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Automated Transaction Monitoring System – FIC provides clarity on timeframes

In a recent LegalBrief post Pam Saxby of Legalbrief Policy Watch shares that the Financial Intelligence Centre (FIC) requires comment on the latest draft (PCC 107) public compliance communication – regarding the use of an automated transaction monitoring system to detect potentially ‘suspicious and unusual activities’.

According to Saxby, the document’s purpose is to provide guidance on an FIC directive gazetted last March, spelling out the reporting obligations of accountable institutions using these monitoring systems, which are nevertheless not mandatory. Those that do use them are reminded that, should an alert be generated, in terms of the March 2019 directive, an accountable institution has 48 hours to determine whether the transaction and/or activity concerned should be investigated and reported within the 15-day reporting period allowed. “The draft communication tends to suggest that some institutions believe they are expected to complete the necessary investigation within 48 hours of the alert being generated,” Saxby commented.

PCC 107 now also clarifies that the 15 days will start “running” from the date on which the ATMS alert is generated, and will hence include the 48 hours within which the investigation should start. Furthermore, it again confirms that the person or group of persons, who exercise the highest level of authority within the organisation, will remain responsible to ensure the effectiveness of the ATMS, and where there may be gaps, manual monitoring will be required.

Comments on the draft PPC 107 can be submitted by Friday, 21 February 2020 via email on

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