New Obligations Under the Namibian FIC's Latest Circular
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The Financial Intelligence Centre of Namibia has issued a fresh reminder that all accountable and reporting institutions must screen their clients against international sanctions lists — and failure to do so is a criminal offence.
What Is This About?
On 24 March 2026, the Namibian FIC issued Circular No. 02 of 2026, reminding all accountable institutions (AIs and reporting institutions (RIs)) — including accounting practices, bookkeepers, and tax practitioners — of their obligations to screen clients against United Nations Security Council (UNSC) sanctions lists and report suspicious activity related to terrorism financing or weapons proliferation.
If you handle financial transactions on behalf of clients in Namibia, this circular applies to you.
What Are Sanctions Lists?
The UNSC maintains lists of individuals, organisations, and entities subject to international sanctions, aimed at preventing money and financial services from reaching those involved in terrorism or weapons proliferation. If a client or anyone connected to your client appears on one of these lists, you are legally required to act immediately.
The latest UNSC consolidated sanctions list can be found here: https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list.
Your Three Key Obligations
Screen all clients — continuously You must screen all clients and all transactions against the UNSC sanctions lists on an ongoing basis. Every time the lists are updated, you need to check again.
If you find a match — freeze immediately If a client or connected party appears on a sanctions list, you must immediately freeze any funds, assets, or economic resources linked to them — without waiting for further instruction. Report the freeze to the FIC without delay.
Prove you screened — even if you found nothing You must maintain documented proof that screening was carried out, regardless of whether a match was found.
How to Report Suspicious Activity
Three report types are available: a Sanction Name Match Activity Report (SNMA), a Terrorist and Proliferation Financing Activity Report (TFPA), or a Terrorist and Proliferation Financing Transaction Report (TPFT).
Reports can be filed electronically at the FIC GoAML system or by submitting manual forms to helpdesk@fic.na.
The Consequences of Non-Compliance
Failure to screen, freeze, or report is a criminal offence under the Financial Intelligence Act. If you provide services to a sanctioned individual simply because you did not screen properly, you expose your practice to criminal liability and serious reputational damage.
