FIC: Updated draft PCC 23A – Guidance on the interpretation of credit providers

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Summary:

The Financial Intelligence Centre (FIC) has published the updated draft Public Compliance Communication 23A (PCC 23A), to provide guidance on the interpretation of Schedule 1, item 11 accountable institutions, namely Credit Providers, and the potential risk indicators.

Article:

This PCC provides guidance on the practical interpretation and application of the definition of credit providers and an overview of certain anti-money laundering, counter terrorist financing and counter proliferation financing vulnerabilities.

This PCC provides clarity on the interpretation of a credit provider as designated in amended item 11 of Schedule 1 to the FIC Act.

Further, the PCC highlights vulnerabilities faced by credit providers and provides risk indicators that can be considered by a credit provider when determining money laundering, terrorist financing and proliferation financing (ML, TF and PF) risks presented in their client engagements.

Examples of credit providers, credit agreements and incidental credit are provided in this draft PCC.

Contents:

  1. Introduction
  2. Interpretation of a Credit Provider
  3. Potential Anti-Money Laundering, Counter Terrorist Financing and Counter Proliferation Financing Risk Indicators
  4. Consultation
  5. Communication with the Centre

Any questions or requests relating to this draft PCC 23A may be sent to the Centre only at [email protected].

Deadline for comments is Friday, 7 February 2025.

Click here to download the 12-page Draft Guidance document:

https://www.fic.gov.za/wp-content/uploads/2024/12/2024.12-draft-PCC-23a.pdf

Relevance to Auditors, Independent Reviewers & Accountants:

  • Auditors, Independent Reviewers and Accountants should be aware of the latest publications and guidance issued by regulators, such as the FIC – to enable their assessment of accountable institutions’ compliance with FICA.
  • When advising clients or performing this function on their behalf, practitioners should be aware of the finer details and specific guidance on Credit Providers.

Relevance to Your Clients:

  • Relevant Accountable Institutions (companies and CCs) should be aware of the latest publications and guidance issued by regulators, such as the FIC.

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