After Registering with the Financial Intelligence Centre

After Registering with the FIC

Registering with the Financial Intelligence Centre (FIC) is a crucial step for any accounting firm aiming to combat financial crimes such as money laundering, terrorist financing, and proliferation. Following this registration, the next essential phase is the development and implementation of a Risk Management Compliance Programme (RMCP). The Financial Intelligence Centre Act (FICA) and the guidance issued by the FIC prescribe specific requirements that must be included in the RMCP. Ensuring comprehensive compliance with these requirements is not only a legal obligation but also a fundamental aspect of maintaining the integrity and reputation of the firm.

Developing the RMCP

Creating an effective RMCP involves meticulous planning and a thorough understanding of the FICA legislation and FIC guidelines. It is crucial that the RMCP incorporates all prescribed elements, leaving nothing out. The following are some of the key components that should be addressed in the RMCP:

Identification and Verification of Client Identities:

The RMCP must outline the procedures for identifying and verifying the identities of clients. This is fundamental in preventing fraudulent activities and ensuring that the firm engages only with legitimate clients.

Risk Assessments:

The RMCP should detail the risk assessment methodologies the firm will follow to evaluate the risk profile of each client. This includes determining the client's risk level (low, medium, high) based on various factors such as the nature of their business, geographical location, and transaction patterns.

Handling High-Risk Clients:

Specific protocols for dealing with high-risk clients must be established. These clients require enhanced due diligence and more stringent monitoring to mitigate potential risks effectively.

Reporting of Suspicious Transactions:

The programme should include detailed procedures for reporting suspicious transactions and clients to the FIC. This is a critical component in the fight against financial crimes.

Cash Reporting:

Specific guidelines for reporting cash transactions above a certain threshold must be included in the RMCP.

Client Screening:

The RMCP must ensure that clients are screened against the FTS lists. Special rules must be applied if a client appears on these lists.

Employee Vetting and Training:

The RMCP should address the vetting of employees to ensure they are fit and proper to perform their duties. Additionally, comprehensive training on FIC legislation and the firm's RMCP must be provided to all employees.


The programme must specify how documents will be kept and for how long. This includes maintaining records of client identification, transaction details, and reports of suspicious activities.

Once the RMCP is developed, it must be rolled out across the firm. This involves obtaining approval from top management, which underscores the importance of commitment from the highest level of the organization. The RMCP should be made accessible to all employees, ensuring that everyone is aware of and understands the compliance requirements and procedures.

An RMCP is not a static document; it must be a living programme that evolves with changes in legislation and the firm's circumstances. Annual reviews are essential to ensure that the RMCP remains current and effective. This includes updating policies and procedures in response to new regulatory requirements or shifts in the firm's risk environment.

The development and implementation of a comprehensive RMCP are critical for any accounting firm registered with the FIC. By adhering to the prescribed requirements and maintaining a robust compliance programme, firms can effectively mitigate the risks associated with financial crimes. This not only ensures compliance with legal obligations but also enhances the firm's reputation and trustworthiness in the eyes of clients and regulatory authorities. Through continuous review and employee training, the RMCP becomes an integral part of the firm's operations, fostering a culture of compliance and vigilance against financial misconduct.

Join Lynette this June for a webinar about FIC:

  • Click here for "Understanding Your Firms Obligations with the Financial Intelligence Centre" on June 18th.
  • Click here for "How to Implement an RMCP in your Firm After Registering with the FIC on June 21st.

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