In March 2022, the Financial Intelligence Centre published a report on the inherent risks of money laundering and terrorist financing the trust and company service provider sector faces. The report aims to improve sector role players’ understanding of the money laundering and terrorist financing risks.
Accountants are among the new types of trust and company service providers to be included under schedule 1 as accountable institutions, which is in line with the FATF requirements. and developing and documenting a risk management and compliance programme . The FIC’s public compliance communication 53, which is available on the FIC website, explains how to develop a risk-based approach and document a RMCP.
The FIC Act defines a beneficial owner in respect of a legal person, as a natural person who, independently or together with another person, directly or indirectly, owns a legal person or exercises effective control of the legal person. Trust and company service providers must scrutinise client information to identify designated people on targeted financial sanctions and domestic prominent influential people and foreign prominent influential people.
The trust and company service provider must keep records of client information, transactional information and regulatory reports filed with the FIC, appoint a compliance officer and provide adequate training to the employees based on the FIC Act and the RMCP.
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