Model Compliance Programme for Accountants.doc

Of the compliance officer and the relevant details of

Info icon This preview shows pages 19–21. Sign up to view the full content.

View Full Document Right Arrow Icon
of the Compliance Officer and the relevant details of the suspicion will be documented and forwarded to the Compliance Officer by the use of an Internal Suspicious Activity Report, an example of which is included in Appendix II. It is the Compliance Officer’s responsibility/ my responsibility to determine whether same constitutes a suspicious transaction or suspicious activity as defined under the POCA and if so, then a report must promptly be made by the Compliance Officer to the FIU. Staff members must notify the Compliance Officer as soon as possible but in any event within one (1) business day of suspicious behaviour or information received during the normal course of business. 6.3 An STR/SAR must be filed within the time frame specified in Section 55 (3) of the POCA i.e. as soon as possible but within 14 days of the date on which I /the Compliance Officer knew or had reasonable grounds to suspect that the funds used in the transaction were the proceeds of a specified offence. The SAR/ STR must also be completed where there are reasonable grounds to suspect that the funds are being used for terrorism in accordance with Section 22C of the ATA Amended. 6.4 Tipping Off I am / Staff must be mindful that it is illegal to tell a customer of the intention to file a STR/SAR or that a STR/ SAR was filed or that an investigation is being conducted. This constitutes the offence of “Tipping Off” under section 51 of POCA. 6.5 A register of enquiries made to the client by law enforcement authorities or other local or foreign authorities must be maintained separate from other records and contain as a minimum the following: The date and nature of the enquiry The name and agency of the enquiring officer The powers being exercised 6.6 Any written request received from the FIU must be responded to within seven (7) days of the receipt of the request for the information. Note however, that the Director of the FIU can request a response within a shorter timeframe. Page | 19
Image of page 19

Info iconThis preview has intentionally blurred sections. Sign up to view the full version.

View Full Document Right Arrow Icon
6.7 Where an oral request was made by the FIU, a response should be provided to the FIU as soon as is reasonably practicable but within twenty-four (24) hours. 6.8 Terrorist funds reporting (a) I am /Entity XXX is required to report to the FIU if there are reasonable grounds to suspect that funds received may be used for the financing of terrorism. Special attention must be paid to complex, unusual or large transactions. Immediate reporting to the FIU must be completed if the funds were received from an individual or legal entity who: commits terrorist acts or participates in or facilitates the commission of terrorist acts or the financing of terrorism or is a person or entity designated by the United Nations Security Council (b) For all new customers, I Entity XXX will consult the UN 1267 List and the Consolidated List to verify whether the customer is included on the Lists (c) Periodic reviews of the above Lists against the customer portfolio will also be conducted (d) After consulting the Lists, if I/the Entity XXX know (s) or has
Image of page 20
Image of page 21
This is the end of the preview. Sign up to access the rest of the document.

{[ snackBarMessage ]}

What students are saying

  • Left Quote Icon

    As a current student on this bumpy collegiate pathway, I stumbled upon Course Hero, where I can find study resources for nearly all my courses, get online help from tutors 24/7, and even share my old projects, papers, and lecture notes with other students.

    Student Picture

    Kiran Temple University Fox School of Business ‘17, Course Hero Intern

  • Left Quote Icon

    I cannot even describe how much Course Hero helped me this summer. It’s truly become something I can always rely on and help me. In the end, I was not only able to survive summer classes, but I was able to thrive thanks to Course Hero.

    Student Picture

    Dana University of Pennsylvania ‘17, Course Hero Intern

  • Left Quote Icon

    The ability to access any university’s resources through Course Hero proved invaluable in my case. I was behind on Tulane coursework and actually used UCLA’s materials to help me move forward and get everything together on time.

    Student Picture

    Jill Tulane University ‘16, Course Hero Intern