Chapter four: Economic governance and management during the review of the auditor general’s report, and can present recommendations to Parliament, these recommendations have often remained in files. Examples of successful prosecutions of corrupt practices include the Lesotho Highlands Development Authority (LHDA) cases involving senior staff. 128 Money laundering 458. Lesotho drafted its first Money Laundering and Proceeds of Crime Bill in 2000, which was passed by Parliament in 2008. Prior to that, commercial banks in Lesotho did not have any legal obligation to report or disclose information on suspected activities involving money laundering. Cases related to money laundering were prosecuted under common law and various statutes such as the Criminal Procedure and Evidence Act of 1981, the PCEO Act of 1999 (as amended), the Customs and Excise Act of 1982, and the FIA of 1999. Lesotho is party to the Eastern and Southern African Anti Money Laundering Group (ESAAMLG), established in 1999. The ESAAMLG countries agreed to prepare the necessary legislative framework to incorporate anti-money laundering measures guided by the UN Convention against Transnational Organized Crime and its Protocols (the Palermo Convention). 459. Lesotho has also signed and ratified many international conventions on combating money laundering, terrorism and corruption. These conventions comprise the Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (Vienna Convention, 1988); the International Convention for the Suppression of the Financing of Terrorism (1999); the UN Convention against Transnational Organized Crime (2000); and the UN Convention against Corruption (2003). However, all these conventions are yet to be domesticated and implemented as national legislation. 460. The government of Lesotho, through the CBL, has issued Anti-Money Laundering Guidelines (2000) under the FIA. These impose duties on financial institutions to, among other things, establish and maintain specific policies and procedures to guard against the use of the financial system for money laundering. It is worth noting that the guidelines do not extend to insurance and other financial-sector businesses. 461. The CBL issued draft Financial Institutions (Know Your Customer – KYC) Guidelines in 2006. These impose a duty on banks to implement policies more clearly around KYC, customer acceptance, risk categorisation and management, transaction monitoring, suspicious transaction reporting as well as customer education on money laundering. In addition to money laundering, the Money Laundering and Proceeds of Crime Act criminalises terrorist financing and covers terrorist property. The Act extends coverage to accountable institutions, which include all players in the financial sector, estate agents, lawyers and casinos. The Act establishes the DCEO as its implementing authority. The Act also establishes the Financial Intelligence Unit (FIU), whose job is to acquire information on money laundering and pass it to the DCEO for appropriate action. Commercial banks in Lesotho have also established an interbank forum where compliance officers/money laundering control officers meet to discuss issues of mutual concern. This forum informs the newly established Bankers Association, which takes the matters up with the CBL in the monthly governor’s meetings. The individual banks are affiliated to South African banks. Their policies are therefore largely dictated by the respective parent bank policies based on South African legislative demands and the South African Reserve Bank’s directive that the respective groups should ensure compliance across the group.