Lesson 1Customer due diligence and onboarding controls: KYC, beneficial ownership, screening, EDD triggers for high-risk merchants like crypto and gamblingThis part tackles customer due diligence for merchants and associates, encompassing KYC, beneficial ownership checks, sanctions and PEP screening, EDD prompts for high-risk areas, and continuous monitoring adapted to payment processor models in Namibian markets.
Merchant KYC and verification controlsBeneficial ownership identificationSanctions and PEP screening at onboardingEDD for crypto, gambling, and high riskOngoing due diligence and refresh cyclesLesson 2Transaction monitoring and detection rules: typologies for payments and digital wallets, rule design, thresholds, and scenario developmentThis part concentrates on transaction monitoring for payment processors, including typologies for cards, alternative payment methods, and wallets, rule and scenario creation, thresholds, alert management, tuning, and model oversight to spot money laundering and fraud in Namibian contexts.
Payment and wallet AML typologiesDesigning rules and scenariosThreshold setting and calibrationAlert triage and investigation flowsModel validation and performance reviewsLesson 3Risk-based approach: risk appetite statements, risk tolerances, segmentation of customers and productsThis part illustrates how payment processors use a risk-based method, covering risk appetite and tolerance declarations, customer and product grouping, scoring approaches, and matching controls and monitoring strength to risk levels for Namibian operations.
Drafting AML risk appetite statementsDefining risk tolerances and limitsCustomer and merchant segmentationProduct and channel risk scoringLinking controls to residual riskLesson 4Reporting and escalation: internal suspicious activity reporting, senior management and board reporting, regulator communication protocolsThis part addresses reporting and escalation for anti-money laundering and sanctions, including internal suspicious activity reports, case escalation, information for leaders and the board, and protocols for engaging regulators and banking partners in Namibia.
Internal suspicious activity reportingEscalation criteria and timelinesManagement and board reporting packsRegulator communication protocolsReporting to sponsor banks and partnersLesson 5Sanctions compliance programme elements: screening workflows, watchlist management, false positive tuning, blocking/filing proceduresThis part elaborates sanctions compliance for payment processors, including screening setup, list oversight, workflow arrangement, false positive minimisation, and steps for blocking, rejecting, reporting, and recording sanctions decisions applicable in Namibia.
Sanctions risk assessment for processorsName and payment screening designWatchlist sourcing and list governanceFalse positive reduction and tuningBlocking, rejecting, and reporting flowsLesson 6Policies and procedures: AML, sanctions screening, KYC, enhanced due diligence (EDD), transaction monitoring, data protection, recordkeepingThis part explains drafting and upholding anti-money laundering, sanctions, KYC, EDD, monitoring, data protection, and recordkeeping policies and procedures that are risk-oriented, practical, version-managed, and synced with regulatory expectations in Namibian settings.
Policy hierarchy and ownership modelCore AML and KYC policy elementsSanctions and screening proceduresEDD and transaction monitoring SOPsVersion control and approval workflowLesson 7Training and competency management: role-based training curriculum, frequency, tracking and testing of effectivenessThis part covers role-specific anti-money laundering and sanctions training for payment processors, including curriculum by function, frequency, methods, completion tracking, effectiveness testing, and fixes for poor results or control lapses in Namibia.
Training needs analysis by role and riskDesigning AML and sanctions curriculaTraining frequency and refresher cyclesTesting knowledge and measuring impactTracking completion and remediation stepsLesson 8Governance and organisational structure: Board oversight, Compliance Officer responsibilities, escalation pathsThis part outlines governance setups for anti-money laundering and compliance in payment processors, specifying board duties, Compliance Officer roles, escalation routes, and committee structures ensuring independent, resourced control functions for Namibian firms.
Board AML and compliance oversight dutiesCompliance Officer mandate and authorityThree lines of defence model in practiceEscalation paths and issue ownershipCompliance and risk committee structuresLesson 9Recordkeeping and auditability: retention requirements, audit trails, change control for rules and modelsThis part details recordkeeping and auditability for anti-money laundering programmes, including retention plans, secure storage, audit trails for decisions, and change oversight for rules, models, and data to aid regulator and internal audits in Namibia.
Regulatory record retention requirementsDesigning searchable audit trailsEvidence of investigations and decisionsChange control for rules and modelsData lineage and system-of-record controls
