Updated UN Sanctions Lists for Client Screening
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Namibia’s Financial Intelligence Centre (FIC) has issued Circular 07 of 2026 following changes made to the United Nations Security Council (UNSC) sanctions lists on 21 May 2026. The update relates to the ISIL (Da’esh) and Al-Qaida sanctions regime and affects all accountable and reporting institutions, including accountants, auditors and trust and company service providers.
The FIC reminded institutions that they are required to screen their client databases against the updated sanctions lists to ensure they are not providing designated services to sanctioned individuals or organisations. The obligation applies even where no positive matches are found. Institutions must be able to prove that screening was performed whenever the lists are updated.
Where a match is identified, accountable and reporting institutions must immediately freeze all relevant funds, assets and economic resources without prior notice to the client and report the matter to the FIC without delay. The obligation extends to directly and indirectly controlled assets, jointly owned assets, related economic resources and attempted transactions.
The circular also warns that failure to comply with the requirements may constitute a violation under section 63 of the Financial Intelligence Act.
The FIC encouraged institutions to subscribe directly to UNSC sanctions update notifications to ensure that changes are identified and implemented as quickly as possible.
Important Reminder
The circular is an important reminder that sanctions screening is no longer a compliance exercise limited to banks. Accounting firms that qualify as accountable institutions under Namibia’s anti-money laundering framework must ensure that sanctions screening procedures are properly documented, regularly updated and capable of producing evidence during inspections or compliance reviews.
The notice also highlights the growing focus on terrorist financing and proliferation financing compliance in Southern Africa. Firms should review whether their onboarding procedures, client acceptance controls and ongoing monitoring processes are sufficient to identify sanctioned persons and related parties before services are provided.