The application of the special foreign-exchange regime to the liquefied natural gas (LNG) projects in Areas 1 and 4 of the Rovuma Basin was the subject of a workshop organised by Millennium bim in Maputo. The event highlighted a key issue for suppliers: participation in the supply chain does not automatically guarantee access to the conditions set out under this framework.

According to a bank statement published on 21 October, the initiative brought together companies and specialists to clarify procedures covering invoicing, foreign-currency receipts, payments, and equipment imports.

Telmo Ferreira, managing partner at CGA — Couto, Graça & Associados, who led the legal component, explained that eligibility depends on the nature of the entity, the operation, and the relevant contracts. The bank's technical teams participated in the analysis of specific cases.

For Januário da Costa Valente, executive board member at Millennium bim, supporting these investments requires specialised knowledge and the ability to anticipate difficulties, enabling companies to execute their operations with greater certainty and predictability.

A Specific Framework for the Gas Projects

The framework is grounded in Decree-Law No. 2/2014 of 2 December, which establishes the special legal and contractual regime for the LNG projects in Areas 1 and 4.

The foreign-exchange chapter covers concessionaires, special-purpose entities, and principal subcontractors. It also extends, in expressly defined circumstances, to financiers, non-resident subcontractors, and expatriate staff.

The decree allows covered entities to hold accounts in meticais and in foreign currency at banks licensed in Mozambique, as well as offshore accounts under the terms it defines. For purchasing meticais to pay taxes, it provides for direct recourse to the Banco de Moçambique.

Foreign-Currency Conversion Has a Defined Scope

One provision stipulates that, following the start of production at each project, 50% of amounts transferred from offshore accounts to accounts in Mozambique for the domestic payments specified in the decree — including taxes, goods, services, and workers — must be converted into meticais.

This percentage applies to those specific transfers and does not constitute a general obligation to convert half of all LNG export revenues. The distinction is important for understanding the regime's effect on foreign-currency availability in the domestic market.

The framework also includes Notice No. 7/GBM/2018, which establishes complementary procedures for financing operations by concessionaires and special-purpose entities, including fund-sharing mechanisms between companies — known as cash pooling. The notice itself limits its application to the operations of these entities.

Accounts and Financing Subject to Oversight

The Foreign Exchange Law, enacted under Law No. 28/2022 of 29 December, recognises the regime established by Decree-Law No. 2/2014 among the special foreign-exchange regimes and sets out provisions for the oil and gas sector.

Among the obligations prescribed are the reporting to the Banco de Moçambique of identifying details for concessionaire accounts within 15 days of opening, and the periodic reporting of movements on offshore accounts, with quarterly statements to be submitted. The law also covers the provision of information on contracts with non-resident suppliers and the supervision of financing arrangements. The application of these rules must take into account the special framework applicable to each project.

For supplier companies, the practical implication is the need to prepare contractual and banking documentation before executing payments or establishing receipt conditions. The classification of each participant and the nature of the transaction determine the applicable procedures, making prior verification an essential step in the financial management of contracts linked to the Rovuma Basin.