FICA Manual

2019

FSP NAME: RAND MUTUAL ADMIN SERVICES (PTY) LTD

FSP Number: 46113

TO ENABLE THE FSP TO UNDERSTAND ITS OBLIGATIONS

IN TERMS OF THE 2017 FICA AMENDMENTS

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TABLE OF CONTENTS

No. Clause Page No.

1. APPLICATION OF THE MANUAL ..................................................................................... 3

2. DEFINITIONS ..................................................................................................................... 3
3. RISK MANAGEMENT FRAMEWORK ............................................................................... 5
4. RISK MANAGEMENT & COMPLIANCE PROGRAMME ................................................... 6
4.1 An FSP’s Client Base ............................................................................................... 6
4.2 Client Risk Rating (To be read together with Annexure 1)....................................... 7
4.3 Principle of “Good Faith” .......................................................................................... 8
4.4 Customer Due Diligence .......................................................................................... 8
5. REPORTING SUSPICIOUS ACTIVITIES ........................................................................ 11
5.1 Reporting Obligations ............................................................................................. 11
5.2 Protection When Making Reports .......................................................................... 11
5.3 Reporting Procedures ............................................................................................ 12
6. TIPPING-OFF ................................................................................................................... 14
6.1 What is “Tipping-Off”? ............................................................................................ 14
6.2 What “Tipping-Off” does not mean ......................................................................... 15
7. STAFF TRAINING ............................................................................................................ 15
7.1 Internal Training Programme ................................................................................. 15
7.2 Manual Amendments & Distribution ....................................................................... 15
7.3 Disciplinary Proceedings ........................................................................................ 16
8. OTHER REPORTABLE ACTIVITIES ............................................................................... 16
8.1 Cash threshold reporting ........................................................................................ 16
8.2 Cross border conveyance and electronic transfer reporting .................................. 16
8.3 Terrorist Property Reporting ................................................................................... 16
9. RECORD KEEPING ......................................................................................................... 16
9.1 Documentation retention ........................................................................................ 16
9.2 Retrieval of documents .......................................................................................... 17
9.3 Destruction of documents ...................................................................................... 17
10. MONEY LAUNDERING REPORTING OFFICER DETAILS ............................................ 17

ANNEXURE 1: CLIENT RISK RATING

ANNEXURE 2: “CUSTOMER DUE DILIGENCE” DOCUMENTATION
ANNEXURE 3: SCREENING & WATCHLISTS
ANNEXURE 4: POLITICALLY INFLUENTIAL PERSONS
ANNEXURE 5: CDD CONFIRMATION CERTIFICATE
ANNEXURE 6: ANTI-MONEY LAUNDERING REPORT

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1. APPLICATION OF THE MANUAL

To be read together with:

1.1 Financial Intelligence Centre Act, 2001 (Act 38 Of 2001)

1.2 The FIC Amendment Act;

1.3 Amendments to the Money Laundering and Terrorist Financing Control Regulations;

1.4 Guidance Note 4A – to assist accountable institutions, reporting institutions and any
other person to whom the FIC Act applies in meeting their reporting obligations in
terms of section 29 of the Act;

1.5 Guidance Note 5B – to assist accountable institutions and reporting institutions in

meeting their cash threshold reporting obligations in terms of section 28 of the FIC
Act;

1.6 Guidance Note 6 – provides guidance on terrorist financing and terrorist property
reporting obligations in terms of section 28A of the FIC Act; and

1.7 Guidance Note 7 – to assist accountable institutions on the implementation of the

various provisions of the FIC Act.

2. DEFINITIONS

2.1 Accountable Institution (AI): An accountable institution is any person or entity as

described in Schedule 1 of the Financial Intelligence Centre Act No. 38 of 2001 who
must ensure adherence to the legal requirements and responsibilities as set out
therein. An accountable institution can be split into two distinct categories:

2.1.1 Primary Accountable Institution: These institutions are responsible for

verifying and keeping record of the identities of their clientele.

2.1.2 Secondary Accountable Institutions: These institutions rely on the

adherence of the Primary Accountable Institutions and as such, are not
required to verify the identities of the Primary Accountable Institution’s clients.

2.2 Act: Financial Intelligence Centre Act No. 38 of 2001 (also known as “FICA”), as
amended by the Financial Intelligence Centre Amendment Act of 2017.

2.3 Controlling ownership interest: refers to the ability by virtue of voting rights
attached to share holdings to take relevant decisions within the legal person and
impose those resolutions.

2.4 Customer Due Diligence: The steps and procedures taken to identify and verify
clients. For the purposes of abbreviation, it is also referred to as “CDD”.

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2.5 Effective control: means ability to materially influence key decisions in relation to a
legal person (e.g. the manner in which the majority of voting rights attached to
shareholdings are exercised, the appointment of directors of a legal person,
decisions taken by a board of directors, key commercial decisions of a legal person),
or the ability to take advantage of capital or assets of a legal person.

2.6 Financial Intelligence Centre: The Financial Intelligence Centre is South Africa’s
national centre for gathering, analysis and dissemination of financial intelligence. It
was established to identify proceeds of crime, combat money laundering and the
financing of terrorism and, in so doing, has a primary role to protect the integrity of
South Africa’s financial system. For the purposes of abbreviation, it is also referred to
as “FIC”.

2.7 Financial Services Conduct Authority: The Regulatory agency responsible for
non-banking financial services in South Africa. For purposes of abbreviation, it is also
referred to as the “FSCA”.

2.8 Financial Services Provider: Any person (including both natural and juristic
persons) other than a Representative who furnishes advice or who furnishes advice
and renders intermediary services. For the purposes of abbreviation, it can also be
referred to as a “FSP”.

2.9 Law enforcement Agencies: Financial Intelligence Centre, South African Police,
National Prosecuting Authority, Financial Services Conduct Authority.

2.10 MLRO: Money Laundering Reporting Officer.

2.11 ML & TF: Money Laundering and Terror Financing

2.12 Money Laundering: Any process which gives the proceeds of unlawful activities the
appearance that they originate from a legitimate source.

2.13 PIP: Prominent Influential Persons refer to any individuals who are or have in the
past been entrusted with prominent functions in a particular country and
encompasses the immediate family members and known close associates of any
given client. PIPs can be split into two distinct categories:

2.13.1 Foreign Prominent Public Officials: Individuals who hold or have held
prominent positions at any time during the preceding 12 months in a foreign
country.

2.13.2 Domestic Prominent Influential Persons: Individuals who hold or have held
(including acting positions exceeding 6 months) prominent positions within the
Republic of South Africa

2.14 POCA: Prevention of Crime Act No 24 of 1999, which stipulates criminal and civil
offences, tipping-off and penalties.

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2.15 Risk: means the impact and likelihood of ML/TF taking place. Risk refers to inherent
risk, i.e. the level of risk that exists before mitigation. It does not refer to residual risk,
i.e. the level of risk that remains after mitigation.

2.16 Risk factors: means variables that, either on their own or in combination, may
increase or decrease the ML/TF risk posed by a business relationship or single
transaction.

2.17 Risk-based approach: means an approach whereby accountable institutions

identify, assess and understand the ML/TF risks to which institutions are exposed
and take AML/CFT measures that are proportionate to those risks.

2.18 Senior management: in an accountable institution is determined by the size,

structure, and nature of the institution. The senior manager whose approval is sought
for purposes of the FIC Act should have sufficient seniority and oversight to take
informed decisions concerning the institution’s compliance with the FIC Act that bind
the institution to those decisions.

2.19 Source of funds: means the origin of the funds involved in a business relationship or
single transaction. It includes both the activity that generated the funds used in the
business relationship (for example the client’s salary, occupation, business activities,
proceeds of sale, corporate dividends, etc.), as well as the means through which the
client’s funds were transferred.

2.20 Source of wealth: means the activities that have generated the total net worth of the
client that is, the activities that produced the client’s funds and property (for example
inheritance or savings).

2.21 Tipping-off: Any instance where an individual within the FSP (including its
Associates) discloses information to someone outside of the approved reporting
chain and, in so doing, the information could potentially prejudice an investigation
into money-laundering.

3. RISK MANAGEMENT FRAMEWORK

3.1 In terms of the FICA Amendments, AI’s will have flexibility to construct and tailor their
risk management framework for the purpose of developing risk-based systems and
controls and mitigation strategies in a manner that is most appropriate to their
business structure (including financial resources and staff), their products and/or the
services they provide.

3.2 Such risk-based systems and controls should be proportionate to the ML&TF risk(s)
an AI reasonably faces. The risk management framework aims to assist AI’s to
develop and implement their AML&CFT programs in compliance with the existing
legal and regulatory requirements and international standards and best practices.

3.3 For effective risk management, the AI should at all levels follow the principles below:

3.3.1 Risk management contributes to the demonstrable achievement of objectives

and improvement of performance, governance and reputation.
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3.3.2 Risk management is not a stand-alone activity that is separate from the main
activities and processes of the AI. Risk management is part of the
responsibilities of management and an integral part of all organizational
processes, including strategic planning.

3.3.3 Risk management helps decision makers making informed choices, prioritize
actions and distinguish among alternative courses of action.

3.3.4 Risk management explicitly takes account of uncertainty, the nature of that
uncertainty, and how it can be addressed.

3.3.5 A systematic, timely and structured approach to risk management contributes

to efficiency and to consistent, comparable and reliable results.

3.3.6 Risk management is based on the best available information.

3.3.7 Risk management is aligned with the AI's external and internal context and risk
profile.

3.3.8 Risk management is transparent and inclusive.

3.3.9 Risk management is dynamic and responsive to change. Following the above
mentioned principles the AI is expected to develop and maintain logical,
comprehensive and systematic methods to address each of the components
referred to above and that such methods and the AI’s approach to ML&TF risk
are understood, implemented and maintained, to some appropriate extent,
within their organizations.

3.3.10 The AI would be expected to demonstrate that their risk based systems and
controls are suitable to their particular business and consistent with prudent
and good practices.

3.3.11 In assessing and mitigating ML& TF risk, the FIs should consider a wide range
of financial products and services, which are associated with different ML& TF
risks.

4. RISK MANAGEMENT & COMPLIANCE PROGRAMME

The Risk Management & Compliance Programme (“RMCP”) encompasses the processes
and procedures employed by the FSP and its Associates to identify, assess, monitor,
mitigate and manage any risks related to money laundering and the financing of terrorist
activities.

4.1 An FSP’s Client Base

An FSP may interact with a broad client base encompassing natural and legal entity,
both within and outside the Republic of South Africa. The client base can broadly be
classified into two groups:

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4.1.1 Direct Clients

In the normal course of business, direct clients contact the FSP directly, without
the assistance of an intermediary, such as a brokerage or investment
institution. The FSP assumes direct responsibility for the risk assessments,
AML procedures, record keeping and reporting obligations applicable to these
clients.

4.1.2 Broker-Engaged Clients

The FSP may interact with a number of Broker-Engaged Clients, each with
their own client base. The FSP will rely on the AML/CFT policies and
procedures of the institutions concerned to identify and verify Broker-Engaged
Clients. While the FSP primarily rely on these policies and procedures, periodic
reviews will be conducted to ensure continued compliance to the Act.

4.2 Client Risk Rating (To be read together with Annexure 1)

4.2.1 Due to the broad scope of the aforementioned client base, it is not practical to
determine whether prospective clients intend to establish long-term business
relationships or conclude single transactions with the FSP. The FSP chooses to
focus primarily on Customer Due Diligence and the associated reporting
obligations.

4.2.2 The FSP shall treat all prospective or new clients as low risk until factors
indicate otherwise.

4.2.3 Factors which will escalate a client’s risk rating include, but are not limited to
the following:

4.2.3.1 A client’s unreasonable resistance or unwillingness to provide requested

CDD documentation;

4.2.3.2 Inconsistencies between provided CDD documentation and client

information on record;

4.2.3.3 Suspicious account activity and/or transactions;

4.2.3.4 Being flagged against sanction watch lists;

4.2.3.5 Being identified as a PIP or as a family member or associate of a PIP;

and

4.2.3.6 The client invests more than R25 000 (in total) during the course of a
year or the client’s portfolio market value exceeds R25 000 during the
year.

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4.3 Principle of “Good Faith”

4.3.1 The FSP extend “good faith” to all its clients – whether new or existing – in that
clients are deemed to have legitimate sources of funds and they have
legitimate business reasons for making use of the FSP’s services. In the
absence of evidence to the contrary, “good faith” will always be extended to
clients.

4.3.2 In a similar vein, when a client chooses to withdraw business from the FSP, the
FSP shall continue to extend “good faith”, deeming that the withdrawal of
business has been made on the basis of honest and legitimate reasons. Where
appropriate, client agreements may require a client certification that they will be
responsible for their own reporting obligations and that their initial and
subsequent funds are not the proceeds of criminal activities.

4.3.3 However, in the interests of “good faith”, the FSP will not establish relationships
with any individual or entity that will expose the reputation of the FSP to risk.
This is done to protect not only the good name of the FSP but also the names
of the clients associated with the FSP.

4.3.4 If a client is suspected of engaging in or being involved with illegal activities,

this will be deemed as a violation of the “good faith” extended by the FSP. As
such, the FSP reserves the right to terminate business relationships with
existing clients if the “good faith” is violated in this manner. The decision to
terminate the relationship will be made by executive management on a case-
by-case basis. Any such terminations will be followed by reporting the FSP’s
suspicions to the relevant law enforcement agencies.

4.3.5 All employees involved in the termination of the business relationship must co-
ordinate the termination with the Money Laundering Officer of the FSP. The
MLRO will in turn liaise with law enforcement agencies before communicating
the FSP’s intention to terminate the client relationship.

The MLRO of the FSP ____________________________________

4.4 Customer Due Diligence

4.4.1 Direct Clients

4.4.1.1 Prospective clients desiring to transact with the FSP are required to
complete the necessary application form(s) to facilitate their investments.
Each application form requires a number of supporting documents to be
provided pertaining to the prospective client’s identity. Acceptable forms,
as per Annexure 2 of verification form the basis of the FSP’s CDD
processes.

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4.4.1.2 Upon receipt of the completed applications and supporting documents,
the information is reviewed to ensure consistency, completeness and
accuracy.

4.4.1.3 Should the FSP be in any way dissatisfied with the provided
documentation, have any doubts as to the identity of the prospective
client, be unable to resolve any noted inconsistencies or should the
prospective client be unwilling to provide the required supporting
documents, the FSP shall not establish a business relationship with the
prospective client, or conclude any transactions on their behalf. Subject
to the circumstances involved, the FSP reserves the right to file a
Suspicious & Unusual Transaction Report with the Financial Intelligence
Centre.

4.4.1.4 After the initial application and acceptance, a client will be screened
against a number of watch lists, as detailed in Annexure 3, on an ongoing
basis to identify:

4.4.1.4.1 Sanctioned individuals;

4.4.1.4.2 Organized crime and threat finance; and

4.4.1.4.3 Politically Influential Person relationships.

4.4.1.5 Any client, as identified by the United Nations Security Council, shall
remain a client of the FSP. Once identified, such a client will be subject to
a Suspicious and Unusual Transaction Report and the FSP shall cease
any and all transactions with the sanctioned client, including concluding
transactions on their behalf, as required by Section 26B of the Act.

4.4.1.6 Any client found to be concluding transactions under a false identity will
be subject to a Suspicious and Unusual Transaction Report and the FSP
shall cease any and all transactions with the sanctioned client, including
concluding transactions on their behalf, as required by Section 20A of the
Act.

4.4.1.7 Should the FSP at any time doubt the veracity of the provided FICA
documentation, the FSP reserves the right to request FICA
documentation as detailed in Annexure 2.

4.4.2 Broker-Engaged Clients & On-Site Reviews

4.4.2.1 When interacting with various Broker-Engaged Clients, it is the policy of

the FSP to obtain a “CDD Confirmation Certificate” from the Broker-
Engaged Client concerned. The certificate provides written confirmation
from the Broker-Engaged Client that the FSP may rely on the
identification, verification, record keeping processes and procedures of
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 the Broker-Engaged Client. The Broker-Engaged Client accordingly
assumes the role of the Primary Accountable Institution in the business
relationship, while the FSP assume the role of Secondary Accountable
Institutions. A template of the CDD Confirmation Certificate is attached in
Annexure 5.

4.4.2.2 It is the manual of the FSP and its Associates to conduct on-site reviews
of a Broker-Engaged Client’s FICA processes. On-site reviews will be
conducted at the discretion of the Compliance department. The on-site
review process is outlined as follows:

4.4.2.2.1 The Compliance department will select an appropriate audit sample

from the Broker-Engaged Client’s customer base. The audit sample
will be reflective of the customer base’s composition and will be
compiled using a mixture of sampling methodologies.

4.4.2.2.2 The Broker-Engaged Client will be contacted and the time and date
of the review will be arranged. The Broker-Engaged Client will be
given sufficient time to compile the auditing sample and any
supporting documentation.

4.4.2.2.3 The audit will be conducted by a representative of the Compliance

department at the time and date as arranged. A comprehensive
audit report will be compiled detailing any and all findings, including
shortfalls in FICA documentation. The audit report will be filed for
record keeping purposes with the Compliance department.

4.4.2.2.4 Upon completion, the audit report will be forward to Management.

Management will in turn relay the audit findings to the Broker-
Engaged Client

4.4.2.2.5 The Broker-Engaged Client shall have opportunity to respond to the

findings and rectify any shortcomings in the FICA documentation.
Proof of such action shall be forwarded to the Compliance
department for record-keeping purposes

4.4.2.2.6 If issues detailed in the audit report are not addressed in a

reasonable amount of time, Management will take appropriate
action to protect the interests of the FSP. These actions may
include reporting the Broker-Engaged Client to the Financial
Intelligence Centre, depending on the circumstances.

4.4.3 Prominent Influential Persons

4.4.3.1 Since PIPs as a category are viewed as high-risk clients, additional

processes may be put in place at the discretion of the FSP to determine
whether a potential client, an existing client or the beneficial owner of a
client is classified as a PIP.

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4.4.3.2 Additional procedures include:

4.4.3.2.1 Senior management’s approval for establishing relationships with a

PIP. If such approval has been received in the past, approval needs
to be obtained to continue the business relationship.

4.4.3.2.2 Establish a PIP’s source of wealth or source of funds.

4.4.3.2.3 Obtain an acknowledgement letter from the Broker-Engaged Client

concerned stipulating that the Broker-Engaged Client will assume
responsibility for ongoing monitoring.

4.4.3.2.4 Continue screening identified PIPs against the sanction watch lists,
as detailed in Annexure 3. The full list of PIPs is detailed in
Annexure 4.

5. REPORTING SUSPICIOUS ACTIVITIES

5.1 Reporting Obligations

5.1.1 The FSP recognises that they has a legal duty to protect the confidentiality of
their clients. However, the FSP will release any and all required information to
law enforcement agencies in the course of reporting and investigating
suspicious business activities.

5.1.2 The FSP will not hesitate to report knowledge or suspicion of criminal conduct
where it is legally obligated to do so. The FSP recognise that failing to do so
would constitute an offence. In reporting suspicious and illegal activities, the
FSP will make full use of the protection afforded by legislation to reporters. This
legislation effectively protects any reporting entity. They cannot be charged with
assisting criminal endeavours.

5.1.3 The MLRO will serve as the FSP’s primary contact when meeting with law
enforcement agencies. When meeting with the aforementioned agencies, the
MLRO may include the Section 43 Compliance Officer and/or Senior
Management.

5.1.4 The FSP have also placed procedures in place to reduce the risk of an
employee tipping-off a client or any other person with whom they are in contact.
Tipping-off is a criminal offence that carries heavy penalties, both for the FSP
(as accountable institutions) and the offending employee (in his/her individual
capacity).

5.2 Protection When Making Reports

5.2.1 No action – criminal or civil – can be brought against the FSP (as accountable
institutions) or any of its employees (as individuals) for complying in good faith
with the provisions of the Act.
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5.2.2 Any person who has made, initiated or contributed to a report in terms of the
Act is not obligated to give evidence in criminal proceedings.

5.2.3 The identity of any person who has made, initiated or contributed to a report in
terms of the Act will not be admissible as evidence in criminal proceedings
unless the person testifies at those proceedings.

5.3 Reporting Procedures

5.3.1 The FSP have implemented a strict reporting process to report any and all
suspicious activity that may be identified during the ordinary course of
business. This process has been laid out in detail in the pages to follow. Any
deviation from this process will require the approval of the Board of Directors.

5.3.2 The FSP and its Associates will never take on a Direct Client who is a PIP.

5.3.3 STAGES:

5.3.3.1 Stage 1

5.3.3.1.1 Stage one of the process requires staff members to identify

suspicious activity. An abnormal or suspicious transaction is any
transaction that has been structured in an extraordinary or unusual
way.

5.3.3.2 Stage 2

5.3.3.2.1 Stage two requires that the staff member complete an “Anti-Money
Laundering Report”. A template of this report can be found in
Annexure 6. It is very important that the staff member explains
his/her reasons for suspecting a given transaction in full detail.

5.3.3.2.2 Once the report has been filled out, the staff member should
present the report to the Head of their Business Unit. They will
discuss the facts, review the report and, where appropriate, add
additional information about the client or transaction if it is relevant
to the matter under consideration. All staff members involved in
discussing the report must sign the report to acknowledge that they
are suspicious of the transaction. If a staff member suspects the
Head of the Business Unit to be involved with the suspicious activity
under consideration, the MLRO should be contacted immediately.
If, the MLRO is suspected, the staff member should speak directly
with Senior Management.

5.3.3.2.3 Suspicions must not be discussed with anyone other than those
mentioned above. Once the reporting process has commenced, it
must be followed through to completion, even if the original
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 suspicion does not exist. All reports will be kept on file by the MLRO
for record-keeping and referral purposes.

5.3.3.2.4 It is of vital importance, regardless of whether the suspicions are

proven true or not, that no mention of these suspicions be made to
the client. Any discussion of this nature would risk a tipping-off
offence. Staff should at all times neither confirm nor deny the
existence of a report to the client or to a third party. Any
correspondence that could indicate the existence of a report should
not be placed in the client’s file.

5.3.3.2.5 Once the report has been finalised, it must be presented to the
MLRO who in turn will acknowledge its receipt in writing. The staff
member will then receive guidance from the MLRO on how to
proceed with the client in question. In particular, if the client
demands that subsequent transactions be executed, the situation
must be discussed with the MLRO before any action is taken. In
certain cases, the MLRO may decide to allow transactions to
continue in order not to raise the client’s suspicions. Regardless,
the MLRO should be kept informed of all subsequent dealings with
the client.

5.3.3.3 Stage 3

5.3.3.3.1 Stage three of the process is handled exclusively by the MLRO.

The MLRO must decide, based on the staff member’s report and all
available information (including additional enquiries), whether or not
the transaction has remained suspicious. If the MLRO feels that the
transaction has remained suspicious, the MLRO will make an
official report to the relevant law enforcement agencies All reports
made to law enforcement agencies will be kept in a “Money
Laundering Reporting Register” for record-keeping and referral
purposes.

5.3.3.3.2 The initiating staff member will receive an acknowledgment signed

by the MLRO confirming that their personal legal obligations in
terms of this Manual have been met. If the staff member has not
received a confirmation within one week of submitting the initial
report, the MLRO should be contacted immediately.

5.3.4 Non-Disclosure of Reports

When the MLRO files a report concerning suspicious transactions with the
Financial Intelligence Centre, any person involved in the making and
submission of that report may not disclose the nature of the report or any
information related to it to any other person.

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5.3.5 Record keeping related to reports

5.3.5.1 Records are kept to provide an audit trail and adequate evidence to law
enforcement agencies during the course of their investigations. However,
these records will only be provided at the request of law enforcement
agencies.

5.3.5.2 All records will be kept for at least 5 (five) years from the date of the last
transaction on the account.

6. TIPPING-OFF

6.1 What is “Tipping-Off”?

6.1.1 “Tipping-off” is an offence in terms of the Act. Any employee of the FSP who
discloses information to someone outside the internal reporting chain of the
FSP, potentially prejudicing an investigation into money laundering activities,
will be guilty of “tipping-off”.

6.1.2 The internal reporting chain of the FSP is as follows:

6.1.2.1 The employee(s) who become aware of the suspicious activity

6.1.2.2 The Head of their Business Unit

6.1.2.3 The MLRO

6.1.2.4 The Law Enforcement Agencies

6.1.3 Any employee who has been found to have deliberately acted against the
provisions of this manual – including tipping-off clients – will be subject to the
internal disciplinary procedures and Code of Conduct of the FSP as well as the
potential penalties as detailed in legislation.

6.1.4 For an employee to be guilty of “tipping-off”, they must have had knowledge of
or suspected that a money laundering investigation was about to be conducted.
An employee would be aware of a pending investigation because:

6.1.4.1 A disclosure has been made or is about to be made to a person in the

internal reporting chain or;

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6.1.4.2 A court order has been served or is about to be served by a law
enforcement agency compelling the production of documents and/or
information.

6.2 What “Tipping-Off” does not mean

If an employee makes a general enquiry, requesting additional information from a

client (specifically regarding their identity or the nature of a transaction) before a
person in the internal reporting chain is notified or a court order is received, the
employee will not have committed a tipping-off offence.

7. STAFF TRAINING

7.1 Internal Training Programme

7.1.1 All employees of the FSP, whether permanent or temporary, will receive anti-
money laundering training necessary to their job function within the FSP.
Training will be provided by the Compliance department.

7.1.2 All employees have been made aware of the offences detailed in the legislation
for non-reporting, tipping-off and consciously or unconsciously assisting money
launderers. As such, they have also been made aware of their responsibilities,
both as individuals within their respective business units and as employees of
the FSP.

7.1.3 All staff are required to sign a register when attending the training sessions.
Each staff member attending the session will receive a copy of the latest
version of this Manual as well as the accompanying explanatory notes. The
signed register will be kept in the Compliance department.

7.1.4 Due to staff movement, ongoing training is necessary to maintain awareness of

anti-money laundering processes. Refresher courses will be offered from time
to time for the benefit of new and existing employees alike.

7.2 Manual Amendments & Distribution

This Manual may be updated from time to time in line with changes to legislation or to
better improve the anti-money laundering processes of the FSP. An updated version
of the Manual will be made available to staff, either through internal communications
or the FSP’s website.

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7.3 Disciplinary Proceedings

Any employee of the FSP found to be in contravention of the requirements and

provisions outlined in this Manual, or the Disciplinary Policy or Code of Ethics, shall
be subject to internal disciplinary proceedings as well as administrative sanctions /
penalties as may be required by the Act.

8. OTHER REPORTABLE ACTIVITIES

8.1 Cash threshold reporting

All cash transactions exceeding R24 999-00 will be automatically reported to the
MLRO.

8.2 Cross border conveyance and electronic transfer reporting

All cross border conveyance and electronic transfers to and from the Republic of
Soth Africa over R24 999-00 will automatically be reported to the MLRO.

8.3 Terrorist Property Reporting

8.4 Any property connected to an offence relating to the financing of terrorist and related
activities or any property directly connected to terrorist and related activities will be
automatically reported to the MLRO.

8.5 All client records will be checked against the United Nations Security Council
Sanctions list and any client who is found to be connected with the financing of
terrorist and related activities will be automatically reported to the MLRO.

9. RECORD KEEPING

9.1 Documentation retention

9.1.1 The FSP will retain all documentation detailing transfers in and out of client
accounts, including any and all supporting documents. These documents will
be kept on file to provide an audit trail for the money transfers and, should the
need ever arise, provide adequate evidence for law enforcement agencies
during the course of their investigations.

9.1.2 If and when the FSP receive a court order requiring documents or other
information for the use of law enforcement agencies, all staff members must
co-operate and assist the MLRO in complying with the court order.

9.1.3 Documents will be kept on file according to the time periods dictated by local
legislation. The minimum retention periods for documentation are as follows:

16
9.1.3.1 Opening Account Records – These records will be kept on a permanent
file for as long as the business relationship continues between the client
and the FSP. Should the relationship be terminated, documents will be
kept on file for at least 5 years after the last transaction or closure of the
account.

9.1.3.2 Account Transaction Records – At least 5 years.

9.1.3.3 “Individual” or Stand-alone Transaction Records – At least 5 years after

the transaction was completed.

9.1.3.4 MLRO register of Reports and supporting documentation – At least 5

years.

9.1.3.5 Training Records relating to Anti-Money Laundering – At least 5 years.

9.1.4 If the FSP is aware that a money laundering investigation is currently being
conducted by law enforcement agencies, all records relating to the client and
the account under investigation must be kept on file until advised otherwise by
the investigating authorities. The MLRO will be responsible for managing such
situations, should they arise.

9.2 Retrieval of documents

Documents that are required under a court order must be retrieved and produced for
inspection within a reasonable period of time, as stipulated by the court order, from
the date the court order was served. Electronic records are also acceptable.

9.3 Destruction of documents

No documentation in respect of the procedures outlined above will be destroyed until

the documents have been archived and the destruction of the documents have been
authorized by the MLRO.

10. MONEY LAUNDERING REPORTING OFFICER DETAILS

The details of the MLRO are as follows:

Name: Hope Ramoshu

E-mail: [email protected]
Tel: 010 214 3016

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 ANNEXURE 1

CLIENT RISK RATING

A client’s risk rating shall directly impact the level of CDD required. Risk ratings are
assigned as follows:

RISK
TRANSACTION TYPE REQUIRED INFORMATION
RATING
Single Transactions Basic Information (Full name & ID)
Low Risk
< R5 000 Completed Application
New Investment Clients Basic Information (Full name & ID)
Low Risk
< R24 999 Completed Application
Bank Verification prior to
Client Redemptions Low Risk
Redemption pay out
New Investment Clients Full FICA
High Risk
> R24 999 Completed Application
Full FICA
Existing Clients
> R24 999 Completed Application
High Risk
(Source of Funds do not need to be
Market Value on Portfolio
verified)
Full FICA
Prominent Influential
Low Risk Completed Application
Persons
Management Sign Off

ESCALATION FACTORS

A “low risk” client may be classified as a “high risk” client if:

 The client is unwilling or unusually resistant to providing the required

documentation;
 There are inconsistencies between the provided documentation and the client
information on record;
 The client engages in suspicious activity, including:

a. Multiple redemptions per month; and

b. Making multiple investments & redemptions within the space of 30 days.

 The client is identified as a PIP (encompassing both Domestic Prominent

Influential Persons & Foreign Prominent Public Officials) or a close family
member of a PIP;
 The client is flagged against sanction watch lists (Refer to Annexure 3);
 The client invests more than R24 999(in total) during the course of a year or
the client’s portfolio market value exceeds R24 999 during the year.

RETIREMENT FUNDS EXEMPTION

Registered retirement funds are exempted from all CDD procedures.

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ONGOING CDD MEASURES

High risk clients will be actively monitored and be required to provide up-to-date
details at least once per year to ensure that the risk ratings and information on
record are accurate and up to date.

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 ANNEXURE 2
“CUSTOMER DUE DILIGENCE” DOCUMENTATION

SOUTH AFRICAN CITIZENS

Investments made by a Natural Persons and their Representatives

NATURAL PERSONS (FICA Reg. 3 & 4)

IDENTIFY VERIFY
Full Name & Surname: ID Document / Passport
Date of Birth: ID Document / Passport
Identity Number: ID Document / Passport
Income Tax Number: SARS Document
Residential Address: Proof of Address (not older than 3 months)

REPRESENTATIVE OF A NATURAL PERSON

(FICA Reg. 3, 4 & 17)
IDENTIFY VERIFY
Proof of Representation: Letter of authority, Court order etc.
Full Name & Surname: ID Document / Passport
Date of Birth: ID Document / Passport
Identity Number: ID Document / Passport
Income Tax Number: SARS Document
Residential Address: Proof of Address (not older than 3 months)
Contact Particulars: Telephone number / Cell Number / Email

Investments made on behalf of a Minor by a Parent or Legal Guardian

 Verified copy of South African green bar-coded ID/new smart card ID

or valid passport of the Natural Parent as Guardian of the Minor
Client.

 Verified copy of the minor’s birth certificate stipulating the name(s) of

the natural parent(s).

If the name(s) of the natural parent(s) is not stated on the birth certificate, the
following documents will be required:

 Copy of sworn Affidavit from the natural parent confirming that the
guardian is the natural parent of the minor, signed in front of an
independent commissioner of oaths.

 Copy of the natural parents’ marriage certificate or copy of Sworn

Affidavit from the natural parent confirming the marriage (signed in
front of an independent commissioner of oaths).

If the investment is made by a court appointed Guardian and not the natural
parent(s) of the minor, the following documents must be provided:

 Verified copy of proof of guardianship from the Master of the Supreme Court.

 Verified copy of the minor’s birth certificate.

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FOREIGN NATIONALS

Investments made by a Natural Persons and their Representatives

NATURAL PERSONS (FICA Reg. 5 & 6)

IDENTIFY VERIFY
Full Name & Surname: Passport
Date of Birth: Passport
Nationality: Passport
Passport Number: Passport
South African Income Tax Number (if
issued): SARS Document
Proof of Address (not older than 3
Residential Address: months)

REPRESENTATIVE OF A FOREIGN NATIONAL (FICA Reg. 5, 6 & 17)

IDENTIFY
Full Name & Surname:

Date of Birth:
Nationality:
Passport Number:
Proof of Address (not older than 3
Residential Address: months)

Telephone number / Cell Number /

Contact Particulars: Email

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 LEGAL ENTITIES: SOUTH AFRICA

Investments made by a South African Companies

If a company is listed on a recognised security exchange, no FICA documentation

(apart from Proof of Listing) is required. This exemption does not apply to
subsidiaries of a listed company, whether wholly owned or not. For all unlisted
South African companies, the following documents will be required:

SA COMPANIES (FICA SECTION 21B and FICA Reg. 7 & 8)

IDENTIFY VERIFY
CM1 & CM2 / CoR 14.1, CoR 14.3 &
Registered Name: CoR 15.1

CM1 & CM2 / CoR 14.1, CoR 14.3 &

Registration Number: CoR 15.1
CM1 & CM2 / CoR 21 or Confirmation
Registered Address: Certificate.
Name under which Conducting
Business: Corporate Letterhead
Proof of Address (not older than
Operating Address: 3 months)
Income Tax & VAT Numbers: SARS Documents
Company Share Register /
Ownership Structure Corporate Organogram
COMPANY REPRESENTATIVES:
For each Manager, Director and Authorised Individual of the Company (FICA Reg. 7
& 8)
IDENTIFY VERIFY
Full Name & Surname: ID Document / Passport
Date of Birth: ID Document / Passport
Identity Number: ID Document / Passport
Proof of Address (not older than 3
Residential Address: months)
Proof of Representation: Resolutions / Letter of Authorisation
INDIVIDUAL SHAREHOLDERS OVER 25% (FICA Reg. 7 & 8)
IDENTIFY VERIFY
Share Certificate / Company Share
Proof of Shareholding: Register
Full Name & Surname: ID Document / Passport
Date of Birth: ID Document / Passport
Identity Number: ID Document / Passport
CORPORATE SHAREHOLDERS OVER 25% (FICA Reg. 7 & 8)
IDENTIFY
Proof of Shareholding: Share Certificate / Company Share Register

Registered Name: CM1 & CM2 / CoR 14.1, CoR 14.3 & CoR 15.1
Registration Number: CM1 & CM2 / CoR 14.1, CoR 14.3 & CoR 15.1
CM1 & CM2 / CoR 21 or
Registered Address: Confirmation Cert.
Name under which Conducting Business:
Corporate Letterhead
Operating Address: Proof of Address (not older than 3 months)

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 Investments made by Partnerships

The FICA Amendment Act of 2017 subjects Partnerships to enhanced Customer

Due Diligence procedures in terms of Section 21B. The following documents will
be required:

PARTNERSHIPS
(FICA SECTION 21B)
IDENTIFY VERIFY
Registered Name: Partnership Agreement
Type of Partnership: Partnership Agreement
Registered Address: Partnership Agreement
Operating Address: Proof of Address (not older than 3 months)
PARTNERS
(FICA SECTION 21B)
IDENTIFY VERIFY
Number & Identity of
Partners Partnership Agreement
Full Name & Surname: ID Document / Passport
Date of Birth: ID Document / Passport
Identity Number: ID Document / Passport
Residential Address: Proof of Address (not older than 3 months)
Income Tax Number: SARS Document
REPRESENTATIVES OF PARTNERS (FICA SECTION 21B)
IDENTIFY VERIFY
Proof of Representation: Letter of authority, Court order etc.
Full Name & Surname: ID Document / Passport
Date of Birth: ID Document / Passport
Identity Number: ID Document / Passport
Income Tax Number: SARS Document
Residential Address: Proof of Address (not older than 3 months)
Contact Particulars: Telephone number / Cell Number / Email

Investments made by Closed Corporations

CLOSED CORPORATIONS (FICA Reg. 7 & 8)

IDENTIFY VERIFY
Registered Name: CK1 & CK2
Registration Number: CK1 & CK2
Registered Address: CK1 & CK2
Name under which Conducting
Business: Corporate Letterhead
Proof of Address
Operating Address: (not older than 3 months)
Income Tax & VAT Numbers:
SARS Documents1
CORPORATION REPRESENTATIVES:
For each Member and Authorised Individual of the Company (Reg. 7 & 8)
IDENTIFY VERIFY
Full Name & Surname: ID / Passport
Date of Birth: ID / Passport
Identity Number: ID / Passport

Proof of Address (not older than 3

Residential Address: months)
Resolutions / Letter of
Proof of Representation: Authorisation
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 Investments made by Trusts

The FICA Amendment Act of 2017 subjects Trusts to enhanced Customer Due
Diligence procedures in terms of Section 21B in addition to those stipulated in the
FICA Regulations. The following documents will be required:

TRUSTS (FICA SECTION 21B and FICA Reg. 15 & 16)

IDENTIFY VERIFY
Trust Name & Number: Trust Deed / Founding Document
Address of the Master of the High Court: Letter of Authority
Income Tax Number: SARS Document
TRUSTEES OF A TRUST (FICA SECTION 21B and FICA Reg. 15 & 16)
IDENTIFY VERIFY
Full Name & Surname: ID Document / Passport
Date of Birth: ID Document / Passport
Identity Number: ID Document / Passport
Proof of Address (not older than 3
Residential Address: months)
Authority to Act: Letter of Authority
BENEFICIARIES OF A TRUST (FICA SECTION 21B and FICA Reg. 15 & 16)
IDENTIFY VERIFY
Method of Beneficiary Determination: Trust Deed
Full Name & Surname: ID Document / Passport
Date of Birth: ID Document / Passport
Identity Number: ID Document / Passport
Proof of Address (not older than 3
Residential Address: months)
FOUNDER OF A TRUST (FICA SECTION 21B and FICA Reg. 15 & 16)

IDENTIFY VERIFY
Method of Beneficiary Determination: Trust Deed
Full Name & Surname: ID Document / Passport
Date of Birth: ID Document / Passport
Identity Number: ID Document / Passport
Proof of Address (not older than 3
Residential Address: months)

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 LEGAL ENTITIES: FOREIGN CORPORATIONS

Investments made by a Foreign Corporations

FOREIGN COMPANIES (FICA Reg. 9 & 10)

IDENTIFY VERIFY
Business Registration
Registered Name: Documents
Business Registration
Registration Number: Documents
Business Registration
Registered Address: Documents
Name under which Conducting Business in
Country of Incorporation : Corporate Letterhead
Proof of Address (not older
Operating Address in Country of Incorporation: than 3 months)
Name under which Conducting Business in South
Africa : Corporate Letterhead
Proof of Address (not older
Operating Address in South Africa: than 3 months)
Income Tax & VAT Numbers (if issued): SARS Documents
COMPANY REPRESENTATIVES:
For each Manager, Director and Authorised Individual of the Company (FICA
Reg. 9 & 10)
IDENTIFY VERIFY
Full Name & Surname: Passport

Date of Birth:
Identity Number:
Residential Proof of Address
Address: (not older than 3 months)

INDIVIDUAL SHAREHOLDERS OVER

25% (FICA Reg. 9 & 10)
IDENTIFY VERIFY
Share Certificate / Company
Proof of Shareholding: Share Register
Full Name & Surname: ID Document / Passport
Date of Birth: ID Document / Passport
Identity Number: ID Document / Passport
CORPORATE SHAREHOLDERS OVER
25% (FICA Reg. 7 & 8)
IDENTIFY VERIFY
Proof of Shareholding: Share Certificate / Company Share Register
Registered Name: Business Registration Documents
Registration Number: Business Registration Documents
Registered Address: Business Registration Documents

25
ACCEPTABLE DOCUMENTS FOR PROOF OF RESIDENTIAL ADDRESS

For documents issued on a monthly basis, the document provided to the FSP cannot
be older than 3 months.

For documents issued on an annual basis, the document provided to the FSP cannot
be older than 12 months.

The items below are acceptable in terms of proof of residential address.

 A lease/rental agreement.
 Affidavit from a CC/Company/Partnership or Mandated Official. Affidavit 6 from a
person co-habiting with the client.
 Affidavit from clients Employer.
 Bank Statements, must evidence an official bank stamp.
 Declaration from the clients Financial Advisor after an on-site visit - within 3
months of the on-site visit. Long term/short term insurance policy document
issued by an insurance company.
 Mortgage /home loan statement.
 Motor vehicle license documentation. Municipal rates and taxes invoice.
 Telephone or Cellular account.
 Utility Bill reflecting Erf/stand no if sent to a P O Box. Valid TV Licence.

26
ANNEXURE 3: SCREENING & WATCHLISTS

As part of the FSP’s ongoing due diligence practices, all underlying clients and
beneficial owners are screened against the Consolidated United Nations Security
Council Sanctions List. Utilising the services of DocFox (Pty) Ltd, the FSP and its
Associates also screen for anti-money laundering, sanction, organized crime and threat
finance as well as Politically Influential Person relationships.

Underlying clients and beneficial owners are currently screened against the following
lists:
 Afghanistan Sanctions
 Australian Department of Foreign Affairs and Trade Australian Listing of Terrorist
Organizations
 Belarus Sanctions
 Burundi Sanctions
 Commodity Futures Trading Commission Corruption Perceptions Index List
 Democratic Republic of Congo Sanctions
 Egypt Sanctions
 European Union Consolidated List FBI Most Wanted List
 Financial Action Task Force (“FATF”)
 FinCEN 314a Control List
 HM Treasury Consolidated List HM Treasury Investment Ban List Interpol Red
Notices
 Iran Sanctions
 Iran Sanctions (Human Rights)
 Iraq Sanctions
 ISIL and Al-Qaida Sanctions
 Lybia Sanctions
 North Korea Sanctions
 Office of Foreign Asset Control (“OFAC”) Consolidated Sanctions List Office of
Foreign Asset Control (“OFAC”) Sanctioned Country List
 Office of Foreign Asset Control (“OFAC”) SDN List – including the OFAC Non-
proliferation List Office of the Superintendent of Financial Institutions (“OSFI”) –
Terrorist List
 Office of the Superintendent of Financial Institutions (“OSFI”) – Unauthorised Bank
List
 Office of the Superintendent of Financial Institutions (“OSFI”) – United Nations Act
Sanctions Politically Exposed Persons (“PEPs”)
 Republic of Guinea-Bissau Sanctions Somalia Sanctions
 South Sudan Sanctions
 Syria Sanctions
 Tunisia Sanctions
 Ukraine Sanctions
 Ukraine Sanctions (Human Rights)
 United Nations Consolidated Sanctions
 U.S. Department of Commerce – Denied Persons List U.S. Department of
Commerce – Entity List
 U.S. Department of Commerce – Unverified List
 U.S. Department of State Foreign Terrorist Organizations Yemen Sanctions
 Zimbabwe Sanctions

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ANNEXURE 4: POLITICALLY INFLUENTIAL PERSONS (PIPs)

DOMESTIC PROMINENT INFLUENTIAL PERSONS

A domestic prominent influential person is an individual who holds, including in an acting

position for a period exceeding six months, or has held at any time in the preceding 12
months, in the Republic—

a prominent public function including that of—

 the President or Deputy President;

 a government minister or deputy minister;
 the Premier of a province; (iv) a member of the Executive Council of a province;
 an executive mayor of a municipality elected in terms of the Local Government:
Municipal Structures Act, 1998 (Act No. 117 of 1998);
 a leader of a political party registered in terms of the Electoral Commission Act, 1996
(Act No. 51 of 1996);
 a member of a royal family or senior traditional leader as defined in the Traditional
Leadership and Governance Framework Act, 2003 (Act No. 41 of 2003);
 the head, accounting officer or chief financial officer of a national or provincial
department or government component, as defined in section 1 of the Public Service
Act, 1994 (Proclamation No. 103 of 1994);
 the municipal manager of a municipality appointed in terms of section 54A of the
Local Government: Municipal Systems Act, 2000 (Act No. 32 of 2000), or a chief
financial officer designated in terms of section 80(2) of the Municipal Finance
Management Act, 2003 (Act No. 56 of 2003);
 the chairperson of the controlling body, the chief executive officer, or a natural person
who is the accounting authority, the chief financial officer or the chief investment
officer of a public entity listed in Schedule 2 or 3 to the Public Finance Management
Act, 1999 (Act No. 1 of 1999);
 the chairperson of the controlling body, chief executive officer, chief financial officer
or chief investment officer of a municipal entity as defined in section 1 of the Local
Government: Municipal Systems Act, 2000 (Act No. 32 of 2000);
 a constitutional court judge or any other judge as defined in section 1 of the Judges’
Remuneration and Conditions of Employment Act, 2001 (Act No. 47 of 2001);
 an ambassador or high commissioner or other senior representative of a foreign
government based in the Republic; or (xiv) an officer of the South African National
Defence Force above the rank of major-general;
 the position of—
o chairperson of the board of directors;
o chairperson of the audit committee;
o executive officer; or
o chief financial officer,
 of a company, as defined in the Companies Act, 2008 (Act No. 71 of 2008), if the
company provides goods or services to an organ of state and the annual
transactional value of the goods or services or both exceeds an amount determined
by the Minister by notice in the Gazette; or
 the position of head, or other executive directly accountable to that head, of an
international organisation based in the Republic.

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FOREIGN PROMINENT PUBLIC OFFICIALS

A foreign prominent public official is an individual who holds, or has held at any time in
the preceding 12 months, in any foreign country a prominent public function including
that of a—

 Head of State or head of a country or government; member of a foreign royal family;

 government minister or equivalent senior politician or leader of a political party;
 senior judicial official;
 senior executive of a state owned corporation; or high-ranking member of the
military.

29
 ANNEXURE 5

CDD CONFIRMATION CERTIFICATE

[Date]

[FSP Entity Name]

[FSP ADDRESS]

CDD Certificate of Confirmation with the Requirements to Identify and verify the
Identity of Clients in terms of the Financial Intelligence Centre Act, 1 of 2017
(“the Act”)

WHEREAS:

ABC (Pty) Ltd, (Registration number: XXXX/XXXXXX/XX), the Primary Accountable

Institution (“ABC”) established a business relationship with

[FSP Entity], (Registration number: XXXX/XXXXXX/XX), the Secondary Accountable

Institution (“FSP Entity”)

We confirm that:

1. We confirm that we are an accountable institution in terms of Schedule 1 of the Act

and acknowledge that the business conducted by us is governed by the Act and the
regulations issued under section 77 thereof. In particular, we confirm the following:

a. In terms of our Risk Management and Compliance Programme ordinarily

applied in the course of establishing business relationships or conducting
single transactions, we will have established and verified, in accordance with
the provisions of Section 21, 21(A), 21(B), 21(C), 21(D), 21(E), 21(F), 21(G)
and 21(H) of the Act, the identity of every client on whose behalf we will be
establishing a business relationship or concluding single transactions with
FSP Entity.

b. In terms of our Risk Management and Compliance Programme ordinarily

applied in the course of establishing business relationships or conducting
single transactions, we will keep record of, in accordance with the Section 22
and 22A of the Act, the identity of every client, the manner in which the
identity was established and any document or copy of document obtained to
verify the client’s identity in terms of section 21, 21(A), 21(B), 21(C), 21(D),
21(E), 21(F), 21(G) and 21(H) of the Act, on whose behalf we will be
establishing a business relationship or concluding single transactions with
FSP Entity.

c. We are responsible to ensure that the client verification documents mentioned

above comply with the requirements of the Act and, should it be found that the
our records are not in compliance with the requirements of the Act, we shall
assume all costs of any measures taken by the Product Provider to obtain the
required compliant client verification documents for the applicable client(s).

2. We acknowledge that FSP Entity reserves the right to request any identification and
verification documents from ABC, with respect to any of the mutual clients that fall
within the scope of this certification and that the Product providers may from time to
time review our records in order to ensure compliance with the requirements of the
Act.

This certification shall remain valid from the date of signature hereof until such time as
ABC gives written notification to the contrary to the Compliance Officer of FSP Entity.

30
Signed:
Name [Signatory name(s)]
Designation [Signatory designation(s)]

ANNEXURE 6

ANTI-MONEY LAUNDERING REPORT

A copy of the completed report must be retained by the person reporting the suspicious
activities elaborated on therein. This retained copy should be signed by the MLRO.

DETAILS OF CLIENT BEING REPORTED

Full name:

Address (registered if required):

Postal Physical:

Telephone numbers (as appropriate):

Home:

Work:

Cell:

Email:

Identity /passport / company

registration No:

Income Tax Number:

____________________________
Bank account details (as
appropriate):

31
Name of organization client represents or
works for:

Capacity:

NATURE OF SUSPICION:

REASON(S) FOR SUSPICION:

SUPERVISOR / MANAGER REFERRED TO:

Name:

Position:

Contact details:

Supervisor / Manager Comments:

Attach any copy of supporting documentation to this report. Further information

can be written on the back of the report.

32
NAME OF STAFF MEMBER MAKING THIS REPORT

Contact details:

Date handed to MLRO:

SIGNATURE:

33
 RECEIPT FOR ANTI-MONEY LAUNDERING REPORT HANDED TO MONEY
LAUNDERING REPORTING OFFICER

Report received from:

Name: ________________________________________________________

Email address: ______________________

Cell: _________________________

Date received:______________________

Signed by:

___________________

Signature:

___________________

Entered in registry:

34