
FIC invites comment on proposed risk and compliance returns
The draft directive requires certain accountable institutions to submit RCR questionnaires covering information from 2023 to 2026.

The draft directive requires certain accountable institutions to submit RCR questionnaires covering information from 2023 to 2026.

Moonstone Compliance’s analysis identifies recurring shortcomings that FSPs should fix to avoid enforcement action.

The draft PCC reinforces zero-threshold travel rule application, mandatory real-time monitoring, enhanced controls for unhosted wallets, and strict freezing obligations.

SPVs designated as accountable institutions must comply with FICA in full, including independent registration and adherence to RMCP and reporting requirements.

Accountable institutions will have to provide comprehensive information on the location of their operations when registering with the Financial Intelligence Centre.

Accountable institutions should adopt practical, risk-based RMCPs tailored to their operations, rather than relying on lengthy templates.

The FSCA has uploaded recordings of its five-part webinar series aimed at helping CASPs meet their FICA obligations.

I-FSCA ifumanise ukuba zombini iifemu azinabuchule bokulawula umngcipheko, kubandakanywa ii-RMCPs ezinqongopheleyo, inkuthalo ephantsi yabathengi, kunye nokusilela ukuhlola ngokuchasene noluhlu lwezohlwayo.

A 2021 inspection found late submission of suspicious activity reports, inadequate staff training, delayed monitoring responses, and shortcomings in the bank’s RMCP.

The FSCA identified serious lapses in Harith General Partners’ risk management, client due diligence, sanctions screening, and employee vetting.

The South African Reserve Bank cites deficiencies in Access Forex’s RMCP, customer verification, and staff training.

The FSCA found both firms lacked effective risk management capabilities, including deficient RMCPs, poor customer due diligence, and failures to screen against the sanctions lists.

The updated guidance gives concrete examples of compliance failures and explicitly states that poorly documented RMCPs may be treated as non-compliant.

Ensure registrations and filings are finalised by 5pm on 8 September and back up all records – the old system will be retired after the upgrade.

The sessions will cover institutions’ regulatory reporting obligations and establishing beneficial ownership.

Institutions that are wrongly registered as ‘business entities with a reporting obligation’ face being sanctioned by the FIC.

HBZ was fined an effective R7.5m, Citibank’s fine was fully suspended, and Bank of Taiwan was reprimanded.