Introduction to the Financial Intelligence Centre Act (FICA)

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1 FORENSIC/ ANTI-MONEY LAUNDERING Introduction to the Financial Intelligence Centre Act (FICA) ADVISORY

2 2

3 Introduction to Money Laundering 3

4 RECENT ESTIMATES SUGGEST THAT US$500 BILLION TO US$1 TRILLION IS LAUNDERED WORLDWIDE ANNUALLY. IT IS ONLY THROUGH THE VIGILENCE OF FINANCIAL INSTITUTIONS THAT THE SYSTEM CAN BE PROTECTED FROM PROVIDING CRIMINALS OR TERRORISTS WITH A MECHANISM FOR CONCEALING THE PROCEEDS OF ILLICIT AND CORRUPT ACTIVITY 4

5 What is Money Laundering Money laundering is the process by which criminals attempt to hide and disguise the true origin and ownership of the proceeds of their criminal activities, thereby avoiding prosecution, conviction and confiscation of the criminal funds COMMONLY REFERRED TO AS THE PROCEEDS OF CRIME 5

6 The Three C s of Money Laundering Convert illicit cash to another asset Conceal the true source or ownership of the criminal proceeds Create the perception of legitimacy for the criminal proceeds

7 Stages of Money Laundering Placement: Physical disposal of cash proceeds derived from illegal activity Layering: Separating illicit proceeds from their source by creating complex layers of financial transactions designed to hamper audit trail, disguise origin of funds and provide anonymity to true owner Integration: Placing laundered proceeds back into financial system in such a way as to appear to be legitimate business funds 7

8 The expanded crime of Money Laundering September 11, 2001 changed the way traditional money laundering (proceeds of crime) was viewed by the international community. Money laundering was expanded to include the use of legal funds for illegal purposes (ie terrorist financing and tax evasion) COMMONLY REFERRED TO AS THE PROCEEDS FOR CRIME

9 Developing Trends in Money Laundering General Trends Becoming more sophisticated Concealment within business structures Misuse of legitimate businesses Use of false identities or documents Exploiting international jurisdictional issues Use of anonymous asset types Proceeds of corruption 10

10 International response to Money Laundering 11

11 12

12 Terrorist Financing Reward Program (US Treasury 03) 13

13 International Initiatives against Money Laundering Basel Committee on Banking Supervision Customer Due Diligence (CDD) The Vienna Convention mainly linked to drug trafficking The Third EC Money Laundering Directive Financial Action Task Force (FATF) 40 Recommendations 9 Special recommendations on Terrorist Financing USA Patriot Act 14

14 An Anti-Money Laundering Control in South Africa 15

15 South African Anti-Money Laundering Legislation Prevention of Organised Crime Act, 121 of 1998 ( POCA ) Financial Intelligence Centre Act, 38 of 2001 ( FICA ) Protection of Constitutional Democracy Against Terrorist and Related Activities Act, 2004 ( POCDATARA ) Money Laundering and Terrorist Financing Control Regulations B

16 POCA Introduce measures to combat organised crime, money laundering and criminal gang activities Prohibit certain activities relating to racketeering Provide for the prohibition of money laundering Create an obligation to report certain information Criminalise certain activities associated with gangs Provide for the recovery of the proceeds of unlawful activity B

17 FICA Establishment of the Financial Intelligence Centre (FIC) Establishment of the Money Laundering Advisory Council Imposition of both administrative duties and reporting obligations B

18 POCDATARA Provide for measures to prevent and combat terrorist and related activities, and the financing of terrorism and related activities Provide for the offence of terrorism Provide for Convention offences Give effect to international instruments dealing with terrorist and related activities Provide for a mechanism to comply with UN Security Council resolutions Provide for investigative measures in respect of terrorist and related activities B

19 Money Laundering Control in Accountable Institutions - FICA The Financial Intelligence Centre Act (FICA) imposes certain duties on institutions and other persons who might be used for money laundering and/or the financing of terrorist and related activities Institutions consist of : Accountable institutions (includes estate agents) Supervisory bodies (Estate Agents Board) Reporting Institutions B

20 The difference between POCA & FICA offences POCA FICA Money laundering offences Criminals who commit crimes Knowing/unwitting helpers. Non-compliance with duties aimed at preventing money laundering. E1.2 21

21 How FICA operates REGULATIONS FICA GUIDELINES E X E M P T I O N S E1.2 22

22 FICA: Estate Agents Duties Accountable institutions (including Estate Agents) have a duty to: Perform Client take-on (KYC) (Section 21) Perform Record-keeping (Section 22) Perform Transaction reporting suspicious and cash (Section 27 32) Compile Internal rules AML compliance manual (Section 42) Appoint a Money Laundering Reporting Officer - MLRO (Section 43) Provide Formal training to all employees (Section 43) 23

23 Screening UN 1267 list POCDATARA section 25 UN has identified: entities who commit, or attempts to commit, any terrorist and related activity or participates in or facilitates the commission of any terrorist and related activity entities against whom Member States of the United Nations must take the actions specified in Resolutions of the said Security Council, in order to combat or prevent terrorist and related activities HOW DO I ENSURE COMPLIANCE 24

24 Screening - Politically Exposed Persons Why a money laundering/terrorist financing risk? PEPs as a category of high risk clients Common Risk Mitigating Controls Recommendation 6 (FATF), Guidance Note 3 (FICA) Institution must Have systems to identify a prospective client as a PEP Senior management approval Source of funds Enhanced monitoring 25

25 FICA: Estate Agents Duties Exemptions Managing agents who collect sectional title and share block levies are exempted from CIV Not exempted from reporting suspicious transactions Managing agents who perform letting functions over and above their levy collection tasks must comply with FICA 26

26 FICA - Chapter 3 Part 1 Part 2 Part 3 Part 4 Duty to CIV clients Duty to keep records Duty to report Compliance duty 27

27 Customer Identification and Verification 28

28 Customer Identification and Verification (CIV) Section 21 and Regulations 3 19 prescribe the CIV requirements Exemption 2 relaxed/simplified due diligence - may accept a mandate and take preparatory steps, but may not conclude a transaction before identification and verification Regulation 21 higher risk customers requires additional information to be obtained Source of client s s income Source of funds which that client expects to use in the course of the business relationship Section 46 failure to identify persons imprisonment for 15 years or fine not exceeding R10 million B2.1 29

29 Customer Identification and Verification (CIV) Accountable Institutions are required to follow prescribed steps in order to: Establish and verify the identity of the client If the client is acting on behalf of another person, to establish and verify: The identity of that other person The client s s authority to establish the business relationship B2.1 30

30 CIV What does this mean for Estate Agents Estate Agents granted a mandate to sell or lease must conduct CIV on their customers If you accept a mandate from a buyer or lessee this is your client conduct CIV Need to obtain certain identification information and documentation Need to verify certain information 31

31 CIV When must I conduct CIV procedures Exemption 2 Prior to accepting a mandate from a client, the client s identity must be established Prior to performing the mandate, the client s s identify must be verified (before an enforceable sale or lease agreement in respect of the property is concluded) In addition to the above, the Source of Funds to be used must be obtained. 32

32 CIV Joint ownership If the property is owned by 2 or more persons, must I identify and verify all the owners? Yes! 33

33 CIV Joint sole mandate If two agents have a joint sole mandate, who must identify and verify the client s s identity, or must this be done by both agents? Agree who is going to identify and who is going to verify. Both agents do not have to do CIV 34

34 Customer Identification and Verification Prescribed identification and verification steps are set out in the Regulations for the following client types: SA Citizens Foreign nationals Close Corporations SA Companies Foreign companies Partnerships Trusts B2.1 35

35 KYC Requirements SA citizens and nationals Full name (Identify and verify) Date of birth (Identify and verify) Identity number (Identify and verify) SA income tax registration number (currently exempted) Residential address (Identify and verify) 36

36 KYC Requirements Foreign nationals Full name (Identify and verify) Date of birth (Identify and verify) Nationality (Identify and verify) Passport number (Identify and verify) SA income tax registration number (currently exempted) Residential address (Identify only) 37

37 KYC Requirements SA Companies Registered name Registration number Registered address Trade name Business address and if operate from multiple addresses, address of office seeking to establish the relationship; and address of head office Full names, Date of birth, Identity number (SA citizen or resident) or nationality (if foreigner) of manager or each natural person who purports to be authorised to establish a business relationship, or natural person holding more than 25% of the voting rights 38

38 KYC Requirements SA Companies Registered name, Registration number, Registered address, Trade name, Business address of each company/cc that holds 25% or more of the voting rights; Name, Registration number, Registered address of each foreign company that holds 25% or more of the voting rights; Name of legal person, Address from where it operates, Legal form of each other legal person that holds 25% or more of the voting rights; Name of the partnership holding 25% or more of the voting Identifying name and number of the trust that holds more than 25% of the voting rights 39

39 KYC Requirements Close Corporations Registered name Registration number Registered address Trade name Business address and if operate from multiple addresses, address of office seeking to establish the relationship, and address of head office Full names, Date of birth, Identity number (SA citizen or resident) or nationality (if foreigner) of: each member each natural person who purports to be authorised to establish a business relationship 40

40 KYC Requirements Close Corporations Residential address and contact particulars of: each member each natural person who purports to be authorised to establish the relationship SA Income tax and VAT registration numbers (currently exempted) Authorisation of persons acting on behalf of the close corporation, to establish the relationship 41

41 KYC Requirements Foreign Companies Name Registration number Registered address Business name in country of incorporation Address from where it operates in country of incorporation, or if from multiple addresses, the address of its head office Trade name in SA Business address in SA and if operate from multiple addresses, the address of office seeking to establish the relationship 42

42 KYC Requirements Foreign Companies Full names, Date of birth, Identity number (SA citizen or resident) or nationality (if foreigner) of: manager of affairs in SA each natural person who purports to be authorised to establish the t relationship natural person holding more than 25% of the voting rights Residential/business address and contact particulars of: manager of affairs in SA each natural person who purports to be authorised to establish a business relationship natural person or legal person, partnership or trust holding more than 25% of the voting rights 43

43 KYC Requirements Foreign Companies Registered name, Registration number, Registered address, Trade name, Business address of each South African company that holds 25% or more of the voting rights Name, Registration number, Registered address of each foreign company that holds 25% or more of the voting rights Name of legal person, Address from where it operates, and Legal form of each other legal person that holds 25% or more of the voting rights Name of the partnership holding 25% or more of the voting rights 44

44 KYC Requirements Foreign Companies Identifying name and number of the trust that holds more than 25% of the voting rights SA Income tax and VAT registration numbers (currently exempted) Authorisation of person acting on behalf of the foreign company, to establish the relationship. 45

45 KYC Requirements Other Legal Persons Name of legal person Address from where it operates Legal form SA income tax number (currently exempted) Full names, Date of birth, Identity number (SA citizen or resident) or nationality (if foreigner) of each natural person who purports to be authorised to establish the relationship Residential address and contact particulars of each natural person who purports to be authorised to establish the relationship Authorisation of person acting on behalf of the other legal persons, to establish the relationship 46

46 KYC Requirements Partnerships Name If partner is a natural person and SA citizen or resident: Full names Date of birth Identity number If partner is a natural person and foreigner Full names Date of birth Nationality[reg 13(b)(i)] If partner is a natural person and foreigner Full names Date of birth Nationality[reg 13(b)(i)] If partner is a South African company or close corporation: Registered name Registration number Registered address Trade name Business address 47

47 KYC Requirements Partnerships If partner is a foreign company Name Registration number Registered address If partner is an other legal person Name Address Legal form If partner is a trust identifying name number 48

48 KYC Requirements Partnerships Full names, Date of birth, Identity number (SA citizen or resident) or nationality (if foreigner) of the person who: exercises executive control over the partnership each natural person who purports to be authorised to establish the relationship Authorisation of person acting on behalf of the partnership, to establish the relationship 49

49 KYC Requirements Trusts Identifying name and number Address of the Master of the High Court where trust is registered, if applicable SA income tax registration number (currently exempted) Natural person Full names Date of birth Identity number (if SA citizen or resident) or nationality (if foreigner) f of each trustee each natural person who purports to be authorised to establish a relationship Beneficiaries referred to by name in the trust deed or other founding instrument founder Where the beneficiaries are not referred to by name, it should be noted how the beneficiaries of the trust are determined [reg[ 15(e)(ii)]. This information can be verified with reference to the trust deed or other founding document in terms of which the trust is created [reg[ 16(1)(a)]. 50

50 KYC Requirements Trusts SA Company or Close Corporation Registered name Registration number Registered address Trade name Business address of each trustee beneficiaries referred to by name in the trust deed or other founding instrument founder 51

51 KYC Requirements Trusts Foreign company Name Registration number Registered address of each trustee beneficiaries referred to by name in the trust deed or other founding instrument founder 52

52 KYC Requirements Trusts Other legal person Name of legal person Address from where it operates Legal form of each trustee beneficiaries referred to by name in the trust deed or other founding instrument founder 53

53 KYC Requirements Trusts Partnership Name of the partnership of each trustee beneficiaries referred to by name in the trust deed or other founding instrument founder Trust Identifying name and number of the trust of each trustee beneficiaries referred to by name in the trust deed or other founding instrument founder 54

54 KYC Requirements Trusts Residential address and contact particulars of each trustee each natural person who purports to be authorised to establish a business relationship each beneficiary of the trust referred to by name in the trust deed or other founding instrument the founder Authorisation of persons acting on behalf of the trust, to establish the relationship 55

55 Record keeping 56

56 Duty to keep records Keep all offer to purchase documents for a period of 5 years after sale has been concluded Keep records accessible Store electronically or on paper. Section 47 Criminalises non-compliance 15 years imprisonment and fine not exceeding R10 million B2.2 57

57 Reporting obligations 58

58 Duty to report suspicious & unusual transactions In general: Report all suspicious transactions What is a suspicious transaction? Report via internal rules & procedures. Continue with transactions Don t tip off Institution to decide whether or not to report to the FIC Failure to report suspicious transactions 15 years imprisonment and R10 million B2.3 59

59 Reporting Obligations In force: Suspicious and unusual transactions S 29 FICA: Person who carries on a business or is in charge of or o manages a business or who is employed by a business FIC 15 days Terrorist property S 28A FICA: Accountable institutions only FIC 5 days Suspected terrorist or whereabouts S 12 of POCDATARA: All persons SAPS 60

60 Reporting Obligations Not yet in force (FICA): Cash transactions above limit S 28: Reporting and Accountable institutions Cash across borders S 30 - All Electronic transfers S 31 Accountable institutions 61

61 Protection for reporter ito POCA & FICA Not compelled to testify in court Identity secret unless you agree to testify Breach of confidentiality is not punishable Protection from prosecution for ML offence. B2.4 62

62 Internal Rules 63

63 Duty to implement internal measures Develop and implement rules & procedures Make rules & procedures available to all Train employees Appoint a MLCO Section 62: Criminalises non- compliance imprisonment not exceeding 5 years and fine not exceeding R1 million B2.5 64

64 FICA: Internal Rules Internal Rules Section 42 must formulate and implement: Manual Concerning: Identification/verification of persons Record keeping Reporting transaction Available to employees Train employees Prosecution utilise to determine reasonable conduct Section 61: Criminalise - imprisonment not exceeding 5 years and fine not exceeding R1 million 65

65 Amendment of FICA 66

66 Financial Intelligence Centre Amendment Act (2008) Application of FICA when in conflict with other laws Section 3 - giving supervisory bodies enforcement powers Section 40 information sharing Section 43A FIC Directives Section 43A(2) FIC or Supervisory Body may issue directive to any category of accountable institutions/reporting institutions Section 43A(3) Specific directive to produce information, refrain from doing something, perform act to remedy non-compliance with FICA. Costs Section 43A(6)(b) supervisory body may issue directive 67

67 Financial Intelligence Centre Amendment Act (2008) (cont) Section 43B Register of Accountable and Reporting Institutions Section 45 Enforcement powers to supervisory bodies Costs incurred to be paid by member Chapter 4 Section 45A: appointment of inspectors suitable person may be appointed by the Director of the FIC or head of supervisory body as an inspector Section 45B inspections Costs incurred to be paid by member expenses necessarily incurred No warrant required open strong rooms, access computers etc 68

68 Financial Intelligence Centre Amendment Act (2008) (cont) Section 45C administrative sanctions Issued by either the FIC or supervisory body, irrespective of criminal proceedings Section 45C(3) - Examples of administrative sanctions: A caution not to repeat misconduct A reprimand Directive to take remedial action Suspension Financial penalty max R10m in respect of natural person and R50m in respect of legal person Section 45C(4)(b) personal liability payment of financial penalty Financial Penalties paid into Criminal Assets recovery Account (CARA) Section 45C(7)(b) failure to pay penalty/lodge an appeal, notice has effect of civil judgement lawfully given in court 69

69 Financial Intelligence Centre Amendment Act (2008) (cont) Section 51A offence for not making a Section 28A report rectify previous omission Section 61A failure to register with the FIC, guilty of an offence Section 68 penalties: Sub-section 1: Fine increased to R100 million from R10 million (general Chapter 3 offences) Sub-section 2: Fine increased to R10 million from R1 million (specific offences) 70

70 An Anti-Money Laundering Program 71

71 Elements of an Anti-Money Laundering Compliance Programme C O M P L I A N C E AML Policy RECORD KEEPING KYC Procedures TRAINING ACCOUNT MONITORING ANNUAL REVIEW OF AML PROGRAMME 72

72 The three dimensions of AML Know your process Know your customer Client Profile Risk Categories Workflow management Know your transaction Transaction Monitoring Know your customer Text mining Client identity and background Beneficial owner and background Source of funds Monitoring over time Know your process Policies, procedures and controls Roles and responsibilities Know your transaction Data mining Trace complex, large transactions Spot unusual behaviour Large volume of transactions The needle in the haystack 73

73 Internal audit reviews A model money laundering framework Senior management Reporting Legal and regulatory requirement Policies Procedures MLRO* Monitoring Verify identity Client Monitoring for suspicious transactions Internal reporting to MLRO External reporting to authorities Training and awareness Local and international pronouncement s Record Keeping *Money Laundering Reporting Officer 74

74 Presenter s s contact details Kevin West KPMG South Africa

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