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Why it is necessary for Namibian banks to comply with Anti-Money Laundering requirements

Why it is necessary for Namibian banks to comply with Anti-Money Laundering requirements

By Njeri Siska, Head: Anti-Money Laundering at Bank Windhoek

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

While 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/SARs) to enable law enforcement and prevent criminals from 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/SARs not only assist law enforcement but also protect the Namibian economy from losing funds through illicit activities.

It is therefore necessary that the general public, especially businesses, appreciate that requirements such as KYC are the foundation which assist banks to combat financial crime, and to 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/SARs?

The fight against financial crime is a responsibility not only for banks but for every citizen and resident of Namibia. Within this core understanding, if you have knowledge of any suspicious activity or 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, report 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 channel 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.


Following reverse listing, public can now acquire shareholding in Paratus Namibia


20 February 2020, Windhoek, Namibia: Paratus Namibia Holdings (PNH) was founded as Nimbus Infrastructure Limited (“Nimbus”), Namibia’s first Capital Pool Company listed on the Namibian Stock Exchange (“NSX”).

Although targeting an initial capital raising of N$300 million, Nimbus nonetheless managed to secure funding to the value of N$98 million through its CPC listing. With a mandate to invest in ICT infrastructure in sub-Sahara Africa, it concluded management agreements with financial partner Cirrus and technology partner, Paratus Telecommunications (Pty) Ltd (“Paratus Namibia”).

Paratus Namibia Managing Director, Andrew Hall

Its first investment was placed in Paratus Namibia, a fully licensed communications operator in Namibia under regulation of the Communications Regulatory Authority of Namibia (CRAN). Nimbus has since been able to increase its capital asset base to close to N$500 million over the past two years.

In order to streamline further investment and to avoid duplicating potential ICT projects in the market between Nimbus and Paratus Namibia, it was decided to consolidate the operations.

Publishing various circulars to shareholders, Nimbus took up a 100% shareholding stake in Paratus Namibia in 2019 and proceeded to apply to have its name changed to Paratus Namibia Holdings with a consolidated board structure to ensure streamlined operations between the capital holdings and the operational arm of the business.

This transaction was approved by the Competitions Commission as well as CRAN, following all the relevant regulatory approvals as well as the necessary requirements in terms of corporate governance structures.

Paratus Namibia has evolved as a fully comprehensive communications operator in Namibia and operates as the head office of the Paratus Group in Africa. Paratus has established a pan-African footprint with operations in six African countries, being: Angola, Botswana, Mozambique, Namibia, South Africa and Zambia.

The group has achieved many successes over the years of which more recently includes the building of the Trans-Kalahari Fibre (TKF) project, which connects from the West Africa Cable System (WACS) eastward through Namibia to Botswana and onward to Johannesburg. The TKF also extends northward through Zambia to connect to Dar es Salaam in Tanzania, which made Paratus the first operator to connect the west and east coast of Africa under one Autonomous System Number (ASN).

This means that Paratus is now “exporting” internet capacity to landlocked countries such as Zambia, Botswana, the DRC with more countries to be targeted, and through its extensive African network, Paratus is well-positioned to expand the network even further into emerging ICT territories.

PNH as a fully-listed entity on the NSX, is therefore now the 100% shareholder of Paratus Namibia thereby becoming a public company. PNH is ready to invest in the future of the ICT environment in Namibia. The public is therefore invited and welcome to acquire shares in Paratus Namibia Holdings by speaking to a local stockbroker registered with the NSX. The future is bright, and the opportunities are endless.