A recent publication by the National Credit Regulator reminds credit providers of their risk and compliance obligations under the Financial Intelligence Centre (FIC) Act.
All credit providers are urged to register with the FIC, if they have not already done so. Credit providers are listed as accountable institutions under item 11 of Schedule 1 to the FIC Act. This means that credit providers have several compliance obligations, including registration with the FIC, customer due diligence, record-keeping, appointing a person responsible for compliance, developing and implementing a risk management and compliance programme (RMCP), training employees on the FIC Act and the institution’s RMCP, and submitting various regulatory reports to the FIC.
Registration with the FIC is the first step towards compliance and enables credit providers as accountable institutions to meet other compliance obligations such as the submission of regulatory reports. Registration is free and can be done electronically using the FIC’s online registration system called goAML.
A key obligation for credit providers as accountable institutions is to develop and document a RMCP. The FIC Act requires accountable institutions to apply a risk-based approach as a preventive measure against money laundering, terrorist financing and proliferation financing (ML, TF and PF). The RMCP must set out the institution’s governance controls, the ML, TF, and PF risk assessments, as well as aspects including a risk-rating framework, customer due diligence, targeted financial sanctions aimed at terrorist and proliferation financing, prominent influential person controls, account monitoring, reporting and record-keeping controls. The publication additionally clarifies that the development and implementation of RMCPs are considered dynamic exercises as opposed to rule-based policies and procedures manuals.
Masthead can help you with your FICA Compliance and Training
Credit providers and other accountable institutions can take advantage of Masthead’s FICA compliance services, including FICA training for your employees, hands-on assistance with implementing FICA requirements in your business, and support before a FIC inspection.
For more information of how Masthead can assist you to comply with the FIC Act requirements, click here.