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RE1 Blueprint Series · Task 10 of 16

Manage and Oversee FIC Act, Money Laundering and Terrorist Financing Requirements

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.

The 4 QCs, in full:
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.

Exam trap: An FSP with a spotless suspicious-transaction filing history isn't automatically FICA-compliant on that basis alone. The exam tests whether you check for the RMCP, staff training, and record-keeping sitting behind those filings — not just the filings themselves.

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.

Real scenario: Staff haven't been trained on what actually counts as a suspicious transaction, and one goes unreported for weeks. The 15-day STR deadline only matters if staff can recognise suspicious activity in the first place and know to escalate internally — untrained staff can't fulfil an obligation they don't understand exists.

Quick Recap

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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