The BOZ's New Forex Guidelines are Well-Intentioned Steps with Room for Improvement

This article evaluates the impact of the Bank of Zambia's (BOZ) new forex guidelines on the foreign exchange (FX) structure and market operations. We divide it into four sections:

1.     Introduction: Sets the context by discussing recent monetary policy decisions and their implications.

2.     The Guidelines: Outlines the new forex guidelines, explaining their provisions and intentions.

3.     Detailed Analysis of General Provisions: Explores each guideline, covering intended objectives, unintended consequences, and potential improvements.

4.     Conclusion: Summarizes the key points.

A. Introduction

Yesterday, some of our thoughts were published in The Business Telegraph's article titled Currency Risks and Tight Liquidity Cast Shadow on Zambia’s Kwacha Bond Sale Ahead. We shared, "Before the Bank of Zambia Monetary Policy Committee meeting on May 15, we advised the monetary authorities not to misinterpret potential Kwacha appreciation as a reason to postpone raising the statutory reserve ratio by 850 bps, as market expectations suggested. Instead, the central bank increased the policy rate by 100 bps, leaving the cash reserve ratio unchanged. This decision soured market sentiment, leading to the exchange rate bottoming on the same day. Despite their rationale of avoiding aggressive tightening in a weak economic environment, we view this as a potential policy mistake. While we recognize the anticipated economic weakness in the latter half of the year, the central bank will face the challenge of weakening growth while supply-side factors drive inflation higher. Addressing inflation is crucial since growth will inevitably be weak. Anchoring inflation could mitigate the adverse effects of moderated growth on the populace, as inflation has remained elevated for a while, severely impacting household finances.

By not hiking the statutory reserve ratio and with upcoming security maturities, the central bank has potentially set the stage for accelerated Kwacha depreciation in June 2024 due to increased market liquidity. The easing in the tight offshore funding market complicates the situation. Non-resident investors who have yet to divest are likely to do so, creating a significant divergence between the onshore spot rate, supported by central bank FX interventions and moral suasion, and the more fluid offshore market. Exchange rate stability remains a key concern."

We considered the decision a policy mistake because we questioned the authorities' commitment to resolving the FX structure issues. We first emphasized the need to address the FX structure eight months ago in our October 2023 article, Strengthening Zambia's FX Market Structure for Kwacha Stability - An In-depth Advisory Essay. Given the BOZ's failure to raise the SRR, they needed an alternative strategy to prevent the USD/ZMW rate from sharply rising to 30 by the end of June 2024. We identified four potential solutions:

1. Enforce the Movement of Government Deposits: The government could enforce the movement of government deposits to strengthen liquidity management. However, their hesitation so far makes this seem unlikely. An investigation is necessary to understand the underlying reasons for this reluctance.

2. Allow the Yield Curve to Rise: The government could increase the yield curve in June by issuing more than the advertised amounts. However, authorities feel the yield curve should be below 20%, even though it is currently above that level. In the Business Telegraph article, we suggested that fiscal authorities consider a policy approach like Nigeria's recent move, where 150 basis points increased the policy rate to 26.25%. Suppose fiscal authorities are concerned about locking in long-term funding at high rates close to 30%. In that case, they should allow shorter-end yields to rise significantly, to 25%-30%, above the overnight interbank rate of 20%. This strategy would align Zambia with some of its continental peers and attract offshore investment into the shorter end of the curve, temporarily inverting the yield curve. Higher short-term yields would alleviate divestment pressures, stabilize the FX rate, and help anchor inflation. Additionally, eliminating taxes on T-bills, which are more burdensome than bonds due to their application on capital gains, could further attract investment in short-term securities and reduce divestment pressures. This diversification would reduce the concentration of Non-resident Holdings (NRH) in longer-tenor government securities, which currently heavily favor bonds at around 97%.

3. Supporting the FX Market with USD: The Bank of Zambia could support the FX market with more USD. However, this would be challenging because the BOZ aims to reach four months of import cover by year-end. They must surpass this level before comfortably supporting the FX market with additional USD. Some relief could come from the recently concluded Article IV consultation. Given the drought's impact on economic indicators, we might see the Net International Reserves (NIR) target adjusted lower, providing some breathing room.

4. Introducing FX Regulations like SI-33 or Convertibility: We saw SI-33 as a straightforward and possible option. However, the convertibility of export proceeds is more complex and would take time to implement. It requires confirmation that all export proceeds are domiciled in Zambia and navigating legal constraints that could breach IMF Article VIII, particularly under an IMF-led program.

B. The Guidelines

While we have not seen the implementation of SI-33 or convertibility measures, the BOZ is taking steps to address the FX structure. On Friday, May 24, 2024, the BOZ will implement new Foreign Exchange Market Guidelines affecting all market participants. These guidelines have been shared with commercial banks to ensure adequate preparation.

The new guidelines, which apply to all individuals and entities participating in the foreign exchange market within Zambia, are designed to promote transparency, efficiency, and effectiveness in the Country's foreign exchange market. The BOZ aims to streamline forex transactions and enhance market stability by introducing new rules and expectations.

Moreover, the BOZ may request information related to transactions in the foreign exchange market, empowering it to monitor compliance and gather necessary regulatory data. Any violation of these guidelines constitutes an offense and incurs penalties as prescribed under the Bank of Zambia Act, underscoring the importance of adherence.

The guidelines include three key provisions:

4. GENERAL PROVISIONS

Persons conducting transactions in the foreign exchange market shall abide by the following provisions:

(a) The buying or selling of foreign currency is prohibited unless one of the parties to the transaction is an Authorised Dealer.

(b) For all persons resident or registered to operate in Zambia, the trading of Kwacha for foreign currency shall only be done with an Authorised Dealer.

(c) Persons buying or selling foreign currency for Kwacha in quantities up to the negotiable amount shall transact at rates displayed on the Authorised Dealers' board rates. Amounts above the negotiable amount may be transacted at negotiable rates.

Definitions

In these Guidelines, unless the context indicates otherwise:

1. Authorised Dealer refers to a commercial bank or an eligible non-bank financial institution, authorised by the Bank of Zambia to engage in foreign exchange dealings.

2. Board rates refer to displayed prevailing exchange rates that Authorised Dealers offer to buy or sell foreign currencies to their clients.

3. Foreign currency means any convertible currency other than the Zambian Kwacha. Foreign currency is deemed to include any bill of exchange, letter of credit, money order, promissory note, travelers’ cheque, or any other instrument of foreign exchange.

4. Person means an individual, a company or an association or body of persons, corporate or unincorporate.

5. Prescribed negotiable amount means the minimum amount of foreign exchange at which a person needs is allowed to negotiate an exchange rate different from the prevailing board rates. This negotiable amount shall be determined by the Bank of Zambia and communicated to Authorised Dealers.

While this introduction marks a significant step by the BOZ to bolster the functionality of the foreign exchange market, there is room for improvement. Firstly, the wording needs to be more straightforward to enhance understanding. Given our improved comprehension of the guidelines, we have expanded the three key provisions into five for this article. This expansion provides a better understanding of the BOZ’s intentions and guides our analysis, particularly regarding transactions involving foreign currency within and outside Zambia.

4. GENERAL PROVISIONS

Persons conducting transactions in the foreign exchange market shall abide by the following provisions:

(a) The buying or selling of foreign currency is prohibited unless one of the parties to the transaction is an Authorised Dealer. This applies to all transactions involving foreign currency within Zambia.

(b) For all persons, including individuals and entities, who are either resident in Zambia or registered to operate in Zambia, as well as foreign persons not resident in Zambia, the trading of Kwacha for foreign currency within Zambia shall only be conducted with an Authorised Dealer.

(c) Persons buying or selling foreign currency for Kwacha in quantities up to the prescribed negotiable amount shall transact at rates displayed on the Authorised Dealers' board rates. Amounts above the prescribed negotiable amount may be transacted at negotiable rates.

(d) Foreign persons not resident in Zambia and not registered to operate in Zambia may engage in foreign exchange transactions with Authorised Dealers within Zambia, provided such transactions comply with these guidelines.

(e) Transactions conducted entirely outside Zambia between non-resident foreign persons or entities are not subject to these guidelines but must comply with applicable international forex regulations.

C. Detailed Analysis of General Provisions

I. Intra-Zambia Transactions through Authorized Dealers

4 (a) The buying or selling of foreign currency is prohibited unless one of the parties to the transaction is an Authorised Dealer. This applies to all transactions involving foreign currency within Zambia

AND

4 (b) For all persons, including individuals and entities, who are either resident in Zambia or registered to operate in Zambia, as well as foreign persons not resident in Zambia, the trading of Kwacha for foreign currency within Zambia shall only be conducted with an Authorised Dealer

Intended Objectives

This guideline ensures transparency and traceability in all forex transactions. Mandating the involvement of authorized dealers, which the Bank of Zambia regulates, aims to prevent money laundering and illegal currency trading. Authorized Dealers possess the necessary systems and oversight to record transactions accurately, report suspicious activities, and comply with global financial regulations.

Furthermore, by requiring residents and registered companies to transact through an Authorized Dealer, the Bank of Zambia can prevent 'capital externalization,' which refers to transferring funds or assets from a domestic economy to a foreign one. This measure ensures that foreign currency remains within the country’s financial system. The latter complements the export proceeds framework, which mandates the domiciliation of all export proceeds within a local bank, with local banks acting as authorized dealers.

Unintended Consequences

The policy could create bottlenecks and inefficiencies, particularly during high-demand periods, and discourage foreign investment due to perceived operational difficulties. For example, businesses needing quick access to foreign currency might face delays, affecting their operations and competitiveness.

This environment might inadvertently foster a parallel black market for foreign currency as traders seek less restrictive and immediate avenues for their forex needs. Despite the regulation requiring transactions to involve Authorized Dealers, individuals might still engage in black market transactions, bypassing official channels and undermining the effectiveness of the regulations. For instance, traders could swiftly resort to informal networks to obtain foreign currency, further complicating regulatory oversight.

Stringent regulations could also lead individuals and businesses to increase their reliance on cash transactions to sidestep the formal banking system. This shift makes tracking and taxation more challenging, as cash transactions are more complex to monitor. Using proxies—individuals performing transactions on behalf of others—could undermine transaction limits and monitoring, complicating the enforcement of capital controls. For example, a company or an individual might use multiple individuals to perform smaller transactions, avoiding detection and compliance with the set limits.

In response to the restrictions, individuals may use multiple mobile money accounts to obscure the flow of funds, thus bypassing the system. This results in less traceable monetary flows and an increased risk of money laundering. For example, someone might use several mobile money accounts under different names to transfer funds without drawing attention, effectively sidestepping the regulatory framework.

While the policy aims to enhance transparency and control, it might inadvertently drive some market participants to find alternative methods that could undermine these objectives.

Potential Improvements

The Bank of Zambia (BOZ) should implement more stringent monitoring, such as regular audits and transaction reviews, and severe penalties for non-compliance, such as fines and license revocations, to deter black market transactions. Increasing the number of Authorized Dealers will improve accessibility and reduce the incentive to seek alternative markets. Strengthening enforcement mechanisms, such as rigorous checks to prevent entities from exploiting loopholes, such as transferring funds to offshore accounts to bypass local regulations, will further deter black market activities. However, this approach may increase administrative burdens and costs. The BOZ can use technology and data analytics to identify suspicious patterns and enforce compliance effectively.

Authorities should introduce robust tracking mechanisms for cash and mobile money transactions. These could involve stricter regulations on large cash withdrawals and deposits, enhanced scrutiny of fragmented transactions linked to a single source, and leveraging the integration of mobile money platforms with formal banking systems for seamless monitoring of fund flows. Real-time data sharing between banks, mobile money providers, and regulatory authorities will enhance monitoring. Moreover, regulations that limit the number of mobile money accounts per individual linked to verified national IDs will prevent misuse.

Educational campaigns will be crucial for public awareness. These campaigns should inform the public about the risks and legal consequences of engaging in forex transactions outside the regulated environment and highlight the potential benefits of using authorized channels, including security and legal protections. This will encourage compliance and support the effectiveness of these measures, fostering a more transparent and secure forex environment.

II. Prescribed Rates and Negotiable Amounts

4 (c) Persons buying or selling foreign currency for Kwacha in quantities up to the prescribed negotiable amount shall transact at rates displayed on the Authorised Dealers' board rates. Amounts above the prescribed negotiable amount may be transacted at negotiable rates

Intended Objective

The primary aim is to discourage clients from negotiating with multiple banks, particularly when selling USD. This practice drives banks to increase their bids for small amounts, pushing the FX rate higher. This policy aims to reduce volatility in the forex market by stabilizing transaction rates.

Fixing rates for smaller transactions also makes speculative activities less profitable. Speculators, both individuals and corporates, who have engaged in currency speculation will find their strategies significantly impacted. Currently, the minimum negotiable amount in the interbank market is $500,000. The guidelines do not specify whether this threshold will remain or be adjusted higher or lower. If the current $500,000 threshold is maintained, speculators operating below this level will find their strategies constrained by the new regulations. Speculators have traditionally exploited narrower trading spreads (less than the prescribed 2% maximum allowable retail/board spread). Crossing the spread will become more complex and costly with the new guidelines. While this might seem punitive to smaller investors, the positive outcome is reducing speculative activity, leading to a more stable and less volatile forex market.

Encouraging more significant transactions to be negotiated allows the BOZ to provide flexibility for significant forex deals that require more competitive rates due to their volume. This approach standardizes and stabilizes transaction rates for most consumers while allowing flexibility for large transactions, keeping the forex market competitive and fair.

Overall, these measures aim to balance the needs of various market participants, ensuring stability and fairness in the forex market. The BOZ seeks to create a more predictable and efficient forex environment by curbing speculative activities and encouraging negotiated rates for more significant transactions. If implemented effectively, these changes could lead to a more stable and less volatile forex market, instilling a sense of optimism among all stakeholders.

Unintended Consequences

This policy may disadvantage smaller traders who cannot leverage the better rates available through more significant transactions, leading to a less competitive environment. Small businesses and individuals might face non-negotiable rates, reducing business competitiveness and market participation.

Additionally, genuine USD sellers who cannot meet the negotiable amount face severe impacts. In a country like Zambia, with persistent dollar liquidity challenges, these sellers hold a valuable commodity but may not receive fair value for their dollars. It's crucial to note that these sellers, if unable to meet the minimum threshold, may be forced to accept non-negotiable rates, potentially leading to financial losses and reduced market participation.

Examining the Zambian FX market reveals a multi-tiered capital system. Larger banks, with substantial capital bases, can extend more significant numbers and more extensive facilities to a broader array of corporates, many of which earn dollars. This relationship fosters natural loyalty, where corporates transact with banks providing credit facilities unless significantly better rates are available elsewhere. Smaller banks, aiming to tap into this client base, often bid aggressively for dollars, offering competitive rates to attract business. This aggressive bidding results in smaller banks operating with narrower spreads, effectively narrower than the 2% prescribed by the BOZ as the maximum allowable board spread.

Larger banks, benefiting from consistent and lazy dollar inflows, do not need to engage in aggressive bidding, allowing them to maintain wider spreads. However, introducing these guidelines could lead to an overall reduction in spreads across the market. Smaller banks might reduce their board spreads to reflect actual dealing rates, prompting larger banks to match these rates to retain customers. Consequently, the market could see narrow spreads altogether, enhancing competition and benefiting clients. Furthermore, should spreads narrow, the Bank of Zambia might revise the prescribed allowable maximum board spread to a lower level than its current 2%.

Despite these potential benefits, unintended consequences could arise. As larger banks match the board spreads shown by smaller banks, the latter might respond to increased competition by further lifting their board bids, effectively raising their rates to maintain competitive advantage. This circular reaction could cause rates to move faster, exacerbating the dollar liquidity issue. It's important to note that these unintended consequences could increase market volatility and potential financial losses for some market participants.

Potential Improvements

Instead of addressing the issue at the micro level, the Bank of Zambia should consider a macro-level approach, such as enforcing measures like SI33, which would require corporates holding dollars to convert them for local transactions, effectively addressing USD liquidity issues in the medium term. Previously, SI33 failed due to strained government relationships with the mining industry over unpaid VAT refunds and low interest rates that made borrowing cheap, allowing mines to bypass the need to sell USD. With improved relationships and higher interest rates making borrowing expensive, it is an opportune time to reintroduce SI33.

Regularly reviewing the thresholds for negotiable rates is essential to ensure they remain effective and not encourage under-the-table dealings. By maintaining these thresholds in line with current market conditions, the Bank of Zambia can prevent circumvention and promote transparency.

Setting a dynamic range for board rates that adjust based on market conditions could offer more competitive and fair pricing. For example, during high demand for USD, the dynamic range could expand, providing flexibility and preventing artificial rate inflation. Alternatively, abolishing the spread altogether could also be a potential improvement. By eliminating the spread, competition among banks for forex flows would naturally rein in pricing, encouraging banks to offer the most competitive rates, benefiting clients, and fostering a more efficient market.

Periodically reviewing the threshold for what constitutes a "negotiable amount" ensures its relevance amidst economic changes. As the foreign exchange landscape evolves, the definition of significant transactions should adapt accordingly.

The BOZ could open opportunities for SMEs or businesses with substantial monthly transaction volumes reflecting genuine economic activity to apply for rate negotiation. This arrangement would be easy to track and manage because these businesses are restricted to dealing only with their respective banks. Enforcing board rates for amounts below the negotiable threshold may harm small businesses and other legitimate enterprises. Therefore, implementing a mechanism that permits these entities to apply for negotiating client status could mitigate adverse impacts.

Under the proposed transparent application process, SMEs could submit their transaction histories and business activities for review by the BOZ. For example, the criteria for qualification could include a monthly threshold in terms of the total transaction volume, ensuring businesses that transact a total of $500,000 or more per month would qualify, whether this amount is reached through several small or large transactions. To ensure equity and avoid income bias, the BOZ could also introduce a tiered system where businesses with lower transaction volumes could apply for different negotiation benefits. This approach ensures that economically impactful businesses receive the necessary support and provides opportunities for smaller businesses to benefit from the policy, promoting fairness and inclusivity in the forex market.

This method balances the need for strict control over forex transactions with the support of small business economic activities, promoting overall market stability and growth while ensuring equitable treatment of all businesses regardless of size.

Incorporating these improvements can lead to a more dynamic, competitive, and transparent forex market in Zambia. Regular reviews, dynamic pricing, the elimination of spreads, and equitable treatment of all businesses, regardless of size, can collectively enhance market efficiency and fairness, ultimately benefiting all participants.

III. Foreign Non-Residents' Transactions with Authorised Dealers

4 (d) Foreign persons not resident in Zambia and not registered to operate in Zambia may engage in foreign exchange transactions with Authorised Dealers within Zambia, provided such transactions comply with these guidelines

Intended Objective

The primary objective is to reduce speculative activities by offshore players who exploit arbitrage opportunities arising from the wide divergence between onshore and offshore spot rates. The latter aims to limit the upward pressure that offshore rates exert on the onshore rate. By regulating foreign involvement in the forex market, the Bank of Zambia seeks to ensure that these engagements benefit the Zambian economy without destabilizing the market.

Additionally, controlling foreign participation helps ensure that forex market activities align with national economic interests. For example, by setting specific guidelines for foreign transactions, the Bank of Zambia can encourage investments that contribute positively to the economy while deterring those seeking speculative gains.

Ultimately, these measures aim to create a more stable and balanced forex market in Zambia. By reducing speculative pressures and regulating foreign involvement, the Bank of Zambia can foster a market environment that supports sustainable economic growth and financial stability.

Unintended Consequences

Understanding the divergence between the onshore and offshore spot FX trading rates is crucial. The primary cause is the 2009 Statutory Instrument (SI) 44, which restricts resident financial service providers from lending Kwacha to non-residents for less than one year, creating an offshore parallel market. Additionally, while the offshore market responds dynamically to conditions, the onshore market faces moral suasion pressures, and the BOZ supports it with foreign exchange, adding to the disparity. If the divergence remains wide, speculative activities may not significantly reduce, as trading at board rates may still be profitable, though less so than before.

This provision could further distort the foreign exchange market. For instance, offshore players needing to sell USD amounts less than $500,000 and requiring Kwacha for investments like Zambian government bonds must deal at the board bid, which might not be advantageous. Additionally, it fails to address the issue of a few offshore entities having trading limits with authorized dealers in Zambia. Consequently, this provision could deter foreign investors who find the operating environment restrictive or cumbersome, impacting foreign direct or portfolio investment.

Conversely, these regulations could inadvertently encourage local and foreign banks to sign International Swaps and Derivatives Association (ISDA) and Global Master Repurchase Agreement (GMRA) contracts with each other, which could spur not only FX spot trading activity but also FX forwards, FX swaps, bonds, and repos. However, local banks must be comfortable adhering to UK law governing these contracts.

While the intent is to stabilize the forex market and reduce speculative pressures, these measures also introduce complexities. By understanding these dynamics, the Bank of Zambia can fine-tune its regulations to balance stability with market competitiveness better.

Potential Improvements

Addressing short-term challenges with laws and regulations underpins long-term negative impacts and can be difficult to reverse. The current offshore parallel market directly stems from the 2009 Statutory Instrument (SI) 44, which the Bank of Zambia (BOZ) should repeal. Suppose monetary authorities are concerned about offshore players during global divestment cycles, which initially justified the SI. In that case, they should utilize more effective tools like repos and reverse repos to manage liquidity more effectively. Using these tools effectively, BOZ can significantly mop up liquidity to mitigate divestment pressures. To achieve this, they need to eliminate the practice of prescribing rates at which resident banks should bid in Open Market Operations (OMOs). Instead, these rates should be market-determined, allowing for a more responsive and dynamic monetary policy. Moreover, allowing offshore players to participate in OMOs could also enhance the effectiveness of monetary and liquidity interventions.

In summary, BOZ can better address short-term and long-term challenges by repealing outdated regulations like SI 44 and adopting a more flexible and market-driven approach to OMOs.

IV. International Transactions by Non-Residents

4 (e) Transactions conducted entirely outside Zambia between non-resident foreign persons or entities are not subject to these guidelines but must comply with applicable international forex regulations

Intended Objective

This provision acknowledges the limitations of BOZ's jurisdiction over international transactions, ensuring that regulatory efforts remain focused on domestic transactions and avoid overreach while adhering to international norms. For example, a transaction between two foreign entities conducted outside Zambia would not fall under BOZ's regulations but would still need to comply with relevant international forex laws.

By clearly delineating its regulatory scope, the BOZ ensures its guidelines are enforceable and practical, focusing on areas where it can effectively exert control. This approach respects international regulatory frameworks and enhances the credibility and effectiveness of BOZ's domestic regulatory measures.

Unintended Consequence

There is a risk of cementing the parallel market outside Zambian regulations, which could indirectly impact the domestic forex market. By imposing stringent regulations on domestic transactions while excluding non-resident activities, the policy could inadvertently strengthen the parallel market, particularly in conjunction with guidelines 4 (c) and 4 (d). As such, this parallel market can siphon more USD liquidity away from the regulated market, exacerbating dollar shortages and destabilizing exchange rates. If significant volumes of forex transactions occur outside the regulatory framework, it undermines the effectiveness of BOZ's policies to maintain market stability.

Potential Improvements

The Bank of Zambia (BOZ) should focus on practical, cost-effective measures to address unintended consequences. Enhancing cross-border regulatory cooperation with key financial centers where significant forex activities involving the Kwacha occur is a pragmatic step. By establishing information-sharing agreements with major financial hubs, the BOZ can monitor and manage offshore activities more effectively without incurring prohibitive costs. For example, South Africa, through the South African Reserve Bank (SARB), has developed cross-border regulatory frameworks to monitor and manage forex transactions effectively. This cooperation with other financial institutions helps to mitigate the risks associated with offshore trading activities. The BOZ can adopt similar strategies, leveraging relationships with major financial centers to ensure that transactions align with Zambia's domestic objectives and regulatory standards.

Advanced data analytics can significantly influence the BOZ's regulatory oversight. By focusing on significant or irregular transactions, these technologies can provide valuable insights into market manipulation or speculative patterns without extensive administrative overhead. For instance, Kenya has successfully implemented such technologies to monitor mobile money and forex transactions, effectively enhancing its regulatory oversight.

By concentrating on strategic international cooperation and targeted use of technology, the BOZ can better manage the risks associated with international transactions by non-residents.

D. Conclusion

The BOZ's new forex guidelines aim to enhance market transparency and stability but have room for improvement. The BOZ can ensure a more effective and competitive forex market by addressing the unintended consequences through practical enhancements.

Dean N Onyambu is the Founder and Chief Editor of Canary Compass, a co-author of Unlocking African Prosperity, and the Executive Head of Trading at Opportunik Global Fund (OGF), a CIMA-licensed fund for Africans and diasporans (Opportunik). Passion and mentorship have fueled his 15-year journey in financial markets. He is a proud former VP of ACI Zambia FMA (@ACIZambiaFMA) and founder of mentorship programs that have shaped and continue to shape 63 financial pros and counting! When he is not knee-deep in charts, he is all about rugby. His motto is exceeding limits, abounding in opportunities, and achieving greatness. #ExceedAboundAchieve

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