The Importance of complying with AML requirements and reporting suspicious transactions

By Njeri Siska*

Head: Anti-Money Laundering at Bank Windhoek

Often Banks receive questions about why Anti-Money Laundering, Combatting Terrorist and Proliferation Financing (AML) requirements such as Know Your Customer (KYC) and Enhanced Due Diligence requirements are necessary.

Whilst these obligations may seem cumbersome in the normal course of day-to-day activities, we must remember that criminals rely on funding to conduct their operations. The primary objective for all the AML requirements imposed on the banks as per the Financial Intelligence Act, 13 of 2012 (FIA) is to report Suspicious Transactions and /or Activities Reports (STR/SAR's) so as to enable law enforcement and prevent criminals from completing or benefiting from the proceeds of their activities. These requirements also protect Bank Windhoek from being used as an institution to launder illicit funds.

Bank Windhoek and Capricorn Group has a zero tolerance policy for corruption and non-compliance with the laws of Namibia.

The latest statistical report from the Bank of Namibia's Financial Intelligence Centre (FIC) indicates that Tax Evasion remains the leading potential offence in all the suspicious reports finalised. This feedback is demonstrative of how STR/SAR's not only assist law enforcement but also protect the Namibian economy from losing funds through illicit activities.

It is therefore the duty of the general public, especially businesses to appreciate that requirements such as KYC are the foundation which assist banks to combat financial crime, decrease the risk of proceeds of crime being cleaned through Namibia's financial system.

What are suspicious transactions and activities?

From a Bank's perspective, when it turns out there is no match between the client's profile i.e. KYC information and the transaction in question, such transaction is considered to be suspicious. An example of such a scenario may be when a client's source of funds are not aligned to the transaction in question or when there is no identification documentation availed. In such cases the Bank may report an STR or SAR to the FIC.

When should you report a STR/SAR's?

The fight against financial crime is a responsibility for not only banks but for every citizen and resident of Namibia. With this core understanding, if you have knowledge of any suspicious activity/ transaction concluded in any business, or suspect that a business received or is about to receive the proceeds of unlawful activities, you must without delay, after the suspicion or belief concerning the transaction/activity that gave rise to the requirement to report the same to the FIC.

Are you as a reporter protected?

In terms of section 50(2) of the FIA, the identity of a person that provides information as well as the information provided is confidential and thus may not be disclosed unless it is done to assist the FIC.

How should you submit an STR/SAR?

In terms of Regulation 20 of the FIA, a report must be made by means of the internet -based reporting available on the FIC website at In exceptional cases where a person does not have the technical capability to make a report electronically, that person may complete the forms in Annexures 1 and 2 of the Regulations and send it by facsimile to the Centre on +264(61) 2835687/ 6918/5922 or hand deliver it to the Centre at 71 Robert Mugabe Avenue, Windhoek.​

*Njeri Siska is the Head: Anti-Money Laundering at Bank Windhoek

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