Botswana’s Non-Bank Financial Institutions Regulatory Authority (NBFIRA) has issued a guidance note for all supervised entities on when and how Simplified Due Diligence (SDD) measures may be applied under the Financial Intelligence Act, 2022. The note clarifies that SDD is a risk-based adjustment to customer due diligence (CDD) rather than an exemption, and it forms part of NBFIRA’s compliance expectations from 2 October 2025. Developed under NBFIRA’s statutory mandate as a supervisory authority (including consultation requirements involving the Financial Intelligence Agency), the guidance aims to ensure consistent, risk-based use of SDD aligned with the Act, its Regulations and Financial Action Task Force recommendations, including in relation to money laundering, terrorism financing and proliferation financing risks. Supervised entities are required to align their AML/CFT frameworks to the guidance, ensure SDD decisions are supported by documented risk assessments, maintain records evidencing the rationale for applying SDD and make those records available to NBFIRA on request; NBFIRA also notes it may take regulatory action where SDD is misapplied or FI Act obligations cannot be demonstrated.
Botswana Non-Bank Financial Institutions Regulatory Authority 2025-10-03
Botswana Non-Bank Financial Institutions Regulatory Authority issues guidance on simplified due diligence measures effective 2 October 2025
Botswana’s Non-Bank Financial Institutions Regulatory Authority (NBFIRA) has issued guidance on Simplified Due Diligence (SDD) under the Financial Intelligence Act, 2022. The guidance clarifies that SDD is a risk-based adjustment to customer due diligence, not an exemption, and requires entities to document and justify SDD decisions. NBFIRA may take regulatory action if SDD is misapplied or compliance with the Act is not demonstrated.