FSCA ONSITE INSPECTIONS ARE HERE - FICA
The FSCA paused their compliance reports last year due to them not being done with the new format compliance reports. Although we do not have written confirmation or any notice to this effect - we've heard from some of their staff that it also affects AUM reports and Handover reports (still to be confirmed). And it does not seem that we have any news on new compliance reports for this year. However, there is some other news.
They are busy though, with onsite inspections. Some of our clients were recently inspected and only on FICA. From discussions with people in the industry they are doing inspections on a broad number of FSP's so you should be ready in case they come to visit you.
You should focus on your FICA compliance ASAP. If you do not have the basics in place your are at risk of being fined. Yes, several FSP's have recently been fined for not complying with even the smallest aspects of FICA after the inspections were conducted (none of our clients though).
“Be ready for a FICA inspection - a few FSP's have been fined already”
What do you need to have in place?
Your RMCP(Risk Management and Compliance Programme) needs to be in place
The RMCP must be adopted by senior management or directors
Ensure you are registered as AML Compliance Officer with the FIC and that your FSP is registered
You must have a list of active clients with details
Training must be done on FICA compliance with a test for all staff on a refresher basis (contact us-we have an online solution)
Your client files need to be complete
It is very important that you must show that you risk rated all your ongoing clients according to your RMCP
Very important that you know what your RMCP states and how to use it as they will ask you these questions.
RMCP's need to be tailored to your business - your logo and name must be reflected and it must reflect the processes you actually use
How will the inspection happen?
They will usually contact the Key Individual and inform them of the impending inspection. They will ask for certain documentation beforehand to peruse it before they visit you. They then provide you with a date on which they will arrive and state what you need to have ready on the day. You will likely not have a fun time during the inspection, but with our help we can make it a little less daunting.
This is a quick summary of what to look out for. If you need assistance please let us know - we are here to help.
