The UNSC List Just Changed. Have You Screened Yet?
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The Namibian FIC has issued Circular No. 05 of 2026 on 14 April 2026, notifying all accountable institutions (AIs) and reporting institutions (RIs) that the United Nations Security Council (UNSC) 1988 Sanctions Committee list was updated on 13 April 2026. That means your existing client screening is potentially out of date right now.
What Changed?
The FIC is not circulating the sanctions update for information purposes only. Under the Financial Intelligence Act 2012 (Act 13 of 2012) and the Prevention and Combating of Terrorist and Proliferation Activities Act, 2014 (PACOTPAA), every Accountable Institution is legally required to screen clients against the updated list, and to act on any matches immediately.
The updated 1988 Sanctions Committee list can be accessed at: https://main.un.org/securitycouncil/sanctions/1988/aq_sanctions_list
Press releases detailing the specific changes are available at: https://main.un.org/securitycouncil/sanctions/1988/press-releases
Your Three Obligations Triggered Again
Screen all clients against the updated list today.
Every update to the UNSC sanctions lists restarts the clock on your screening obligation. This is continuous, not once-off. The 13 April 2026 change means your last screening round may already be incomplete.
If you find a match freeze immediately.
No waiting. No checking with a senior partner. No prior notice to the client. Under section 25 of the PACOTPAA, you must freeze any funds, assets, or economic resources linked to a matched person or entity, including accounts, joint assets, and anything derived from those funds. Then report the freeze to the FIC without delay.
Prove you screened, even with no match found.
You must maintain documented proof that screening occurred against this updated list, even if you found no positive match. This is not optional documentation, it is a regulatory requirement.
How to Report
Three report types are available for suspicious transactions linked to terrorism or proliferation financing:
Sanction Name Match Activity Report (SNMA)
Terrorist and Proliferation Financing Activity Report (TFPA)
Terrorist and Proliferation Financing Transaction Report (TPFT)
Reports can be submitted electronically via the FIC's GoAML system at https://www.fic.na/goaml/, or by manual form to helpdesk@fic.na.
A Practical Step You Can Take Right Now
Subscribe to the UNSC's free email update list so you never miss a change. Send a subscription request to sc-sanctionslists@un.org. You'll receive automatic notifications of all additions, amendments, and deletions, before the next FIC circular lands in your inbox.
Non-compliance with this circular is a criminal offence under section 63 of the FIA. Providing services to a sanctioned individual, because you failed to screen, doesn't reduce your liability. It establishes it.
