RISK AND COMPLIANCE SCREENING:
UNDERSTAND YOUR DUTIES
In terms of the Namibian Financial Intelligence Act of 2012 (FIA) and the Namibian Prevention and Combating of Terrorist and Proliferation Activities Act of 2014 (PACOTPAA), Accountable and Reporting Institutions (AIs and RIs) are obliged to screen their clients as follows:
AIs and RIs must screen their individual and entity clients (which include all beneficial owners and persons acting on behalf of the client):
1. for compliance with United Nations sanctions and
2. for determining their client’s risk profile (i.e. to assist them in understanding the money laundering / terrorist financing / proliferation financing risk the client poses and to obtain the correct information from the client and perform the required level of transaction / activity monitoring) .
1. Sanctions compliance
Sanctions compliance obligations must be fulfilled on an ongoing basis. This means that all clients must be screened continuously / every time changes to sanctions lists are published in the Government Gazette .
2. Client risk profiling
AIs and RIs must determine the money laundering and terrorist / proliferation financing risk posed by their clients and fulfil their customer due diligence and monitoring activities accordingly. This means:
AIs and RIs have to screen all their clients to -
2.1 identify Politically Exposed Persons
2.2 consider adverse media
2.3 consider involvement in criminal activities such as, fraud, money laundering, trafficking (of people, drugs, weapons and/or other items), terrorism or supporting terrorism, corruption and/or organised crime.