The Financial Action Task Force (FATF), an international watchdog, plays a pivotal role in setting global standards aimed at combatting money laundering, and terrorist financing, and preserving the integrity of the international financial system. Comprising 39 member nations and numerous international entities, the FATF promotes the adoption of legislative and regulatory reforms necessary to fight these financial crimes.

Namibia, a participant through the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG), faces challenges following its recent greylisting by the FATF in February 2024. This designation signifies that Namibia has strategic deficiencies in its anti-money laundering (AML) and counter-terrorism financing (CTF) systems, necessitating heightened due diligence from international businesses and leading to a significant reduction in capital flows, estimated at 7.6% of GDP.

Understanding FATF's Public Lists

• Jurisdictions Under Increased Monitoring (so called ‘Greylist’): This list includes countries that are actively working with the FATF to address strategic deficiencies within their AML/CTF frameworks.

• High-Risk Jurisdictions (‘Blacklist’) are Subject to a Call for Action: These countries show insufficient progress in engaging with the FATF to rectify their AML/CTF shortcomings. These countries include Democratic People's Republic of Korea, Iran and Myanmar.

FATF's Mutual Evaluation Process

The FATF conducts thorough evaluations through a mutual assessment model, involving several on-site visits to assess compliance with its 40 recommendations. These recommendations cover legal, regulatory, and operational measures nations should adopt against money laundering and terrorist financing. Following these evaluations, reports are reviewed and adopted during the FATF’s tri-annual meetings, where countries can address or contest the findings.

The International Cooperation Review Group (ICRG) reviews countries based on several criteria, including non-participation in FATF-style regional bodies and poor mutual evaluation results. Namibia's greylisting followed its unsatisfactory performance during such evaluations, despite ongoing legislative efforts to enhance its AML/CTF frameworks.

Namibia's Responses

Namibia has made considerable progress in complying with the FATF recommendations but still needs to address 13 outstanding action items. To effectively tackle these, the FATF has devised a detailed Action Plan for Namibia, which includes:

• Enhancing AML/CFT Supervision: Boosting the capabilities for both offsite and onsite inspections and implementing strict sanctions for breaches in anti-money laundering and counter-terrorism financing obligations.

• Improving Preventive Measures: Ensuring that financial institutions and designated non-financial businesses promptly apply enhanced due diligence measures and comply with terrorism and proliferation financing requirements.

• Increasing Beneficial Ownership Transparency: Stepping up the reporting of beneficial ownership information and enforcing corrective actions and penalties for non-compliance.

• Strengthening the Financial Intelligence Unit (FIU): Providing more resources and training to enhance the FIU’s analytical and strategic capabilities.

• Enhancing Cooperation between the FIU and Law Enforcement: Improving the integration and use of financial intelligence in criminal investigations through better collaboration between the FIU and law enforcement agencies.

• Boosting Investigative and Prosecutorial Capabilities: Allocating adequate resources and targeted training to authorities involved in investigating and prosecuting money laundering and terrorist financing.

• Demonstrating Effectiveness in Law Enforcement: Showcasing the improved capabilities of law enforcement in handling and prosecuting cases related to money laundering and terrorist financing.

• Finalizing the National Counter Terrorism Strategy: Completing and approving an updated strategy to enhance efforts against terrorism financing.

The Financial Intelligence Centre (FIC) of Namibia is integral to national efforts aimed at rectifying the identified deficiencies. The FIC is enhancing compliance measures and regulatory frameworks to tackle issues leading to greylisting, thereby striving to restore Namibia’s financial reputation on the global stage.

The role of Accountants in fighting Corruption

Accountants play a vital role in maintaining financial integrity and combating economic crimes, guided by the International Federation of Accountants’ (IFAC) Action Plan. This plan emphasizes accountants' ethical responsibilities to avoid aiding criminal activities through thorough due diligence and risk assessments, particularly when taking on new clients. IFAC’s Action Plan for Fighting Corruption and Economic Crime encourages accountants to actively fight corruption using five key pillars: enhancing education, supporting global standards, promoting evidence-based policymaking, strengthening partnerships, and contributing expertise through advocacy. These pillars help accountants effectively address corruption and economic crime.

The Impact on the Work of Accountants

Accountants and financial professionals in Namibia and those engaging with Namibian entities must now navigate increased regulatory scrutiny. The greylisting means:

1. Updated Regulations: New reporting requirements

   Changes in regulations with stricter record keeping and reporting requirements, i.e. beneficial ownership.

2. Enhancing Due Diligence Measures

   Accountants need to consider and adjust internal policies and procedures to incorporate FATF’s updated guidelines and recommendations, particularly in identifying, and managing high-risk clients. This includes the development and implementation of more detailed due diligence procedures regarding AML/CTF risks regarding clients.

   Enhanced due diligence and stringent administrative procedures affect not just financial institutions but all businesses engaged in international transactions.

What Accountants Should Do Now

• Be aware of the new requirements and receive adequate training relating to (AML/CTF).

• Understand the implications and implement new measures to be up-to-date and compliant.

• Participate in discussions and forums on AML/CTF to stay informed of regulatory changes and influence policy development

The Way Forward

Namibia’s path to removal from the FATF grey list requires a concerted effort to adhere to the action plan, necessitating substantial political commitment and regulatory overhaul. The accounting community's proactive engagement in enhancing compliance measures and educating stakeholders about best practices will be crucial in this endeavour.

In conclusion, while the greylisting presents significant challenges for Namibia, it also offers a crucial opportunity for systemic improvements in financial regulation and oversight. Accountants play a critical role in these reforms, ensuring that Namibia not only meets international standards but also enhances its economic resilience against future threats.

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