New FIC Guidance on Prominent Influential Persons: What You Need to Know
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The Financial Intelligence Centre (FIC) has issued Guidance Note No. 01 of 2026: Guidance on the Identification and Treatment of Prominent Influential Persons (PIPs).
The revised Guidance Note, issued in August 2026, replaces the 2019 guidance on Politically Exposed Persons (PEPs) and provides important clarification on how accountable institutions must identify and manage relationships involving Prominent Influential Persons (PIPs), their family members and close associates.
For CIBA members working in accounting, tax, advisory, trust, company and compliance environments, the message is important: PIP compliance is broader than simply asking whether a client is a politician.
From “PEP” to the broader concept of “PIP”
Under the Financial Intelligence Act, 2012 (FIA), a PIP is a person who holds, or previously held, a prominent public position or function in Namibia or another country. It also includes persons entrusted with prominent positions in international organisations. The FIC confirms that the term PIP encompasses persons traditionally regarded as Politically Exposed Persons under FATF standards.
Namibia's definition is deliberately broad.
Schedule 6 includes, amongst others, heads of state and government, ministers and senior politicians, members of Parliament, significant political-party officials, local and regional councillors, senior management and board members of public-owned enterprises, judicial officers, ambassadors, high-ranking military officers, traditional leaders, religious leaders and senior executives of international organisations operating in Namibia.
Religious leaders deserve particular attention
One of the noteworthy clarifications in the 2026 Guidance Note concerns religious leaders.
The FIC describes a religious leader as someone holding an ordained, appointed, elected or otherwise formally recognised position in a religious or faith-based organisation who, through that position, exercises significant authority, seniority or influence over the organisation, its members, resources or the wider community.
Importantly, this influence may exist at national, regional or even congregational level.
This means institutions should not rely merely on a person's title. The actual level of seniority, authority and influence must be considered. The Guidance Note provides examples across Christianity, Islam, Judaism, Buddhism and Hinduism, while making it clear that comparable senior figures in other religions may also fall within the category.
What about senior executives of private companies?
Schedule 6 refers to senior executives of private entities where those entities have such turnover as may be prescribed.
However, the FIC confirms that no turnover threshold had been prescribed at the date of publication of the Guidance Note.
Until this changes, identification should therefore not simply be driven by a turnover figure. Where customer due diligence identifies a senior executive of a private entity presenting elevated risk — considering factors such as its activities, sector, ownership structure or the individual's influence — the institution should apply its risk-based approach.
This is an important distinction for accountants advising larger private businesses.
Family members and close associates cannot be ignored
The compliance obligation does not end with the PIP.
The Guidance Note gives a broad meaning to family members, including spouses or partners, siblings and their spouses, children, including biological, adopted and stepchildren of any age, children's spouses or partners, and parents, including adoptive and step-parents.
“Close associates” can extend even further.
They may include business partners, joint beneficial owners, fellow trustees or founders of trusts, persons holding structures established for a PIP's benefit, known close friends, persons in intimate relationships outside the family unit, and certain persons sharing prominent positions or business/legal arrangements with a PIP.
A family member or close associate does not technically become a PIP in their own right, but the FIA requires them to be subjected to equivalent scrutiny.
For CIBA members conducting client acceptance and beneficial ownership procedures, this distinction is particularly important.
Perhaps the biggest compliance message: there is one standard for PIPs in Namibia
The Guidance Note highlights an important difference between the international FATF approach and Namibia's domestic legislative framework.
Under FATF Recommendation 12, enhanced measures distinguish between foreign PIPs and domestic or international-organisation PIPs. Namibia's FIA does not adopt that triggering distinction.
Once a client or beneficial owner has been identified as a PIP, the measures prescribed under section 23A(2) apply. This is true irrespective of whether the person is a domestic or foreign PIP.
In other words: Risk determines how intensely the measures are applied, not whether they are applied at all.
That is likely to be one of the most important practical principles for CIBA members to incorporate into their compliance frameworks.
The three mandatory measures
Once a client or beneficial owner is identified as a PIP, an accountable institution must apply three key controls:
Obtain senior-management approval before establishing a new business relationship or continuing an existing one.
Apply enhanced ongoing monitoring to the relationship.
Take measures to establish the source of wealth and source of funds, as far as reasonably possible.
A lower-risk assessment does not eliminate these requirements. Instead, it allows the institution to adjust the depth, extent and documentation of the measures proportionately.
This distinction should be reflected clearly in an accountable institution's Risk Management and Compliance Programme and operational procedures.
A signed source-of-funds declaration is not enough
This is another significant practical point.
The FIC expressly states that the source-of-wealth and source-of-funds obligation is not discharged merely by obtaining a signed declaration from the customer.
The information should be corroborated.
For public office holders, this can include testing whether the client's explanation is plausible when compared with known or reasonably expected remuneration, published public-service salary scales, remuneration frameworks or available asset and interest declarations. Where an explanation appears implausible, the discrepancy must be pursued and the enquiries, evidence and conclusion recorded on the client file.
The Guidance Note usefully distinguishes:
Source of wealth asks: How did this person accumulate their overall wealth?
Source of funds asks: Where did the money involved in this particular transaction come from?
Possible evidence includes salary or pension records, business ownership and dividend records, inheritance or trust documents, property and investment records, financial statements and tax records for wealth; and bank statements, payslips, sale agreements, financing agreements or investment payout documentation for particular funds.
Persistent inability to understand or establish the source of wealth or funds is itself identified as a risk indicator that may warrant escalation or a suspicious transaction/activity report.
There is no official FIC “PIP list”
Members should also be careful about the assumption that compliance can simply be achieved by checking a database.
The FIC states that it does not maintain, endorse or provide a PIP register or database. Commercial screening systems may be used, but the FIC does not prescribe or endorse a particular product.
Instead, institutions may use a combination of current customer due-diligence information, employee and internal declarations, credible internet and media searches, commercial databases, government-issued information and asset-disclosure systems, and their own internal records.
Even customer self-declaration is only part of the process. The FIC specifically states that self-declaration alone is insufficient and should be tested against other information sources.
PIP screening is not a once-off onboarding exercise
An individual who was not a PIP when the client relationship began may subsequently become one.
The Guidance Note therefore requires appropriate systems capable of identifying PIP status both at onboarding and throughout the business relationship, including screening the client and beneficial owner and detecting changes in beneficial ownership or status.
Trigger events for an out-of-cycle review may include unusual or significant transactions, changes in position or influence, new adverse information, changes in beneficial ownership or transactions inconsistent with the client's expected profile.
Does someone stop being a PIP when they leave office?
No — not automatically.
The 2026 Guidance Note states that there is no fixed “cooling-off” or declassification period after leaving office.
Instead, what may change over time is the person's risk. Some former office holders may lose influence rapidly; others may retain networks, influence or beneficial relationships for years. Institutions must therefore assess residual risk individually.
Even a person appointed temporarily or in an acting capacity to a position involving a prominent public function must be identified as a PIP during that appointment, with residual risk continuing to be assessed thereafter.
What should CIBA members do now?
Members operating as accountable institutions, compliance officers or advisers to accountable institutions should review their existing AML/CFT/CPF procedures against the new Guidance Note.
In practical terms, attention should be given to whether client onboarding forms use the broader PIP terminology; whether beneficial owners, family members and close associates are adequately addressed; whether PIP identification continues after onboarding; whether senior-management approval is properly documented; whether source-of-wealth and source-of-funds information is corroborated rather than merely declared; whether monitoring intensity is linked to documented risk; and whether former PIPs remain appropriately assessed.
Members should also consider whether staff have been trained on the considerably broader categories that may constitute PIPs under Namibian law.
The key takeaway
Being identified as a PIP is not an allegation of criminality.
Indeed, the Guidance Note explains that senior-management approval exists to ensure accountable and informed decision-making about higher-exposure relationships — not because the PIP is presumed to be a criminal.
The purpose is risk management.
For professional accountants, this requires a careful balance: do not stigmatise the client, but do not dilute the statutory controls either.
The 2026 Guidance Note makes that balance clearer. Once PIP status is identified, the statutory measures apply. The risk-based approach then determines how deeply, frequently and extensively those measures should be performed and documented.
For CIBA members, that means PIP compliance should no longer be treated as a checkbox asking, “Are you a politician?”
It should form part of an integrated process involving client identification, beneficial ownership, source of wealth, source of funds, ongoing monitoring, professional judgement and documented risk assessment.
This article is intended as a technical member update based on FIC Guidance Note No. 01 of 2026 and does not constitute legal advice. The FIC notes that the Guidance Note assists accountable institutions with compliance, while the FIA, Regulations and applicable Directives prevail in the event of inconsistency.
