Namibia

Section 6(1)(b) prohibits prejudice to an employee for past, present or anticipated disclosure of information the employee is entitled or required to give, and s 33(2)(a) makes a dismissal for that reason unfair. No dedicated whistleblowing channel duty was found in the sections read.

Section 48(1) requires a public officer offered or given gratification in breach of the Chapter to report it to their supervisor and the Commission; s 48(2) requires anyone who demanded, accepted or tried to obtain gratification to report it. Failure to report is an offence (s 48(3)).

Section 18 requires the originating provider to obtain and send originator and beneficiary information with a transfer, and the beneficiary provider to obtain and keep originator and accurate beneficiary information. Breach carries up to N$10 million and 10 years' imprisonment (s 18(6)).

Section 7(1) bars a person from operating as a virtual asset service provider without meeting the listed conditions and holding a licence under the Act; s 7(2) sets a fine of up to N$10 million and up to 10 years' imprisonment. Section 54 requires existing providers to apply within three months of commencement.

Section 20A(1)-(2) requires regular ML/TF/PF risk assessment, including of new products and technologies before launch. Sections 20A(4)-(5) require a customer acceptance policy and internal programmes approved by senior management, s 20A(6) lists programme contents including an independent audit function, and s 20A(7) requires a management-level compliance officer who is ordinarily resident in Namibia.

Section 21(2) bars establishing a business relationship or concluding a single transaction until the client's identity, the beneficial owner and any agent's authority are established. Section 23(1A) requires a risk profile for each client, updated during ongoing due diligence, and s 24(1) requires information to be kept current and transactions monitored, with duties for high-risk and correspondent banking relationships.