Model Compliance Programme for Accountants.doc

Refer to the hr policy if applicable if further

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Refer to the HR Policy (if applicable if further details exist). 8.4 State management’s procedure to facilitate all relevant records being retained for the six (6) year retention period. Consideration must be given to the storage of all relevant documents (hardcopy and/or softcopy) relating to location, back up procedures etc. 8.5 All domestic and international transactions and identification data obtained through the customer due diligence process are maintained in electronic or in written form, for a period of six years to enable me/Entity XXX to comply with lawful requests for information from auditors, other competent authorities and law enforcement authorities that request these records, for purposes of criminal investigations or the prosecution of persons charged with criminal offences . I/The Compliance Officer will/ confidentially and securely maintain records of any SAR/ STR filed with the FIU, Terrorist Funds Reports and Internal Suspicious Activity Reports. I/The Compliance Officer also has access to all customer due diligence documentation. Include details of who has access to and control of storage of identification data, transactional records, SARs/ STRs. 9 Training 9.1 Each member of staff is to receive a copy of the Compliance Program and he/she must familiarise himself/herself with the provisions thereof. 9.2 The Compliance Officer must from time to time circulate to all staff members various articles, notices and memos relating to the duty of vigilance which may contain further requirements for the implementation of provisions AML/ CFT legislation and guidelines to ensure staff is aware of any changes/ amendments. 9.3 On a regular basis, at least annually, I /all staff members, including any Directors will be provided with AML/ CTF training. Such training will usually be provided by the Compliance Officer, unless is determined Page | 23
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otherwise and will include training in customer due diligence procedures as well as in detecting and reporting suspicious transactions. 9.4 Records must be maintained as evidence of any training sessions conducted/ attended and must include registers showing date, facilitator(s), topics covered, employees’ names and signatures. SEE GUIDANCE ON WHAT MIGHT BE INCLUDED IN THE EXAMPLE OF THE SPECIMEN FORM ATTACHED AS APPENDIX IV. 9.5 The training will cover all the relevant legislation and guidelines including but not limited to the following: The Proceeds of Crime Act 2000/ Amended 2009 The Financial Obligations Regulations 2010 The Financial Intelligence Unit 2009/ Amended 2011 The Financial Intelligence Unit Regulations The Anti Terrorism Act 2005/ Amended 2010/ Amended 2011 The Financial Obligations (Financing of Terrorism) Regulations 2011 The training will also include identifying suspicious transactions. 10 Review of Compliance Program 10.1 This Compliance Program will be reviewed annually by me/the Compliance Officer to ensure it incorporates current recommended best-practices, as well as any changes to AML/ CFT legislation and guidelines issued by the FIU and will be submitted to the FIU for re- approval every 2 years.
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