FICAA - Important information about business processing
As of 2 April 2019, some important changes to the Financial intelligence Centre Act (FICA) become effective which will have a direct impact on certain processes across the industry. The primary objectives of these changes are to: verify, screen and risk-rate your clients.
As a result of this, we would like to bring your attention to very important information regarding our business processing which will also help you avoid unnecessary delays:
- Verification of the client: In terms of the new FIC Amendment Act, Nedgroup Investments will no longer place reliance on any third party to act as the “primary” accountable institution. This means that we must have FICA documents on record for our clients. We are therefore removing the primary accountable institution section from our instruction forms. Please note that going forward, we will require all relevant identification documents as stipulated on our forms to be submitted to avoid processing delays.
- Screening the client (and associated parties): In order to determine whether a prospective client is a domestic prominent influential person (PIP) or a foreign prominent public official (FPPO), we are required to screen investors and all linked parties - such as persons acting on behalf of; 3rd party funders; beneficiaries and beneficiary/ controlling persons on legal entities - against all watchlists before accepting their instructions.
- Risk Rating the client: As part of the requirements to risk-rate each client, certain clients, such as the ones mentioned above (PIP’s and FPPO’s) may be subject to an enhanced assessment which could also result in delays in processing. Additional mandatory fields have been added to the below application forms:
- initial investment,
- additional investment,
- debit order initiation,
- debit order change, or
- static instruction.
Please ensure that all the information in the additional fields is filled in as we will not be able to proceed with the instruction without it.
By making use of our paperless, digital onboarding you can bypass the manual form completion process altogether. However, if you choose to complete manual forms, please use the latest forms which are available on our website and ensure that all fields are fully populated before submitting them for processing. Using old forms or submitting new forms with any blank sections will result in the form being rejected for processing.
For more details of changes brought by FIC Amendment Act please read our Legal Update.
Bank details no longer on application forms
Furthermore, to comply with Public Compliance Communications Guidance Note 31 we will no longer reflect our bank account details on our initial investment forms.
Going forward, for EFT payments, once we have approved your client they (the investor) will receive an SMS from us which will reflect the relevant bank details to be used for their investment instruction. Please remind your clients that they will need to make payment into the bank account provided.