FICA Induction: Practical Compliance for Employees and Compliance Officers

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

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

FICA Induction: Practical Compliance for Employees and Compliance Officers

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 firm
• What constitutes a money laundering offence under POCA
  
  Accountable Institutions and Governance Responsibilities
• When and why a firm is 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:

• Different services provided by the firm
• Client types and structures
• Geographic and transactional risk factors

• Risk assessment and risk rating methodologies
  
  Customer Due Diligence (CDD)

• CDD requirements for:

• Natural persons
• Legal persons
• Partnerships
• Trusts

• Identification and verification procedures
• Identifying beneficial owners of legal entities and trusts
• 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 firm
• 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
• Reporting obligations when performing:

• Audits
• Independent reviews
• Tax services

• What must be reported and to whom:

• Suspicious transactions → FIC
• Reportable irregularities → IRBA
• Certain disclosures → CIPC

• 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
• Managing client relationships after reporting
  
  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

ISQM 1 Training outline:

• What is a quality management systeM
• How does this differ from the previous ISQC
• The risk-based approach
• Identifying quality objectives for your firm
• Identifying and assessing the risk to these quality objectives based on the nature and circumstances of the firm
• Implementing responses over these risks
• Performing the risk-based approach for each component of quality management
• Resources required to document and implement the responses
• Documentation of the quality management system
• Monitoring and evaluation of the quality management system
• Root cause analyses
• Responding to deficiencies identified