
The Mutual Evaluation will assess both Zimbabwe’s technical compliance with the FATF 40 Recommendations and the effectiveness of its AML/CFT/CPF system. Mandatory Recommendations to be assessed include Recommendations 1, 2, 4, 8, 15, 24, 25, 30, 31, 38, and 40. The process will culminate in a single public Mutual Evaluation Report that provides an internationally agreed assessment of Zimbabwe’s compliance and effectiveness, alongside recommendations for strengthening the national AML/CFT/CPF framework.
Of particular relevance to civil society is Immediate Outcome 10, which examines the extent to which Zimbabwe has applied focused and proportionate mitigation measures to NPOs identified as vulnerable to terrorist financing abuse, without disrupting or discouraging legitimate NPO activities. FATF Recommendation 8 explicitly seeks to address the historical misapplication of counter-terrorism financing measures to the non-profit sector. It requires countries to identify relevant risks, apply proportionate and targeted measures, and remain mindful of the impact of regulation on legitimate NPO activities. Measures that are overly burdensome or restrictive, or that impose obligations such as due diligence on NPOs, are not consistent with the FATF standards.
During the 15th Edition of the NANGO Annual NGO Directors’ Summer Retreat, held in Masvingo, a dedicated session on the FATF Mutual Evaluation Overview was convened to further enhance civil society understanding of the process and its implications. A presentation was delivered by Mr. Tichafa Chigaba, Deputy Director at the Financial Intelligence Unit (FIU) Zimbabwe, who provided insights into the Mutual Evaluation framework, key assessment areas, and expectations for Zimbabwe ahead of the 2026–2027 evaluation cycle. The engagement formed part of NANGO’s ongoing efforts to promote informed, constructive dialogue between civil society and regulators on AML/CFT/CPF issues. For those who were unable to attend the session, the recording is available and can be accessed here:
The FATF Mutual Evaluation represents a critical moment for Zimbabwe’s civil society sector. The way AML/CFT/CPF standards are interpreted and implemented during this process will have lasting consequences for civic space, organisational autonomy, and democratic participation. Sustained, coordinated, and technically informed civil society engagement will be essential to ensure that international compliance obligations strengthen transparency and accountability without eroding the freedoms necessary for civil society to operate effectively.