Guidelines for Electronic Money Issuers in Namibia

The Guidelines for Electronic Money Issuers in Namibia are supervisory guidance issued by the Bank of Namibia to support and elaborate the Determination on the Issuing of Electronic Money (PSD-3). They translate the requirements of PSD-3 into practical guidance for banking and non-bank institutions that issue, or wish to issue, electronic money, including mobile money and other digital-wallet providers, and they form part of the operative framework that now sits under the Payment System Management Act, 2023. The Guidelines apply to all e-money issuers and prospective issuers and address both the application/authorisation process and ongoing conduct. They explain the eligibility and entry requirements, the documentation expected by the Bank, and the criteria the Bank applies, including corporate form and fit-and-proper standards for owners, directors and management, governance and risk-management arrangements, and operational, technology and security readiness. Reflecting PSD-3, they emphasise the protection of customer funds, requiring issuers to safeguard the funds backing outstanding electronic money through trust or equivalent arrangements, ring-fenced from the issuer, and the redeemability of e-money at par. They provide detailed expectations on the appointment and oversight of agents (including the issuer's responsibility for agent conduct), customer due diligence and KYC with tiered transaction and balance limits, anti-money-laundering and counter-terrorist-financing controls, consumer-protection and disclosure obligations (including fee transparency and complaints handling), interoperability, business-continuity, and reporting to the Bank of Namibia. The Guidelines also describe the Bank's assessment process, the possibility of conditional approval and the ongoing supervisory expectations once an issuer is authorised. As guidance read together with PSD-3 and beneath the umbrella Payment System Management Act, they are an operative how-to instrument for e-money and mobile money licensing and conduct in Namibia and remain in force.

1. 1Elaborate PSD-3 into practical guidance for banking and non-bank electronic money issuers
2. 2Set out the application/authorisation process, documentation and fit-and-proper, governance and operational criteria
3. 3Emphasise safeguarding of customer funds via trust/equivalent arrangements and redeemability of e-money at par
4. 4Detail appointment and oversight of agents and the issuer's responsibility for agent conduct
5. 5Address CDD/KYC tiers and limits, AML/CFT, consumer protection, disclosure, interoperability and reporting
6. 6Describe the Bank of Namibia's assessment, conditional approval and ongoing supervision