SIMPLIFIED CUSTOMER DUE DILIGENCE 30

Overall, the use of banking channels was considered the most comfortable access point for financial services as shown in the chart below from the survey.

59.6%

The main barriers to banking included the lack of money to save (59.6 percent), the least reported barrier was the inconvenience of banking hours (0.1 percent)

While 9 percent stated the lack of required documentation by banks as an exclusion factor. Ownership of ID and passports, which are some of the main requirements to access formal banking products and services, was high at 88.3 percent.6

AML/CFT/CPF

The IMF provided an update of Namibia’s AML/CFT implementation in its 2018 Financial System Stability Assessment.7 The report found that since the 2009 mutual evaluation report, Namibia had made significant progress, notably by criminalizing money laundering and terrorism financing, and implementing a freezing mechanism for terrorist assets.

The Bank of Namibia and the Namibia Financial Institutions Supervisory Authority have both adopted a risk-based approach to AML/CFT/CPF supervision in the banking sector and non-bank financial institution (NBFI) sector, respectively. Namibia has recently undergone its second Eastern and Southern Africa Anti-Money Laundering Group (ESSAMLG) mutual evaluation, which commenced with a desk review in August 2020. Their onsite assessment, which was previously scheduled in June 2021, was postponed due to COVID-19.8 The status of Namibia’s compliance with the FATF 40 Recommendations will be known once the mutual evaluation report is adopted and published.

3.3. MONGOLIA

Mongolia is a relatively large country with a small population of around 3.37 million people dispersed across 1,564,116 km² About 50 percent live in the capital while the remaining 50 percent herd livestock in the countryside.

FINANCIAL INCLUSION

Mongolia undertook a Financial Accessibility Survey in 2018 which was conducted by the Financial Regulatory Commission and the National Research and Consulting Centre. It found that 91.9 percent of citizens accessed formal financial services from commercial banks, 9.3 percent through NBFIs, 3.4 percent through savings and credit cooperatives, and 5.2 percent responded that they did not receive financial services.

92.1%

The survey also found that 95.6 percent of citizens had at least one account with a commercial bank and 92.1 percent were actively using their accounts (refer to figure 3 opposite).

6 Ibid, 11. 7 International Monetary Fund. March 2018. Namibia, 2018 Financial

System Stability Assessment, 27. Available at: https://www.imf.org/en/

Publications/CR/Issues/2018/03/15/Namibia-Financial-System-Stability-

Assessment-4572 8 Namibia FIC Annual Report. August 2021. Available at: https://www.fic. na/FIC-Annual-Report-2020-2021.pdf

FIGURE 2: 2017 NAMIBIA FINANCIAL INCLUSION SURVEY, USE OF BANKING CHANNELS, %

ATM Bank branch Wallet account Cellphone banking Internet banking Writing a cheque

10.9%

9.2%

8.6%

1.0% 58.1% 64.7%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%