buyer had suddenly been changed at the very last moment, just before the transition was due to be closed. She noted that the instruction had been complied with as she did not wish to lose the sale. The transaction had thereafter been duly concealed and implemented. 3.2.8. Discuss why you think the above transactions could be suspicious. The first case : The buyer did not disclose that there is a third party involve in the sale and the third party could not be identified The second case : The details of the purchaser was changed at the last minute of the sale which makes it suspicious. Details of a purchaser should remain the same throughout a sale 3.2.9. Indicate who is responsible for reporting the suspicious transactions and the process that you will follow in dealing with these two reports. When an employee reports a suspicious transaction to the person which was appointed by the company for this reporting (MLRO), his legal obligation has then been discharged as he did report it to the relevant appointed person. It does not matter if this report was given attention or not. An employee must know whom to report, and the company must ensure that employees report suspicions promptly. Employees must also be aware that should they not report suspicions, they will face disciplinary procedures. A report to FIC regarding suspicious transactions will be made and compiled by the companies appointed compliance officer. 30 Juanre Heinlein 8806200093088
The reports must be sent to FIC in terms of Section 28A of FICA, within 5 days after it was discovered that property managed by the accountable institution is related to with terrorist activities. If otherwise agreed by FIC they can stipulate a certain date for the report to reach their office The submitted report must contain the following information: o All detailed information o Reason why there is a suspicion, the grounds for knowledge o Suspicious transaction including the account holder involved o Date transaction was made o Amount of suspicious transaction o Account activity for the past 180 days which was considered for reporting (history report), whether it was or was not o Client, person acting on behalf of the client, person on whose behalf the client is acting, broke, intermediary, trustee or any other person involved in the transaction Report can be submitted in the following way: o Electronically on the FIC website – o Fax to FIC – 021 315 5828 o Deliver the report personally to the FIC No reports can be posted to FIC. All reports are confidential, no copy of the report is needed. If a copy is kept it needs to be in a safe place as it is confidential. 3.2.10. Furnish your own report on the two matters to the Principals of your firm, indicating the action to be taken and the possible remedies for the situations. Print and place this evidence in your PoE, clearly labelled as “Unit 2, 3.2.10.”.
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- Fall '18