Comments on article ‘Requirements Could Impede Financial Services for the Poor’
The above article published in your daily newspaper on the 1st of August 2007, bears reference.
This letter serves as a feedback from the Financial Intelligence Centre (FIC), Bank of Namibia (BON), on the comments made by Nepru researcher, Jonathan Andongo, on the Know Your Customer (KYC) requirements as stipulated in the Financial Intelligence Act, Act No. 3 of 2007 ( FIA).
We wish to comment as follows:
The BON has studied in great detail the implementation of KYC obligations as regards Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) in a number of countries.
Since last year, the BON and the Ministry of Finance have been in consultation with International Anti-Money laundering experts and various Namibian Financial Institutions, regarding the AM/CFT measures, as mandated by the FIA. These consultations included the KYC concerns raised by the NEPRU researcher in abovementioned article.
These consultations focused and are still focusing on the drafting of regulations to implement the FIA in a graduated and measured manner, which takes into consideration the time and resources required by the concerned Supervisory Bodies, Accountable Institutions and their clients.
The BON and the Ministry of Finance attempted to find uniquely Namibian solutions to comply with international AML/CFT standards on the one hand, whilst on the other hand ensuring that Namibian citizens and residents enjoy the financial services they need, no matter the size of their account balances or the value of their transactions.
This means that the KYC requirements will be designed in a manner not to disadvantage clients from the rural areas, who will find it difficult to comply with requirements such as providing a municipal bill or a residential address.
With the desire for transparency, the BON and the Ministry of Finance will make available the draft FIA regulations and exemptions for comment by the relevant Supervisory Bodies and Accountable Institutions, prior to their enactment.
Should the need arise for any further particulars, please do not hesitate to contact our office.
Leonie Dunn (MS)
Director: Financial Intelligence Centre
Bank of Namibia