FICA for Partners and Compliance/Reporting Officers of Accounting and Auditing Firms

In terms of the Financial Intelligence Centre Act (FICA) your firm might be regarded as an Accountable Institution and will then be required to implement certain control measures to prevent and mitigate money laundering.

All firms will be required to develop, implement and maintain a Risk Management Compliance Programme (RMCP).
The duty to implement this programme will rest on the shoulders of the partners and the appointed compliance/reporting officer of the firm.

The purpose of this session is to explain all the requirements of a RMCP.

The session will cover the following:

• What is money laundering
• What constitutes a money laundering offence i.r.o. POCA
• Implementing a Risk Based Approach
• Customer due diligence procedures for natural persons, legal persons, partnerships and trusts
• Scrutinizing clients against the UNCS and Targeted Financial Sanctions Lists (TFS)
• Freezing of assets and implementing financial sanctions when applicable
• Dealing with Domestic and Foreign Politically Exposed Persons (DPEP and FPEP)
• Risk assessment rating for each category
• Making a report to the Financial Intelligence Centre
o Suspicious transaction reporting
o Cash transaction reporting
o Reports on Terrorist activity (POCDATARA)
• Reports on bribery, extortion or fraud (PRECCA)
• Appointment and duties of the compliance/reporting officer
• Training requirements for all employees
• Screening of employees
• Identifying the beneficial owners of legal entities and trusts and the new reporting requirement
• Specific reporting requirements when performing an audit, independent review or tax services
• Effect of confidentiality clauses and client privilege
• Non-compliance and penalties