Namibia Loses N$16.7 Billion to Illicit Financial Flows
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Namibia is estimated to have lost approximately N$16.7 billion through Illicit Financial Flows (IFFs) between 2022 and 2024 — equivalent to around 9% of the country’s nominal Gross Domestic Product (GDP).
The figure highlights not only a significant challenge to Namibia’s domestic revenue base, but also an increasingly important area of responsibility for accountants, tax practitioners, auditors, compliance professionals and business leaders.
Following Cabinet approval, the Ministry of Finance issued a press release on the results of Namibia’s assessment of Illicit Financial Flows, undertaken through a national Technical Working Group led by the Bank of Namibia, with technical assistance from the United Nations Conference on Trade and Development (UNCTAD).
The assessment involved NamRA and numerous Government Offices, Ministries and Agencies and applied internationally recognised UNCTAD methodologies using Namibian statistics.
The resulting estimate is significant: IFFs amounted to approximately 9% of Namibia’s GDP during the 2022–2024 period.
What are Illicit Financial Flows?
Illicit Financial Flows generally refer to money that is illegally earned, transferred or used across borders, or transactions where the true origin, destination, ownership or purpose of funds is concealed.
IFFs can arise through a range of activities, including:
tax evasion;
trade misinvoicing;
corruption and bribery;
money laundering;
proceeds of criminal activities;
abusive or unlawful cross-border arrangements; and
structures intended to conceal the true ownership, destination or purpose of funds.
For accountants, however, an important distinction must be maintained.
Not every cross-border transaction, tax-efficient structure or legitimate tax-planning arrangement constitutes an illicit financial flow.
The legality, commercial substance, documentation, disclosure and tax treatment of a transaction remain critical considerations. Practitioners should therefore be careful not to automatically equate legitimate tax planning with tax evasion or other illicit conduct.
NDP6: Reducing IFFs to 5% of GDP by 2030
Namibia's Sixth National Development Plan (NDP6) has now established a specific national target: reducing Illicit Financial Flows from the estimated N$16.7 billion, or 9% of nominal GDP, to 5% of GDP by 2030.
This aligns Namibia with broader international efforts under the Sustainable Development Goals to strengthen domestic resource mobilisation and combat illicit financial flows.
The significance of the N$16.7 billion estimate extends beyond tax collection.
Money lost through illicit financial activity represents resources that could otherwise contribute to infrastructure, healthcare, education, social development and other public priorities.
It also affects legitimate businesses.
Businesses that comply with tax, customs, exchange-control and regulatory requirements may find themselves competing against operators who deliberately conceal income, manipulate transactions or move funds outside legitimate financial channels.
Combating IFFs is therefore not merely a revenue issue. It is also a question of fair competition, good governance and economic integrity.
Namibia strengthens its regulatory framework
Government has indicated that several legislative measures have been strengthened since 2023 to address trade-related money laundering and illicit financial flows.
These include amendments and developments relating to the:
Financial Intelligence Act;
Prevention of Organised Crime legislation;
Virtual Assets Act;
Payment Systems Management Act; and
Banking Institutions Act, among others.
Tax measures have similarly been strengthened to address weaknesses that could facilitate the movement of funds without the appropriate tax consequences.
Authorities have also invested in additional capacity for investigators and prosecutors dealing with complex financial investigations, tracing of assets and recovery of criminal proceeds.
The national IFF assessment brought together institutions including the Bank of Namibia, Namibia Revenue Agency, Financial Intelligence Centre, Anti-Corruption Commission, BIPA, NAMFISA, Namibia Statistics Agency, NamPol, Office of the Prosecutor-General and other government institutions.
This multi-agency approach is particularly important because illicit financial flows rarely fall neatly within the jurisdiction of a single regulator.
A suspicious transaction may simultaneously involve tax, beneficial ownership, customs, banking, anti-money-laundering, company law and criminal-law considerations.
Recoveries are already being made
According to the Ministry of Finance, enforcement efforts have begun producing measurable results.
Authorities reportedly recovered more than N$28 million in taxes during 2025, while a single investigation during 2026 resulted in the recovery of more than N$45 million.
While these recoveries are encouraging, they must be considered against the estimated N$16.7 billion scale of the problem.
The national assessment is therefore particularly valuable because it moves Namibia beyond merely acknowledging the existence of illicit financial flows. It provides authorities with information about the sectors, commodities and trading activities most vulnerable to them.
This should enable more targeted investigations, enforcement activities, policy interventions and revenue-recovery initiatives.
What does this mean for CIBA members?
The fight against illicit financial flows will increasingly reach the desks of accounting professionals.
Accountants frequently occupy positions where unusual financial activity becomes visible long before it reaches a regulator.
We prepare financial statements. We analyse ledgers. We process tax returns. We examine invoices. We advise on company structures. We reconcile bank accounts. We deal with related-party transactions and cross-border payments. We maintain beneficial ownership information and, in many cases, assist businesses with their regulatory obligations.
That places the profession in a unique position — but it also creates responsibility.
CIBA members should remain particularly alert to transactions that lack clear commercial substance, unexplained payments to foreign entities, unusual related-party transactions, inconsistent invoicing, discrepancies between customs and accounting records, unexplained changes in ownership structures, payments routed through multiple jurisdictions without apparent commercial justification, and transactions inconsistent with a client's normal business activities.
Professional scepticism should not be confused with suspicion of every client.
Rather, it means asking the necessary questions, obtaining appropriate supporting documentation and ensuring that the accounting records accurately reflect the economic substance of transactions.
The accountant as a gatekeeper of financial integrity
The N$16.7 billion estimate should serve as an important reminder that accountants are no longer simply recordkeepers.
Increasingly, the profession operates at the intersection of taxation, governance, anti-money-laundering compliance, beneficial ownership transparency and financial crime prevention.
This means practitioners must understand not only whether a transaction has been correctly recorded, but also whether its underlying economic rationale makes sense.
Where something does not make sense, asking questions is part of our professional responsibility.
Where documentation is inadequate, we should insist on proper evidence.
Where legal or reporting obligations arise, those obligations must be understood and appropriately addressed.
And where practitioners encounter matters outside their expertise, obtaining specialist legal, tax, forensic or compliance advice may be necessary.
Integrity starts with accurate information
Government has also called on taxpayers to contribute to the fight against illicit financial flows by honestly declaring their tax affairs.
For the accounting profession, the message extends further.
Accurate accounting records, transparent ownership structures, properly supported transactions and ethical tax compliance are fundamental components of a functioning financial system.
Reducing Namibia's illicit financial flows from 9% to 5% of GDP by 2030 will require more than legislation and enforcement.
It will require cooperation between regulators, businesses, financial institutions and professionals.
Accountants are part of that defence.
Every correctly recorded transaction, every unexplained discrepancy questioned, every beneficial owner properly identified and every tax position supported by law contributes to the integrity of Namibia's financial system.
The N$16.7 billion estimate is therefore not simply a government statistic.
It is a governance challenge — and one in which the accounting profession has an important role to play.
CIBA Namibia encourages members to remain informed of developments relating to taxation, beneficial ownership, anti-money-laundering requirements and financial crime prevention, and to maintain the highest standards of professional conduct when advising clients and employers.
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