Judgment No. CCZ 5/15 12 Const. Application No. CCZ 23/14 without being registered. Section 88 goes further to penalise any person who holds himself out to be an insurer or insurance broker whilst not being registered as such in terms of the Act. The prescribed penalty for such conduct is the same as that stipulated under ss 7(1) and 35(1). It is clear that the Act itself does not require the registration of insurance agents. However, s 89(1) provides for the making of regulations prescribing anything which under the Act is to be prescribed or which is necessary or convenient to be prescribed for carrying out or giving effect to the Act. In particular, s 89(2)(d) enables, inter alia, the regulation, registration, licensing and control of insurance agents. The Insurance Regulations 1989 (S.I. 49 of 1989), framed in terms of s 89 of the Act, regulate the conduct of virtually every class of insurance business and activity, including insurance agents. Section 14 of the Regulations provides for the issuance of various insurance agent licences, while s 15 enjoins every agent who represents a registered insurer in respect of insurance business to hold a valid insurance agent licence in the class of business concerned. Additionally, s 15(5) stipulates that no registered insurer or broker shall cause or permit any agent to represent him in respect of any insurance business unless that agent is in possession of a licence in respect of that class of insurance business. It is abundantly clear from the foregoing that ZIMRA is acting in contravention of the Insurance Regulations, by purporting to issue motor insurance policies and collect