Guide to identifying and reporting suspicious behaviours and transactions

Guide to identifying and reporting suspicious behaviours and transactions logo

This guide unpacks each of the following reporting duties to FIC set out in Part 3 of the FICAA (Financial Intelligence Centre Amendment Act):

  1. Accountable Institutions are obligated to report any suspicious behaviour or transactions to the FIC

  • STR / SAR – Suspicious Transaction Report / Suspicious Activity Report

  1. This includes reporting any cash transaction over R49 999

  • CTR – Cash Threshold Reporting

  1. When you think your client may possess or control property belonging to a client that could be linked to terrorism

  • TPR – Terrorist Property Report

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https://blog.docfox.co.za/reporting-suspicious-behaviours-and-transactions?utm_source=website&utm_medium=article&utm_campaign=GoLegal+April+2023

Relevance to Auditors, Independent Reviewers & Accountants:

  • FICA and FICAA are more pieces 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, independent reviewer and accountant, you need to be aware of useful guides that you and your clients can use in practice.

  • You need to consider that your clients – especially those who are regarded as accountable institutions, are complying with their responsibilities in terms of FICA and FICAA.

Relevance to Your Clients:

  • An accountable institution must comply with the FIC Act and its obligations, otherwise, it could be held liable.

  • Your clients need to be aware of useful guides that they can use in practice.

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