Question 1

Who receives suspicious transaction reports in Botswana?

Accepted Answer

The Financial Intelligence Agency is Botswana's central financial intelligence unit. Reports are submitted through its internet-based reporting portal and current goAML process, subject to the permitted fallback methods in the Regulations.

Question 2

How quickly must a suspicious transaction be reported?

Accepted Answer

As soon as possible and no later than five working days after the suspicion arose, unless the FIA approves later reporting in writing. Urgent cases that risk frustrating an investigation or moving proceeds beyond reach should also be escalated to the FIA as soon as reasonably possible.

Question 3

Does Botswana require cash transaction reports?

Accepted Answer

Yes. A cash transaction of P10,000 or more, or the foreign-currency equivalent, is reportable as soon as possible and no later than five working days after it is concluded. Suspicion must still be reported separately regardless of amount.

Question 4

What is Botswana's beneficial-ownership threshold for customer due diligence?

Accepted Answer

The 2022 Regulations require identification of a natural person who directly or indirectly holds more than 10% of shares, voting rights or other ownership interest. Ownership percentage is not the only test: control through other means and, if no natural person is identified after reasonable measures, the senior-managing-official fallback must also be considered.

Question 5

Must Botswana companies declare beneficial owners to CIPA?

Accepted Answer

Yes. CIPA states that all new and existing companies must declare natural persons with ultimate ownership or control, the nature of their interest, and nominee or alternate director and shareholder arrangements through the Online Business Registration System.

Question 6

How long must AML records be kept?

Accepted Answer

The Financial Intelligence Act requires 20 years: transaction records run from the transaction date, while CDD, account, correspondence and analysis records run after termination of the business relationship or occasional transaction. An investigatory authority may require longer retention in writing.

Question 7

How quickly must UN sanctions matches be frozen?

Accepted Answer

After receipt of a circulated UN Security Council list, covered persons must identify and freeze relevant property without delay, without prior notice and no later than eight hours, then report the action and property particulars without delay.

Question 8

Is Botswana on the FATF grey list?

Accepted Answer

No. FATF removed Botswana from increased monitoring in October 2021, and Botswana does not appear on FATF's current public lists available as at 15 July 2026. Firms must still monitor current FATF and FIA country-risk notices.

Question 9

Do fintechs need a licence in Botswana?

Accepted Answer

Licensing depends on activity. Electronic payment services generally require Bank of Botswana licensing; banking and deposit-taking require the relevant banking authorisation; payment-system operation may require recognition; and regulated virtual-asset services require NBFIRA authorisation under the 2025 regime.

Question 10

How does Botswana data protection interact with AML record keeping?

Accepted Answer

Financial Intelligence Act duties form a legal basis for necessary AML processing and 20-year retention. The Data Protection Act still requires transparency, minimisation, security, rights handling, DPIAs where triggered, breach notification and lawful transfer controls. The FI Act prevails only where a conflict concerns combating financial offences.

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