Learning Outcomes

By the end of the course, participants will be able to:

• Understand the purpose and structure of FICA and related legislation
• Understand why the entity is an Accountable Institution and the implications thereof
• Recognise suspicious and unusual transactions during client interactions
• Apply the entity’s RMCP and risk-based approach in practice
• Understand reporting obligations, escalation channels and confidentiality constraints
• Distinguish between employee responsibilities and compliance officer duties
  
  

Regulatory Framework and Legislative Overview

• Purpose and objectives of the Financial Intelligence Centre Act
• Overview of related legislation:

• POCA (Prevention of Organised Crime Act)
• POCDATARA
• PRECCA

• Outline of key FICA sections relevant to employees and compliance officers
• Consequences of non-compliance: enforcement actions and penalties

Understanding Money Laundering and Terrorist Financing

• Definition and stages of money laundering
• How money laundering affects the accounting and professional services sector
• Common typologies relevant to services provided by the entity’s industry
• What constitutes a money laundering offence under POCA

Accountable Institutions and Governance Responsibilities

• Why are we regarded as an Accountable Institution
• Duties and responsibilities of Accountable Institutions
• Appointment, role and accountability of the compliance/reporting officer
• Oversight responsibilities of partners, directors and senior management

Risk Management and Compliance Programme (RMCP)

• Purpose and legal requirement for an RMCP
• Key components of an effective RMCP
• Implementing and maintaining the RMCP in practice
• Training requirements for all employees
• Employee screening and ongoing compliance culture

Risk-Based Approach to Client Engagements

• Principles of the risk-based approach under FICA
• Identifying inherent risks linked to:

• Client types and structures
• Geographic and transactional risk factors

• Risk assessment and risk rating methodologies

Customer Due Diligence (CDD)

• CDD requirements for:

• Natural person
• Legal persons

• Identification and verification procedures
• Identifying beneficial owners of legal entities
• New and enhanced reporting requirements relating to beneficial ownership

Sanctions, PEPs and High-Risk Clients

• Scrutinising clients against:

• United Nations Consolidated Sanctions List
• Targeted Financial Sanctions (TFS) lists

• Freezing of assets and implementation of financial sanctions
• Dealing with Domestic and Foreign Politically Exposed Persons (DPEP and FPEP)
• Enhanced due diligence and ongoing monitoring requirements
  
  

Reporting Obligations and Escalation Procedures

• Internal reporting procedures within the entity
• Reporting to the Financial Intelligence Centre (FIC):

• Suspicious Transaction Reports (STRs)
• Cash Transaction Reports (CTRs)
• Terrorist activity reports (POCDATARA)

• Reports relating to bribery, extortion or fraud (PRECCA)
• Information sharing obligations and limitations

Reporting in Professional Engagements

• What must be reported and to whom to the FIC
• Practical reporting decision-making scenarios

Confidentiality, Client Privilege and Legal Protections

• How confidentiality and client privilege interact with FICA reporting
• Legal protections for reporters acting in good faith

Practical Application and Case Studies

• Recognising suspicious transactions during client engagements
• Applying the RMCP in day-to-day work
• Common red flags for employees and compliance officers
• Practical guidance on fulfilling reporting duties effectively
  
  
  

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