As auditors, it is not only imperative to ensure that your own firm complies with FICA, but also that your clients comply with the Act.

As such, it is good practice to have a set of internal rules to ensure that your firm is compliant and to give guidance to trainees and employees when faced with FICA during audits of general businesses, as well as other accountable institutions.

Even though, as an audit firm you might not need to register as an accountable institution, there is a chance that some of your clients will be accountable institutions. Therefore, will need to understand the stringent requirements placed on them by the Act to assess non-compliance with Laws and Regulations during the audit. The obligations placed on the auditor by the FIC Act includes the following:

• Advising clients on compliance obligations
• When accepting a client, ensuring that they do not partake in money laundering activities
• Assessing the risk of material misstatement due to non-compliance with Laws and Regulations
• Evaluating the effect of non-compliance on the business, especially in terms of going-concern issues due to the high penalties imposed in terms of the FIC Act
• Reporting the non-compliance and money laundering transaction to IRBA in the form of a reportable irregularity.
• Reporting as a business to the FIC when directly involved in a suspicious and unusual transaction
• Assessing the impact of potential non-compliance on the audit report.
In order to perform these obligations effectively, it is important that everyone within the firm have a knowledge of and understand the FIC Act in terms of what would constitute non-compliance, especially with regards to the clients who are accountable institutions and carry a higher risk of non-compliance.
With this in mind, ProBeta Training has developed an updated FICA manual of internal rules which can be used by accounting and auditing practices in general. This manual includes:

• An overview of the Act
• The responsibilities of all businesses with regards to the Act
• The reporting obligation of all registered auditors
• Internal rules and policies a firm can implement to ensure compliance with these responsibilities.
• These rules and policies were designed to ensure compliance with all the requirements of the FIC Act, whether for an accountable institution or not.
The FICA Manual can be used by your firm to:
• Ensure that the correct policies and procedures are in place in order to comply with the FIC Act
• Use as a training tool for employees to update their knowledge in terms of the Act, as well as a standard to evaluate your clients against
• Ensure compliance during an audit.

These rules have been designed in such a way, that additions and adjustments can be made easily to suit any business. The generic internal rules can also be added to any existing policy manual regardless of the Quality Control Manual you have in place, because the internal rules of the FICA manual are generic. Such adjustments may however, in most cases relate to certain internal matters, such as who is responsible for the identification of clients, who is responsible for verification thereof and who is responsible for the storage of the data.