In January 2020 the Financial Intelligence Centre (FIC) published a draft Public Compliance Communication (PCC) for comment, containing guidance to all reporters on the requirements set out in Directive 5 of 2019. The comments have since been considered and incorporated into the final Guidance Note (PCC 45) where appropriate and was published by the FIC on 20 March 2020.
Directive 5 of 2019 was published by the FIC during March 2019. The Directive relates to the usage of an Automated Transaction Monitoring System (ATMS) for the detection and submission of regulatory reports to the Centre in terms of section 29 (Suspicious and Unusual Transactions) of the FIC Act. Directive 5 places certain obligations on accountable and reporting institutions and other persons (collectively referred to as reporters) who use an ATMS to enable them to monitor client transactions and activity in order to identify suspicious and unusual transactions.
It is important to note that it is not mandatory for a reporter to use an ATMS. However, should the reporter opt to make use of an ATMS, they must do so in line with Directive 5 and the guidance set out in PCC 45.