Filing Currency Transaction Reports on goAML in Zambia: From the FIC's Online Portal Forms to Bulk XML (2026)

Short answer: A Zambian reporting entity must report any currency transaction "equal to or above the kwacha equivalent of ten thousand United States dollars", single or linked, within three working days (section 30 of the Financial Intelligence Centre Act, 2010; regulation 7 of SI No. 53 of 2022). The prescribed CTR form says "Send the Completed form via the Online Portal", with email or post only in exceptional circumstances. The Financial Intelligence Centre (FIC) now runs a goAML portal at goaml.fic.gov.zm for electronic submission of reports, set on 1 October 2026 to XML schema version "5.0", at most 500 transactions per report and at most 10 attachments, with .xml and .xlsx among the accepted file types. We found no FIC notice that sets a date for filing CTRs as XML on goAML, or that closes any earlier channel. This guide works from the published settings and says where the FIC has not spoken.

It is for operations, compliance and IT teams at banks and other reporting entities that file many CTRs and want to move from web forms to batches of XML. It is a practical guide, not legal advice.

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The rule in one paragraph

Section 30 of the Act requires a report "promptly but not later than three working days" on any currency transaction at or above the prescribed amount, "whether conducted as a single transaction or several transactions that appear to be linked". Regulation 7 of SI No. 53 of 2022 sets the amount at the kwacha equivalent of USD 10,000, in kwacha or a foreign currency, "in the Form set out in the Schedule". Accountable institutions, such as motor vehicle dealers and travel agents, have the same duty under SI No. 54 of 2022. The FIC's 2023 guidelines for non-bank financial institutions call the amount "a threshold and not a limit", and splitting transactions to avoid the report is an offence under section 45A. Whether "currency" reaches electronic transactions, which exchange rate applies and whether any exemption exists are open questions. Our currency transaction report guide for Zambia covers each.

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How CTRs have reached the FIC so far

The FIC's reporting channel predates goAML. Its Banking Sector Reporting Guidelines of 2019 say that to report an STR or CTR "the designated compliance officer should obtain login credentials from the FIC for the FIC online reporting portal". Its 2022 STR guidance note lists filing "On the FIC e-system", and its 2023 sector guidelines refer to "the online reporting portal". The prescribed CTR form says "Send the Completed form via the Online Portal", and "Only in exceptional circumstances" by email to FICCTR@fic.gov.zm or by post. None of these documents names goAML.

Zambia's 2025 National Risk Assessment found that "the suspicious transaction and currency transaction reporting system was automated and the majority of reports from reporting entities were received electronically". The FIC received 1,327,832 CTRs from 2019 to 2024, and 377,808 in 2024 alone, up 32.6% from 285,004 in 2023.

goAML is the newer system. The FIC began implementing it in 2023, and its bulletin for the first quarter of 2024 said: "We envisage to go-live in quarter 3 of 2025." The production portal was live on 1 October 2026. We found no announcement of the go-live date, no notice closing the older channel, and no rule or notice requiring CTRs to be filed as XML, or through goAML, by any date; the Act and both 2022 statutory instruments do not name goAML. Plan around the portal as it stands, and confirm the current channel with the FIC in writing.

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What the goAML portal's settings mean for a bulk filer

The production portal's settings on 1 October 2026:

Schema version. The portal reports "5.0" with no minor version. Generate and validate XML to the version the portal reports, and recheck it before each release.

500 transactions per report. An illustrative example: a bank with 1,200 reportable transactions on one day needs at least three reports, of 500, 500 and 200; split by branch or customer and it needs more. The FIC has not said how it wants batches split, so agree the split key with the FIC first. The goAML reporting module for Zambia of the Creodata AML platform splits a batch under a per-report transaction limit and brings linked transactions together under currency-threshold rules, but the split rule itself should come from the FIC.

Test environment. The FIC runs a second site labelled "TEST ENVIRONMENT" on the same software version. We found no statement on whether you must test there before filing live. Use it anyway.

Registration and users. The portal says "You have to login for you to be able to submit a report". An organisation registers first under "Register as an Organisation" and other staff join as "User (Reporting Entity)"; see our FIC goAML registration guide.

Support and gaps. The help text says: "Kindly contact the FIC for any assistance with the system." The support line is (+260) 211 220 254 and the email address is gosprt@fic.gov.zm. We found no FIC goAML user guide or filing notice, and the report-type list needs a login, so the FIC's CTR report codes are not public.

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The prescribed CTR form's fields and where your data lives

The table maps the field groups of the prescribed form in SI No. 53 of 2022, not goAML's own field names, which the FIC has not published for Zambia, to the systems that usually hold the data.

Large banks have thousands of reportable cash transactions a week, and smaller institutions key each one into a web form by hand. Either way, no single system holds every data point the form asks for, so the first project is the data model.

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Linked transactions, subsequent CTRs and structuring

The duty covers "several transactions that appear to be linked", and the Director-General may ask for information on linked transactions (SI No. 53 of 2022, regulation 4). We found no defined period for linking: no same-day rule and no other window. Document the key, window and scope your rule uses and apply it consistently.

The threshold is not a ceiling. The 2023 NBFI guidelines say: "NBFIs are advised to submit subsequent CTRs on previously reported customers." A bulk process that suppresses repeat customers is wrong.

Structuring is a separate offence. Section 45A covers a person who "conducts multiple transactions separately with one or more reporting entities in order to avoid the duty to report a transaction": up to 700,000 penalty units, seven years' imprisonment, or both. The FIC's Trends Report 2024 lists "structured deposits below the reporting thresholds" among the common reasons for suspicion in 2024 STRs. Patterns just under the line are an STR question; see our STR guide for Zambia.

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Amendments and corrections

The prescribed form has a box, "Amends Prior Report", so the FIC expects corrections to be filed as reports that point to an earlier one. The FIC has not published how an amendment is identified on goAML for Zambia, so agree the mechanism with the FIC along with the report codes.

Section 46 makes it an offence to intentionally make "a false or misleading statement", provide "false or misleading information" or fail "to state a material fact" in connection with reporting obligations: up to 500,000 penalty units, five years' imprisonment, or both. Not filing at all falls under section 45, which has covered CTRs since 2016: up to 700,000 penalty units, seven years, or both.

Manual filers track amendments in spreadsheets. A bulk process needs every original, every amendment and the link between them in one record an inspector can read.

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Grey areas to settle with the FIC

Put each of these to the FIC or your supervisory authority in writing and keep the reply.

1. Cash or any currency? Since 2020 the Act defines "currency" as legal tender that "may be represented in coin, paper, electronic or virtual form", while the FIC's 2023 NBFI guidelines and the form speak of cash.
2. Which exchange rate? No rule names the rate that turns USD 10,000 into kwacha. Fix one documented source and time and store the rate with each record.
3. Any exemptions? We found none in the Act, SI No. 53 of 2022 or SI No. 54 of 2022.
4. The aggregation window. No rule defines a period for linking transactions.
5. Attachments. The portal's code lists categories such as Business/Company Registration Certificate, NRC, Passport and Tax Clearance Certificate for report attachments, not registration. The FIC has not said which, if any, it wants with a CTR.

For the law behind these points, see the Financial Intelligence Centre Act explained.

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Migration checklist

The FIC's Trends Report 2025 says "The Mutual Evaluation (ME) for Zambia is due in 2027" and does not mention goAML; there is no published goAML deadline, only the three-working-day clock.

1. Confirm your FIC-approved compliance officer and reporting officers; pre-goAML guidelines tied portal credentials to that approval.
2. Register on goaml.fic.gov.zm as a "Reporting Entity" and add filers as "User (Reporting Entity)".
3. Ask the FIC for its report codes and any filing instructions; none are published.
4. Confirm the current CTR filing channel with the FIC in writing, and whether the test environment must be used first.
5. Build to schema version "5.0" and validate every file before upload.
6. Design the batch split around 500 transactions per report and agree the split key with the FIC.
7. Write the linked-transaction rule: key, window and scope.
8. Capture the conductor of third-party cash deposits as structured data.
9. Store the exchange rate used with every record.
10. Define the amendment process, including how an amended report is identified on goAML.
11. Keep every report, amendment and submission record for at least ten years.
12. Run a full batch on the test environment, and know who to call: (+260) 211 220 254 or gosprt@fic.gov.zm.

See also our bank readiness guide for goAML reporting in Zambia and our guide to goAML submission rejections.

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Frequently asked questions

Can we file CTRs to the FIC by email?

Only in exceptional circumstances. The prescribed form says "Send the Completed form via the Online Portal" and reserves email to FICCTR@fic.gov.zm, or post, for exceptional cases.

How many transactions fit in one goAML report in Zambia?

On 1 October 2026 the production portal was set to a maximum of 500 per report. The FIC has not said how to split a larger day into batches.

Is there a goAML test site?

Yes. The FIC runs a site labelled "TEST ENVIRONMENT" on the same software version as production, but we found no statement on whether you must test there first.

Does the FIC say which exchange rate to use?

No. We found no rule on the rate in SI No. 53 of 2022, SI No. 54 of 2022 or the FIC's 2019 and 2023 guidelines. Choose one documented source and keep the rate with each report.

What happens if we split transactions to stay under the threshold?

Section 45A makes it an offence to conduct multiple transactions separately to avoid the duty to report: up to 700,000 penalty units, seven years, or both. A customer's pattern of this kind belongs in an STR.

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Bulk CTR filing with the Creodata AML platform

The goAML reporting module of the Creodata AML platform generates schema-valid goAML XML from transaction and customer data and validates it against the goAML XSD and business rules before it is uploaded to the FIC's portal. Currency-threshold rules bring linked transactions together and split a batch under a per-report transaction limit, every report and filing goes into an immutable audit trail, and a manual download covers a portal outage. A typical project runs six to eight weeks from kickoff to first live submission. See the goAML reporting module for Zambia and AML compliance software in Zambia.

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Sources and date checked

All checked 1 October 2026 unless stated.

• Financial Intelligence Centre Act, 2010 (Act No. 46 of 2010), sections 30, 45, 45A and 46, with the amendment Acts No. 4 of 2016 and No. 16 of 2020. PDFs on fic.gov.zm; the 2020 Act also on mofnp.gov.zm.
• SI No. 53 of 2022, regulations 4 and 7 and the Schedule (CTR form). Gazette copy on media.zambialii.org.
• SI No. 54 of 2022, regulation 13 and the Fourth Schedule. PDF on fic.gov.zm.
• FIC Banking Sector Reporting Guidelines, 2019; Guidance Note on Reporting of Suspicious Transactions, 2022; AML/CFTP Guidelines for the NBFI Sector, August 2023. PDFs on fic.gov.zm.
• FIC Bulletin, Quarter 1 2024; FIC Trends Report 2024; National Risk Assessment Report 2025. PDFs on fic.gov.zm.
• FIC Zambia goAML production portal (public home page, help text and configuration settings) and test environment home page, goaml.fic.gov.zm. No login used.
• FIC Trends Report 2025. PDF on fic.gov.zm. Checked 4 November 2026.