Comply with FICA and Money Laundering Regulations

FICA — the Financial Intelligence Centre Act — sits outside the FAIS Act entirely, but every representative operates under both simultaneously. This task tends to have the highest concentration of exact-number questions on the whole exam: specific deadlines, specific thresholds, specific consequences. Vague understanding doesn't get you through this one — you need the actual figures.

Suspicious Transaction Reports (STRs)

When a representative or FSP has reasonable grounds to suspect a transaction is linked to money laundering or the proceeds of unlawful activity, a Suspicious Transaction Report must be filed with the Financial Intelligence Centre. The deadline for this is a detail candidates consistently get wrong: 15 days, excluding weekends and public holidays, from when the suspicion arose.

That "excluding weekends and public holidays" qualifier matters — it's not 15 calendar days, and the exam will test the distinction directly with scenarios that span a long weekend or a holiday period.

Cash Threshold Reports (CTRs)

A Cash Threshold Report is triggered differently from an STR — it's based purely on the size of a cash transaction, regardless of whether anything looks suspicious about it. The threshold was raised on 14 November 2022, and cash transactions exceeding R49,999.99 now trigger a mandatory CTR. Once triggered, the report must be filed within 3 business days.

Real scenario: A client deposits exactly R50,000 in cash for a policy premium. Does this trigger a CTR? Yes — the threshold is exceeding R49,999.99, and R50,000 clears that mark. The exact cutoff matters here, since a transaction of precisely R49,999.99 itself would not trigger the report — it has to exceed that figure.

"Tipping Off" — A Criminal Offence

Once an STR has been filed, disclosing to anyone — including the client themselves — that a report was made, or revealing its contents, is a criminal offence under FICA. This is commonly referred to as "tipping off," and it exists specifically to prevent someone under suspicion from being warned and given a chance to destroy evidence or move funds before an investigation can proceed.

Real scenario: A representative who filed an STR about a client later mentions to that same client, in a moment of discomfort, "just so you know, I had to report that large deposit." Even said with good intentions or simple honesty, has a criminal offence occurred? Yes — disclosing that a report was filed, to anyone including the client it concerns, is tipping off, regardless of the representative's motive for saying it.

Customer Due Diligence (CDD)

Before establishing a business relationship or concluding a single transaction above certain thresholds, FICA requires FSPs to verify a client's identity and, where relevant, understand the nature of their business and the source of their funds. This isn't a once-off box-ticking exercise at onboarding — ongoing due diligence is required throughout the relationship, especially where a client's risk profile changes or their transaction patterns shift unexpectedly.

Real scenario: A client who has held a low-value savings product for years suddenly starts making large, irregular cash deposits inconsistent with their known income. Does the FSP's original due diligence from account opening remain sufficient? No — a material change in transaction behaviour is exactly the kind of trigger that requires renewed due diligence and, potentially, an STR if the pattern genuinely looks suspicious rather than merely unusual.

Quick Recap

• STR deadline: 15 days, excluding weekends and public holidays, from when suspicion arose
• CTR threshold: cash transactions exceeding R49,999.99 (raised 14 November 2022)
• CTR deadline: 3 business days once triggered
• Tipping off: disclosing an STR or its contents to anyone, including the client, is a criminal offence — regardless of motive
• CDD: ongoing, not once-off — a material change in client behaviour can require renewed scrutiny