FSPs are "accountable institutions" under the Financial Intelligence Centre Act. This task sits alongside your FAIS obligations, not inside them — a KI who is excellent on FAIS compliance but has never engaged with the FSP's FICA obligations has a genuine, separate gap.
QC1 — Explain the requirements specific to a FSP prescribed by the FIC Act
QC2 — Verify that all Compliance Risk Management Programme requirements under the FIC Act are in place
QC3 — Verify processes exist ensuring compliance with identification, verification, record-keeping and reporting obligations
QC4 — Check that employees are trained and aware of their obligation to report suspicious transactions
QC1: What the FIC Act Specifically Requires
As an accountable institution, the FSP needs a documented Risk Management and Compliance Programme (RMCP, Section 42), an appointed person with sufficient seniority to ensure FICA compliance (Section 42A — distinct from the FAIS Compliance Officer, though one person can hold both roles), client identification and verification before establishing a relationship, and staff training.
QC2: The RMCP Is Not a Generic Template
The RMCP must document the FSP's own assessed money laundering, terrorist financing, and proliferation financing risks, along with the specific controls used to manage them. The Financial Intelligence Centre recommends reviewing it at least annually, more often if the FSP's risk profile changes.
QC3: Beyond Just Collecting an ID
Collecting a client's ID is only the identification step — it doesn't by itself satisfy the training, monitoring, and reporting obligations that sit around it. A full process covers identification, verification, record-keeping, and reporting, not just the easiest one to tick off.
QC4: Training Behind the Deadlines
The two most precisely tested numbers in this task sit here: the Suspicious Transaction Report deadline is 15 days (excluding weekends and public holidays), and the Cash Threshold Report deadline is 3 business days for cash transactions over R49,999.99.
Quick Recap
- The RMCP must reflect the FSP's own assessed risks, reviewed at least annually — not a generic template
- Section 42A specifically requires a person of sufficient seniority overseeing AML/CTF obligations
- STR deadline: 15 days, excluding weekends and public holidays. CTR deadline: 3 business days for cash over R49,999.99
- Clean filing history doesn't prove compliance — the RMCP, training, and records behind it are what's actually tested
FICA Sits Beside FAIS, Not Inside It
RE Mastery Hub's Task Quizzes test the exact STR and CTR deadlines side by side — the pairing examiners rely on to catch confusion.
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