FIC Issues Multiple Updates to Screening, Reporting and Legal Duties
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The Financial Intelligence Centre (FIC) has issued three major compliance updates in 2025 (Circulars 02, 03, and 06) that affect all Accountable Institutions (AIs), Reporting Institutions (RIs), businesses, and even individuals.Who’s affected?
Any person, business, organisation, AI or RI operating in Namibia must comply with the Financial Intelligence Act, 2012 (FIA) and the Prevention and Combating of Terrorist and Proliferation Activities Act, 2014 (PACOTPAA) when it comes to terrorist and proliferation financing.
What’s changed?
12 March 2025 – ISIL (Da’esh) & Al-Qaida list updated (Circular 02).
10 June 2025 – Certain individuals/entities removed from the ISIL (Da’esh) & Al-Qaida list (Circular 03).
5 August 2025 – Iraq (1518) Sanctions List updated (Circular 06).
Key legislative requirements
FIA Section 33 – AIs and RIs must report Suspicious Transactions (STRs), Suspicious Activities (SARs) and nil returns relating to terrorist and proliferation financing.
FIA Section 9(1)(h) – FIC may issue directives and circulars to enforce compliance.
FIA Section 63 – Non-compliance with FIC directives is an offence.
PACOTPAA Sections 22–25 – Require:
Freezing of all funds, assets, and resources owned or controlled (directly or indirectly) by listed persons/entities.
Immediate action without prior notice to the client.
Reporting frozen assets, attempted transactions, and matches to the FIC.
Maintaining proof of screening even when no matches are found.
PACOTPAA Section 22(2) – When a person/entity is removed from the sanctions list, previously frozen assets must be unfrozen without delay.
PACOTPAA Section 2 – Prohibits dealing with funds or assets linked to listed persons/entities.
When You Must Report to the FIC
You must report immediately when:
There is a positive match – Freeze assets without delay and file a Sanction Name Match Activity Report (SNMA) via goAML.
Suspicious activity/transaction is detected – File a Terrorist & Proliferation Financing Activity Report (TFPA) or a Terrorist & Proliferation Financing Transaction Report (TPFT).
A delisting occurs – If you previously froze assets, you must unfreeze them and inform the FIC.
No matches occur – Keep proof of screening and be ready to provide it if requested.
Even no Matches Matter
You must still keep evidence that every client and transaction has been screened against the latest UN lists.
Non-compliance = Serious consequences
Failing to comply is an offence under FIA and PACOTPAA, exposing you to criminal penalties and severe reputational damage.
Action steps for accountants
Subscribe to UN sanctions list updates: sc-sanctionslists@un.org (free).
Check the latest list here: UNSC Consolidated List.
Screen every client (new and existing) and all transactions.
File reports via goAML.
Keep detailed records of screenings and any actions taken.
This is not just a tick-box exercise — missing a match or failing to unfreeze when required could lead to prosecution and high-risk exposure to terrorist financing and proliferation activities.
