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The Financial Intelligence Centre (FIC) of Namibia has published Guidance Note 01 of 2026 on Prominent Influential Persons (PIPs) in a version dated October 2026. The note states an operational date of December 2026. AW covered the guidance note on 7 September 2026, when it was reported as issued in August 2026. The October note is labelled a revision, but its version history does not list an August version. It also adds the operational date and covers life insurance payouts.
What changed
The October 2026 version states that the note becomes operational in December 2026.
It replaces Guidance Note 01 of 2019 on politically exposed persons.
The FIC issued it under section 9(1)(h) of the Financial Intelligence Act, 2012.
The note does not mention a comment period.
The note sets out four duties under section 23A of the FIA:
Keep systems to detect PIPs, their family members and close associates, at onboarding and during the relationship, for both the client and the beneficial owner.
Obtain senior management approval before opening or continuing the relationship.
Establish source of wealth and source of funds, checked against documents. A signed declaration alone is not enough.
Apply enhanced ongoing monitoring.
A person does not stop being a PIP on leaving office. The note sets no cooling-off period; the institution assesses residual risk instead. A person in an acting appointment is a PIP during that appointment, and the end of the appointment does not by itself end the PIP measures. The note cites the FATF view that foreign PIPs are always high risk, but says the FIA applies the same mandatory measures to all PIPs; whether a PIP is foreign or domestic matters for risk assessment only.
Who it affects
Accountable institutions under the FIA, including life insurers paying out to beneficiaries.
What this means for accountants and finance professionals
The note becomes operational in December 2026; the section 23A duties in the Act already apply.
Family members and close associates get the same scrutiny as the PIP, although they are not PIPs themselves.
Former office holders stay in scope; review frequency can reduce only where the practice's own policy allows.
Source of wealth must be supported by documents, not only a client declaration.
What to do
Read the October 2026 version and compare it with the version AW reported in September.
Update onboarding forms to identify PIPs, family members and close associates.
Set a documented senior approval step for PIP clients.
Diarise December 2026 as the operational date.
Sources: FIC Guidance Note 01 of 2026 (PDF), FIC Namibia home page