On 5 June 2026, the Minister of Public Service, Labour and Social Welfare promulgated the Private Voluntary Organisations (Risk-Based Supervision and Protection from Terrorist Financing Abuse) Regulations, 2026 through Statutory Instrument 98 of 2026, in terms of section 28 as read with sections 22(5) and (6) of the Private Voluntary Organisations Act [Chapter 17:05].
The Regulations establish a risk-based supervisory framework for PVOs aimed at strengthening transparency, accountability and compliance with anti-money laundering and counter-terrorist financing standards. They introduce obligations relating to risk assessment, governance, record-keeping, reporting and regulatory oversight, with the objective of preventing the abuse of PVOs for terrorist financing purposes.
We outline the key provisions of the Regulations as follows:
Objectives of the Regulations
The Regulations seek to implement a risk-based approach to the supervision of Private Voluntary Organisations (PVOs) in line with Financial Action Task Force (FATF) Recommendation 8. Their objectives are to ensure that measures aimed at preventing terrorist financing are proportionate to the risks identified and to safeguard the PVO sector from terrorist financing abuse without disrupting or discouraging legitimate charitable and developmental activities.
Risk-Based Supervision and Classification of Private Voluntary Organisations
A central feature of the Regulations is the adoption of a risk-based supervisory framework for the PVO sector, consistent with FATF Recommendation 8. The Regulations require the Minister, in consultation with the Financial Intelligence Unit (“FIU”) and other relevant stakeholders, to conduct periodic sector-wide risk assessments to identify those organisations that fall within the FATF definition of non-profit organisations and are susceptible to terrorist financing abuse.
These assessments evaluate both the threats posed by terrorist actors and the vulnerabilities present within the sector and must be reviewed at least every five years or whenever there is a significant change in the risk environment. Based on the outcomes of these assessments, the Registrar is required to classify PVOs as High Risk, Medium Risk or Low Risk, with the level of regulatory scrutiny and compliance obligations applied to each organisation being proportionate to its assessed risk profile.
The Regulations further require the Registrar to provide reasons for risk classifications and afford affected organisations appropriate avenues for review and appeal. High-Risk classifications are subject to periodic reassessment, and mechanisms are provided for removal from the High-Risk Register where the relevant risk factors have been effectively addressed.
Designated PVOs, Enhanced Supervision and Foreign Funding Controls
The Regulations establish a framework for identifying and designating PVOs that are particularly vulnerable to terrorist financing abuse. Designation may arise where an organisation operates in conflict-affected regions, receives substantial funding from high-risk jurisdictions, engages in significant cross-border financial activity, or maintains governance structures that obscure beneficial ownership or effective control.
Once designated or classified as High Risk, a PVO becomes subject to enhanced regulatory oversight. This includes more frequent reporting obligations, disclosure of funding sources and beneficial ownership information, independent AML/CFT-focused audits, enhanced donor and beneficiary due diligence requirements, and risk-based inspections designed to verify the end use of funds.
The Regulations also introduce a dedicated monitoring regime for foreign funding. Funding originating from jurisdictions identified by the FATF or FIU as presenting elevated terrorist financing risks attracts additional scrutiny and disclosure obligations. PVOs receiving such funding are required to provide prescribed information relating to the source, beneficial ownership, intended use and transfer mechanisms of the funds.
Importantly, the Regulations seek to balance regulatory oversight with the operational realities of the sector. They expressly require supervisory measures to be applied in a manner that does not unnecessarily impede legitimate humanitarian, charitable or development activities and establish mechanisms intended to ensure that legitimate funding is not subjected to unreasonable delays.
Governance, Internal Controls and Self-Regulation
The Regulations place considerable emphasis on governance and institutional accountability as key safeguards against terrorist financing abuse. All PVOs falling within the scope of the Regulations are required to implement governance, financial management and compliance systems proportionate to their size, activities and risk exposure.
These obligations include the maintenance of governance and conflict-of-interest registers, implementation of financial control measures, maintenance of procurement and approval procedures, sanctions screening, donor and beneficiary due diligence processes, and mechanisms designed to detect and prevent the diversion or misuse of funds.
Additional obligations apply to High-Risk organisations, including enhanced verification procedures for beneficiaries, implementing partners and counterpart organisations, as well as strengthened controls designed to prevent funds from being channelled to sanctioned or terrorist-linked persons or entities.
A notable feature of the Regulations is the recognition of self-regulation within the sector. The Registrar may recognise umbrella bodies and sector associations as Self-Regulatory Bodies (“SRBs”), empowering them to develop and enforce sector-specific codes of conduct and compliance standards. Membership in recognised SRBs and adherence to approved compliance frameworks may be considered favourably during risk assessments and supervisory reviews, thereby encouraging greater sector ownership of compliance and governance standards.
Record-Keeping, Reporting and Transparency Obligations
The Regulations establish extensive record-keeping and reporting obligations intended to promote transparency, accountability and traceability of funds within the PVO sector.
PVOs are required to maintain records of domestic and international transactions, donor and beneficiary information, governance records and other supporting documentation sufficient to demonstrate that resources have been utilised consistently with the organisation’s stated charitable purposes. Accounting and financial records must be retained for prescribed periods and made available to competent authorities upon lawful request.
In addition, organisations must maintain accurate and up-to-date registers of members, trustees, directors and key employees. These obligations are intended to facilitate effective oversight, support investigations where necessary, and improve the overall transparency of the sector.
The reporting framework is equally comprehensive. PVOs are required to report suspicious transactions and activities indicative of terrorist financing or money laundering to the FIU. Reports made in good faith benefit from statutory confidentiality protections and immunity from civil or criminal liability.
The Regulations further require the reporting of cash, near-cash and cross-border transactions above prescribed thresholds, together with supporting documentation. Organisations must also establish internal escalation procedures for suspicious activities while ensuring that reporting to the FIU is not delayed by internal processes.
Information Sharing, Regulatory Oversight and Investigative Powers
To support effective supervision and enforcement, the Regulations confer extensive oversight and investigative powers upon the Registrar, the FIU and other competent authorities.
These powers include the authority to request information and documentation, compel the production of records, conduct inspections, enter premises where there are reasonable grounds for suspicion, investigate suspected terrorist financing activities and issue compliance directives requiring remedial action.
The Registrar may also issue compliance orders where weaknesses are identified within an organisation’s governance or control framework and require corrective measures to be implemented within specified periods.
The Regulations further establish mechanisms for domestic and international cooperation. Information may be shared between the Registrar, the FIU, law enforcement agencies and foreign counterparts where necessary for AML/CFT purposes. These provisions reflect the increasingly cross-border nature of terrorist financing risks and seek to facilitate coordinated regulatory and enforcement responses.
Outreach, Capacity Building and Regulatory Guidance
Recognising that compliance is most effective when supported by awareness and education, the Regulations place significant emphasis on outreach, training and capacity building.
The Registrar and the FIU are required to conduct ongoing educational and awareness programmes aimed at improving understanding of terrorist financing risks, emerging typologies and compliance obligations within the sector. Particular emphasis is placed on donor and beneficiary due diligence, governance standards, risk assessments and measures for safeguarding organisational resources.
The Regulations also require regulators to publish guidance notes, compliance tools and typology reports to assist organisations in implementing appropriate risk management measures. Such guidance is intended to ensure that compliance obligations remain practical, proportionate and responsive to the differing capacities and risk profiles of organisations operating within the sector.
To strengthen engagement between regulators and stakeholders, the Regulations establish a Consultative Forum comprising representatives from the PVO Board, the FIU and the PVO sector. The Forum provides a platform for ongoing dialogue regarding emerging risks, implementation challenges and regulatory developments affecting the sector.
Enforcement Measures and Regulatory Sanctions
The Regulations establish a graduated enforcement framework designed to ensure that regulatory responses remain effective, proportionate and dissuasive.
Where non-compliance is identified, regulators may employ a range of enforcement measures, beginning with corrective and remedial interventions such as warnings, guidance directives, mandatory training or compliance orders. More serious or persistent breaches may attract administrative penalties, restrictions on activities, enhanced supervision or other regulatory measures.
The most severe sanctions are reserved for circumstances involving serious terrorist financing risks or persistent non-compliance. These include the freezing of assets, suspension or revocation of registration, removal of office bearers and, where appropriate, referral for criminal prosecution under applicable AML/CFT legislation.
The Regulations also empower the Registrar to remove office bearers who have been designated as terrorists or terrorist associates and require the publication of serious enforcement actions, including revocations of registration, in order to promote transparency, protect donors and beneficiaries, and reinforce public confidence in the integrity of the sector.
Conclusion
The Regulations introduce a comprehensive and sophisticated risk-based supervisory regime for the PVO sector. While they significantly expand regulatory oversight, reporting obligations and compliance requirements, they also incorporate safeguards intended to ensure that legitimate charitable, humanitarian and development activities are not unnecessarily disrupted.
For PVOs, the practical implications extend beyond simple regulatory compliance. Organisations will need to review their governance structures, funding arrangements, risk management frameworks, internal controls, record-keeping systems and reporting procedures to ensure alignment with the new requirements. The Regulations therefore mark a significant evolution in the regulation of the sector and reflect Zimbabwe’s broader efforts to strengthen compliance with international AML/CFT standards while preserving the vital role played by civil society organisations in national development.
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