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In terms of amendments to Section 42 of the FICA, accountable institutions(*) are required to “up-their-game” in terms of knowing their clients and their clients business in terms of amendment effective 1 April 2023.

The recent “grey-listing” of south Africa by the global financial watchdog, the Financial Action Task Force or FATF has sent a knee jerk response to the wave of anti-money laundering (“AML”) and terrorist financing (“TF”) activities taking place in South African or using South Africa as a conduit. The FIC in response have imposed more and stricter guidelines on accountable institutions to prevent such activity.

A Risk Management Compliance Plan (“RMCP”) is the derivative of the above concerns and all AI’s are required to design and develop a plan aimed to identify, assess, monitor, mitigate and manage risks thereby preventing financial crime. The requirements of the plan, depending on your specific industry range can be extremely onerous to implement and monitor.

Are you an accountable institution as defined? If so, have you considered your RMCP and more pressing responded to the FIC Directive 6 series of 160 plus questions (due on or before 31 May 2023).