Model Compliance Programme for Accountants.doc

Application of compliance program this compliance

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Application of Compliance Program This Compliance Program applies to me/all persons employed with Entity XXX, including all members of support staff, collectively referred to as “staff”. 5.1 Objectives of the Compliance Program The objective of this Compliance Program: A. Ensure compliance with applicable laws and regulations B. Implement the required policies, procedures and internal controls C. Provide training and direction to affected staff, agents and business partners D. Prevent the services offered from being used as a conduit for the laundering of illegal funds or financing of terrorist activities E. Know our customers and employees and continue building sound legal, professional and ethical relationships Therefore, this Compliance Program requires the following: a. Obtaining/ confirming the true identity of customers requesting our services b. Recognising and reporting suspicious transactions to the FIU. In this regard, note that any person who in good faith voluntarily discloses information to the FIU arising out of a suspicion or belief that any money or other property represents the proceeds of criminal conduct, is protected under the POCA, from being sued for breach of any duty of confidentiality c. Retaining records for a period of at least six (6) years d. Training all staff e. Liaising closely with the FIU on matters concerning vigilance, policy and systems f. Ensuring that there is a regular monitoring/ review of the implementation and operation of vigilance systems 5.2 Client Due Diligence Measures Page | 9
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Before the acceptance of a new client , I/staff need to verify the identification information received to determine the legal nature of the entity e.g. individual, limited liability company, an unlimited liability company, a partnership, a sole trader and whether a foreign entity, or a locally registered external company, a trust company, a merchant or commercial bank, etc. I/Staff therefore must apply the following points of guidance according to the legal personality of the client and the capacity in which he/she is seeking the assistance of Entity XXX. 5.3 Individuals (a)A personal introduction from a known and respected client and/or a key member of staff is often a useful aid but it does not remove the need to verify the subject in the manner provided herein. It must in any case contain the full name and permanent address of the client in question, and as much as is relevant of the information contained in paragraph hereinbelow. (b)Save in the case of reliable introductions, a senior member of staff should, whenever feasible, meet with and interview the client in person. (c) The following measures will be used to identify an individual client as outlined in Regulation 15 (1) of the FOR: Full name of the client Permanent address and proof thereof Date and place of birth Nationality Nature / place of business/ occupation (where applicable) Occupational income (where applicable) Signature Purpose of the proposed business relationship or transaction/ source of funds
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