Only P887k recovered from P380m stolen by workers
Innocent Selatlhwa | Wednesday April 22, 2026 09:26
This is contained in the Botswana National Money Laundering and Terrorist Financing Risk Assessment Report. The Risk Assessment (2020–2024) is the country’s second national assessment following the inaugural exercise concluded in 2017.
The risk assessment adopts the World Bank Risk Assessment Tool, which evaluates national threats, scale and nature of illicit proceeds, terrorist financing (TF), as well as vulnerabilities, being weaknesses that may enable criminal exploitation.
Incidents of stealing by servants reported between 2020 and 2022 were found to be low; the values involved were significantly high. In 2020, P298,191,266.20 was reportedly stolen by servants in 20 incidents involving three people, of which only P83,000 has been restrained, and nothing has been confiscated as of when the report was published in October 2025. In 2021 and 2022, P24,227,683.90 and P17,346,356.75 were said to be stolen by servants, respectively, and only P2,520 has been restrained, whilst nothing has been confiscated.
This is the assessor's link with the COVID-19 period, where loads of corruption cases were recorded.
“This may be attributed to the COVID-19 period, where internal controls were compromised by protocols applied to control the spread of the virus. Similarly, the amounts restrained or confiscated were minimal during the same period as compared to the total values involved,” they state.
This, they say, was largely due to delays in identifying and reporting the incidents to Law Enforcement Agencies (LEA) and thereby giving the offenders more time to conceal the money trail and ultimately making it difficult to recover the stolen funds. All the cases recorded involved citizens of Botswana.
The offence called stealing by a servant refers to the misappropriation of property, funds, or assets by an employee entrusted with access in the course of employment. It is a recognised predicate offence under the national AML/CFT framework. Stealing by a servant presents a moderate threat to the AML/CFT system. Weak internal controls, delayed detection, and low asset recovery elevate vulnerability. Recommended mitigation measures include strengthened internal controls, improved segregation of duties, enhanced employee vetting, fraud-awareness programmes, and better coordination between institutions and law enforcement.
The extent of criminality associated with stealing by servants was assessed as moderate, although it only accounted for approximately six percent of the total proceeds generated from national predicate offences. The high number of reported incidence and their upward trend over the years poses a higher level of risk, whilst on the other hand, the amounts involved were, on average, decreasing.
According to the report, although the methods used were not highly sophisticated, they often involved collusion amongst multiple individuals and the use of various tactics to avoid detection, which increased the difficulty of uncovering these offences.
“The actors involved were typically low-level individuals acting alone or with minimal coordination, with no indication of organised syndicate involvement. However, some offenders possessed sufficient knowledge of internal systems and processes, enabling them to exploit operational vulnerabilities,” states the report.
The findings of the assessment are expected to provide Botswana with a comprehensive understanding of its ML/TF threats and vulnerabilities, thereby supporting all stakeholders to implement risk-based supervision, inform policy development, guide resource allocation, and enhance coordinated mitigation efforts.