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2025-01-21

Implementation of UN Sanctions Lists During the Holiday Season

The Non-Bank Financial Institutions Regulatory Authority (NBFIRA) directs all Non-Bank Financial Institutions to reinforce their monitoring and response procedures for United Nations Sanctions lists during the holiday season. Institutions must ensure real-time list integration into monitoring systems, conduct regular staff training, assign dedicated contacts for immediate action on alerts, and perform thorough customer due diligence during onboarding and high-risk transactions. NBFIRA further requires prompt reporting of suspicious activities to the Financial Intelligence Agency to maintain financial system integrity and sustain anti-money laundering, counter-terrorist financing, and sanctions compliance efforts.

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Botswana

Non-Bank Financial Institutions Regulatory Authority

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December 14, 2023 NBFIRA 3/3/5–II (53) To: AML/CFT Compliance Officers/Principal Officers - NBFIs URGENT ACTION REQUIRED: IMPLEMENTATION OF UNITED NATIONS SANCTIONS LISTS DURING THE HOLIDAY SEASON The Non-Bank Financial Institutions Regulatory Authority (NBFIRA) would like to emphasize the critical importance of maintaining robust mechanisms to receive and promptly act upon United Nations Sanctions lists during the holiday season. It is imperative to recognize that financial crime is a dynamic threat, and criminals do not adhere to holiday schedules. In fact, historical data suggests an increased likelihood of illicit activities during festive periods when vigilance might be compromised due to reduced staffing levels and increased transaction volumes. To safeguard the integrity of the financial system, NBFIRA hereby directs all Non-Bank Financial Institutions (NBFIs) to reinforce and enhance their procedures for monitoring and responding to UN Sanctions lists. This includes but is not limited to:

  1. Ensuring real-time integration of UN Sanctions lists into your monitoring systems.
  2. Conducting regular training sessions for relevant staff to stay abreast of the latest developments in sanctions regimes.
  3. Establishing a dedicated team or point of contact responsible for immediate action upon receiving updates or alerts related to sanctioned entities.
  4. Conducting thorough customer due diligence, especially during the onboarding process and when processing transactions with potential high-risk counterparties. All NBFIs are urged to remain vigilant and report any suspicious activities/transactions to the Financial Intelligence Agency promptly. The cooperation of each stakeholder is crucial in maintaining the integrity of our financial system and fulfilling our commitment to combating financial crime. Your cooperation in implementing and reinforcing these measures is vital in ensuring the continued effectiveness of our anti-money laundering, countering the financing of terrorism and proliferation and sanctions compliance efforts. Thank you for your attention to this matter. Sincerely Signed Mooketsi Ramanteba Director- AML/CFT
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