2025-12-04

NBFIRA Model Anti-Money Laundering and Counter-Terrorism Financing Policy

The Non-Bank Financial Institutions Regulatory Authority (NBFIRA) has issued a model Anti-Money Laundering, Counter-Terrorism Financing and Proliferation (AML/CFT&P) policy for Non-Bank Financial Institutions. The directive requires these entities to document comprehensive AML/CFT&P frameworks tailored to their specific business conditions, operations, and risk profiles. Institutions may reference the accompanying guidance note while maintaining customized policy versions where standard language proves insufficient for their operational context.

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Botswana

Non-Bank Financial Institutions Regulatory Authority

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3rd floor Exponential Building Plot 54351 CBD off PG Matante Road Gaborone Private Bag 00314 Gaborone Botswana Telephone: +267 310 2595 / 368 6100 Facsimile: +267 310 2353 / 310 2376 Website: www.nbfira.org.bw

[Logo: NBFIRA Non Bank Financial Institutions Regulatory Authority]

April 15, 2024

NBFIRA 3/3/10-I (98)

To: AMLCOs/Principal Officers - Non-Bank Financial Institutions

A MODEL POLICY FOR ANTI-MONEY LAUNDERING AND COUNTERING FINANCING OF TERRORISM AND PROLIFERATION

  1. In line with the Non-Bank Financial Institutions Regulatory Authority’s (the Authority) ongoing commitment to enhance the effectiveness of anti-money laundering, combatting the financing of terrorism and proliferation (AML/CFT/P) measures, the Authority hereby disseminates the attached AML/CFT & P model policy.

  2. This model policy aims to provide comprehensive instructions/guidance and methodologies to assist Small, Medium and Micro Enterprises in documenting a thorough and effective AML/CFT&P policy. If any language does not adequately address an entity’s business condition in any respect, NBFIs are required to have a tailor-made version of their specific institutional frameworks, operations and identified risks.

  3. NBFIs may refer to the guidance note Documenting a policy for Anti-Money Laundering / Combatting the financing of Terrorism and Proliferation for further guidance.

  4. Kindly contact the AML/CFT Department at amlcft@nbfira.org.bw for further clarification.

Yours sincerely

[Signature]

Mooketsi Ramanteba Director - AML/CFT

NON-BANK FINANCIAL INSTITUTIONS REGULATORY
AUTHORITY
3RD FLOOR EXPONENTIAL BUILDING
PLOT 54351 NEW CBD
PRIVATE BAG 00314 GABORONE BOTSWANA
PHONE:+267 310 2595/+267 3686100 FAX:+267 310 2376

Directors: H. Hlanti K. S. Gaamangwe L. Maruping Dr. L. Senatla P. Masalela