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Financial Intelligence Centre Act – Accountable institutions to comply to all the obligations

The Financial Intelligence Centre (FIC) has published draft Public Compliance Communication no 109 (PCC 109). The objective of the communication is to provide clarity on the FIC’s position regarding the commencement and enforceability of the obligations pursuant to the FIC Amendment Act, which commenced on 2 October 2017.

The draft PCC reiterates the amendment that has been brought about by the FICA Amendment Act applies in respect of the accountable institution’s (AI) entire client base. The AI must have a documented Risk Management and Compliance Program (RMCP) which has been implemented and provides for a risk-based approach to determine the risk each client may present to the AI. Therefore, client due diligence (CDD), and where applicable enhanced client due diligence, need to be performed on all clients of the AI in accordance with their RMCP.

Comment on the Draft PPC 109 must be submitted to the FIC by Friday, 20 March 2020 via email on

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