AML Compliance in Botswana, A 2025 Guide for Regulated Businesses

Botswana has built a strong reputation for regulatory stability and institutional integrity, which has played a key role in maintaining trust in its financial system. As financial services become more digital and cross-border activity continues to grow, Anti-Money Laundering (AML) compliance remains a core obligation for regulated businesses operating in the country.

Unlike KYC and KYB, which focus on identifying customers and businesses at onboarding, AML in Botswana is concerned with how institutions prevent, detect, and report suspicious financial activity on an ongoing basis. This guide outlines Botswana’s AML framework in 2025, the roles of key supervisory authorities, and the operational responsibilities placed on reporting entities. It also highlights how regulated businesses can leverage digital tools, such as VOVE ID, for compliant and efficient customer and corporate onboarding, while maintaining strong AML practices.

Botswana’s AML Legal Framework

Botswana’s AML regime is built on a combination of national legislation and sector-specific regulatory guidance. Key instruments include:

• Financial Intelligence Act (FIA), as amended in 2025 (Act 1 of 2025)
• Financial Intelligence Regulations
• AML directives and prudential guidelines issued by relevant supervisory authorities
• Virtual Assets Act 2025 (Act 4 of 2025), which regulates virtual assets, virtual asset service providers (VASPs), and initial token offerings

The Financial Intelligence Agency (FIA) serves as Botswana’s financial intelligence unit. It is responsible for receiving and analysing suspicious transaction reports, disseminating financial intelligence, and coordinating AML enforcement domestically and internationally.

The 2025 amendments to the Financial Intelligence Act strengthened the role of the FIA and formally integrated virtual assets into Botswana’s AML framework. As a result, VASPs and issuers of initial token offerings are explicitly subject to AML obligations, including suspicious transaction reporting.

Botswana maintains close alignment with FATF recommendations and participates in regional AML cooperation through the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG).

AML Supervisory Authorities in Botswana

AML supervision in Botswana is allocated by sector and type of institution:

• The Bank of Botswana (BoB) oversees AML compliance for banks and certain payment and financial institutions.
• The Non-Bank Financial Institutions Regulatory Authority (NBFIRA) supervises non-bank financial institutions, including insurance companies, capital markets participants, and virtual asset service providers (VASPs) regulated under the Virtual Assets Act 2025.

These authorities work in coordination with the FIA to ensure consistent application of AML requirements across the financial system.

Who Must Comply With AML in Botswana

AML obligations apply to all reporting entities under the Financial Intelligence Act, including:

• Banks and non-bank financial institutions
• Payment service providers and electronic money issuers
• Insurance companies and investment firms
• Forex bureaus and money remittance services
• Designated non-financial businesses and professions
• Virtual asset service providers (VASPs) and issuers of initial token offerings, regulated under the Virtual Assets Act 2025

Both traditional institutions and digital-first businesses are subject to the same core AML responsibilities, regardless of whether services are delivered in person or remotely.

Core AML Obligations for Reporting Entities

AML compliance in Botswana is centred on risk-based governance and ongoing controls, rather than onboarding checks alone.

Key obligations include:

• Risk-based AML programs that reflect the institution’s products, delivery channels, customer profiles, and geographic exposure.
• Documented internal policies and procedures covering risk assessment, escalation processes, and reporting obligations, approved by senior management and reviewed regularly.
• Appointment of AML compliance officers responsible for overseeing implementation, maintaining regulatory engagement, and ensuring timely reporting to authorities.

Suspicious Transaction Reporting in Botswana

The identification and reporting of suspicious activity is a cornerstone of Botswana’s AML framework.

Reporting entities are required to:

• Identify transactions that may be linked to money laundering or terrorist financing
• Submit suspicious transaction reports to the Financial Intelligence Agency
• Refrain from tipping off customers or third parties

Suspicion may arise from unusual transaction patterns, inconsistencies with known business activities, or unexplained changes in transaction behaviour. Reports must be submitted promptly and supported by appropriate internal documentation.

Record Keeping and Audit Expectations

Botswana’s AML regulations require reporting entities to maintain comprehensive records that enable regulators to assess compliance and reconstruct transactions where necessary.

This includes:

• Transaction records and internal reports
• Risk assessments and AML program documentation
• Training records and audit findings

Records must be retained for the legally required period and made available to supervisory authorities upon request. Internal reviews and regulatory inspections are used to evaluate the effectiveness of AML controls.

AML Training and Organisational Awareness

AML compliance extends beyond compliance teams. Reporting entities are expected to provide ongoing AML training to relevant staff, ensuring they understand red flags, internal escalation procedures, and reporting obligations.

Training should be role-specific and updated to reflect regulatory developments, including those related to virtual assets and emerging financial crime risks.

The Role of Technology in AML Programs

While AML obligations are defined by regulation, many institutions rely on technology to support consistency, documentation, and operational efficiency. Digital systems can assist with risk assessments, reporting workflows, and audit readiness.

Regardless of the tools used, responsibility for AML compliance remains with the regulated entity.

Final Thoughts

AML compliance in Botswana is built on strong governance, risk-based controls, and clear accountability across regulated sectors, including the growing virtual assets space. For regulated businesses, understanding AML obligations beyond onboarding is essential to maintaining regulatory trust and long-term resilience.

For official guidance, businesses should consult publications and updates issued by the Financial Intelligence Agency (FIA), the Bank of Botswana, and the Non-Bank Financial Institutions Regulatory Authority (NBFIRA).

By aligning internal AML programs with local regulatory expectations, institutions can reduce financial crime risk while supporting sustainable growth in Botswana.