FIC Circular No. 02 of 2025 Brings in New Compliance Requirements
The Financial Intelligence Centre (FIC) has issued Circular No. 02 of 2025, introducing stricter compliance measures for Accountable Institutions (AIs) and Reporting Institutions (RIs), including accountants, auditors, and financial service providers. The circular aligns with United Nations Security Council (UNSC) sanctions and aims to strengthen Namibia’s fight against money laundering, terrorist financing (TF), and proliferation financing (PF).
Mandatory Reporting of Suspicious Transactions and Activities
Accountants must report the following to the FIC without delay:
Suspicious Transaction Reports (STRs) – If a transaction appears unusual, lacks a legitimate purpose, or may be linked to money laundering or terrorist financing.
Suspicious Activity Reports (SARs) – If a client’s actions or behaviors suggest involvement in prohibited activities.
Nil Returns – If no suspicious transactions were detected during the reporting period, an accountant must still submit a report confirming this.
🔗How to Report:
Reports must be submitted electronically via https://www.fic.na/goaml/ or by completing a manual form from www.fic.na and emailing it to helpdesk@fic.na.
Screening Clients Against UN Sanctions Lists
All new and existing clients, as well as all transactions, must be screened against the UNSC Sanctions List. What you need to look for:
Individuals or entities linked to terrorism or proliferation activities.
Persons or organisations subject to targeted financial sanctions.
Actions to Take When Dealing with Suspicious Clients
If a client or transaction matches a name on the UN Sanctions List, accountants and financial institutions must immediately take the following actions:
Freeze Funds and Assets:
Block any funds, accounts, or assets owned, controlled, or linked to the sanctioned person or entity.
Do not notify the client about the freeze before reporting to the FIC.
Report to the FIC Without Delay:
Submit an official notification to the FIC detailing the frozen assets and the reason for suspicion.
Report any attempted transactions by sanctioned individuals or entities.
Failure to comply is a criminal offence under the Prevention and Combating of Terrorist and Proliferation Activities Act (PACOTPAA).
Important Compliance Reminders for Accountants
Document and prove compliance – Accountants must retain records of their screening activities and provide proof to the FIC upon request.
Regularly check UNSC Sanctions Updates – The UN Security Council frequently updates its list, and firms must ensure ongoing compliance.
Failure to comply can lead to serious penalties under Section 63 of the FIA.
Subscribe for automatic updates from the UNSC:
Send an email to sc-sanctionslists@un.org to receive notifications when the sanctions list is updated.
Consequences of Non-Compliance
Engaging in business with a sanctioned individual or entity, even unknowingly, can result in:
Criminal charges, heavy fines, and regulatory sanctions.
Severe reputational damage and loss of professional accreditation.
Take Action Now
Review your firm’s client screening processes.
Train your staff to recognize and report suspicious transactions.
Regularly update compliance measures to align with FIC guidelines.
Submit reports timeously to avoid penalties.
For full details, visit www.fic.na or contact the FIC Help Desk at helpdesk@fic.na.
