Schedule 1 and 3 to the Financial Intelligence Centre Act lists who should register with the FIC as Accountable and Reporting Institutions respectively. A failure to register with the FIC carries maximum penalties of up to R10m (R50m for entities) and 5 years in prison. Yikes!
It is also quite important to note that each branch of a business must register with the FIC separately, not just the head office.
The difference between Accountable and Reporting institutions are that Reporting Institutions merely report certain transactions on a continual basis, whereas Accountable institutions need to have policies and procedures to identify clients, to risk rate them according to a risk management control program and ultimately report certain transactions to the FIC such as Cash Threshold Reports (CTR's) and Suspicious Transaction Reports (STR's), among other things.
"It is also quite important to note that each branch of a business must register with the FIC separately, not just the head office.
At the time this is published the list of Accountable and Reporting institutions are as follows:
Now it is also interesting to note that these lists are under review by the FIC and they will likely be expanded to include other service and product companies such as credit providers and auctioneers.
If you or your company needs any advice or services that with regards to FICA and Anti-Money Laundering please give us a call!
by: Horizon Compliance team