Guidance: International Fund Transfer Reports

Guidance: International Fund Transfer Reports logo

GN 9 guides respect of certain accountable institutions’ obligation to file international funds transfer reports with the FIC, in terms of section 31 of the Financial Intelligence Centre Act, 2001 (Act 38 of 2001).

Draft Guidance Note 104 was initially made available for consultation, and comments were invited by accountable institutions, supervisory bodies and all other persons from 1 March 2019 to 1 April 2019. All comments received were considered and incorporated in the updated draft GN 104A where appropriate. 

Draft Guidance Note 104A was made available for a second round of consultation, and comments were invited by accountable institutions, supervisory bodies and all other persons from 19 January 2023 to 1 February 2023. All comments received were considered and incorporated into the final GN 9 where appropriate.

Click here to download the Guidance Note:

https://www.fic.gov.za/wp-content/uploads/2023/11/2023.11-GN-Guidance-note-9.pdf

Relevance to Auditors, Independent Reviewers & Accountants:

  • The Financial Intelligence Centre Act (FICA) is yet another piece of legislation that your clients must comply with, and which you must assess compliance with.  If they don’t comply with the relevant laws and regulations, you have certain reporting obligations in terms of NOCLAR (Non-Compliance with Laws And Regulations) – this could include reporting to management, qualifying your audit opinion, reporting a Reportable Irregularity, etc.

  • As an auditor and independent reviewer, you need to consider amendments, regulations, guidance and directives that are gazetted relating to FIC and accountable institutions, to ensure that your clients (or even your practice) comply with their reporting obligations.

Relevance to Your Clients:

  • Relevant entities (specifically accountable institutions) must comply with the FIC Act, otherwise, they could be held liable.

  • Relevant entities should be aware of amendments, regulations, guidance and directives that are gazetted relating to FIC and accountable institutions, to ensure that they comply with their reporting obligations.

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