Accountable Institutions must develop, document, maintain and implement a Risk Management and Compliance Programme (RMCP).

During this practical session my aim is to provide you with a step-by-step process of how to implement a RMCP for your firm.

Accountable Institutions must follow a risk-based approach when dealing with different clients due to the different levels of money laundering, terrorist financing and proliferation financing risks.

I will be providing practical guidance on the following regulatory obligations:
• Responsibility of management and those charged with Governance
o Approval and adoption of the Risk Management and Compliance Programme (RMCP)
• Appointment and responsibility of the Compliance/Reporting Officer
• Account monitoring and reporting
o Cash Threshold Reports (CTRs)
o Suspicious and Unusual Transaction Reports
o Terrorist property reports
• Customer due diligence
o Identification and verification of the identity of clients, persons acting on behalf of the client, and the client’s beneficial owners
o Scrutinising client information
o Foreign politically exposed person – Schedule 3B of the FIC Act
o Domestic politically exposed person – Schedule 3A of the FIC Act
o Prominent influential person – Schedule 3C of the FIC Act
• Risk assessments for each type of entity
• Targeted financial sanctions aimed at terrorist financing
o Scrutinising persons and entities against the Targeted Financial Sanctions list (TFS) and UN lists
• Record keeping
• Training of employees
• Screening of employees
• Additional obligations for trustees of trusts in terms of the Trust Property Control Act
• Submission of Beneficial Ownership registers to CIPC.