Money Laundering and Proceeds of Crime Act Act No. 4/2013 (b) any deposit, withdrawal, exchange or transfer of funds in any currency whether in cash or by cheque, payment order or other instrument or by electronic or other non-physical means; (c) the use of a safety deposit box or any other form of safe deposit; (d) entering into any fiduciary relationship; (e) any payment made or received in satisfaction, in whole or in part, of any contractual or other legal obligation; (f) any payment made in respect of a lottery, bet or other game of chance; (g) establishing or creating a legal person or legal arrangement; (h) such other transaction as may be designated in accordance with section 102; “ultimately owns or controls the rights to or benefits from property”, in relation to the property of a legal person that is deemed to be owned or controlled by a natural person, has the meaning given to that phrase in subsection (2);8I “wire transfer” means any transaction carried out on behalf of an originator through a financial institution (including an institution that originates the wire transfer and an intermediary institution that participates in completion of the transfer) by electronic means with a view to making an amount of money available to a beneficiary person at another financial institution. 14 Anonymous accounts and shell banks prohibited (1) No financial institution shall establish or maintain any anonymous account, or an account under fictitious name. (2) No shell bank may be established or permitted to operate in or through the territory of the Zimbabwe. (3) No person shall enter into or continue business relations with a shell bank or a respondent financial institution in a foreign country that permits any of its accounts to be used by a shell bank (4) No designated non-financial business or profession shall effect or facilitate a transaction where any director, principal, officer, partner, professional, agent or employee of the business or profession knows or has reasonable grounds to suspect that a party to the transaction is acting anonymously or under a name that is not his or her own, unless the director, principal, officer, partner, professional, agent or employee concerned in the transaction is satisfied as to the true identity of the party and that there are legitimate reasons for the party so to act. (5) Where a designated non-financial business or profession has effected or facilitated a transaction in which a party is acting anonymously or under a name that is not his or her own, the director, principal, officer, partner, professional, agent or employee concerned in the transaction shall, on behalf of the business or profession of which he or she is the director, principal, officer, partner, professional, agent or employee, record its reasons for doing so and shall keep the record for at least five years after the completion of the transaction. (6) Any person who intentionally or by gross negligence— (a) opens an anonymous account or an account in a fictitious name for a customer in contravention of subsection (1); or (b) establishes in Zimbabwe in contravention of subsection (2); (c) contravenes subsection (3), (4) or (5); shall be guilty of an offence shall be guilty of an offence and liable to a fine not exceeding level fourteen or to imprisonment for a period not exceeding ten years, or both such fine and such imprisonment. 8 (sic) This should refer to section 2(2). There is no subsection (2) in section 13. - 23 -