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The FSP must establish its own nominee company or identify an existing approved nominee company High 24 Risk Area: Control Issues Recommended Actions/Processes Risk Rating : High Medium Low Responsible Person/s Monitoring/ Review Frequency The FSP is obliged to implement an appropriate set of internal rules Ensure that FICA internal rules are implemented High Key Individual Ongoing Financial Intelligence Centre Act FICA Internal Rules Sec 42: FICA Key performance dates Provide copies to all staff members Client due diligence Sec 21: FICA Proper due diligence must be applied with regard to all new client take on in accordance with the provisions of FICA and the Regulations Obtain appropriate FICA declarations from new clients High Key Individual Ongoing Obtain proof of employment High Key Individual Ongoing Client verification Sec 25: FICA Regulations The FSP must verify relevant client information as per FICA Establish a process to ensure that the required documentation is obtained from all active clients as per FICA Internal Rules High Key Individual Ongoing PEP Verification Government Notice 27803: Guidance Notes Sec 25 - 27 The FSP must verify if a client is a PEP Establish a process to ensure that clients that are PEPs are identified and necessary documents are verified and proof of source of funds are obtained High Key Individual Ongoing Recordkeeping Sec 22 – 26: FICA Sec 26: FICA Regulations The FSP must ensure that proper recordkeeping is in place according to the provisions of FICA Ensure that records will be kept for a period of 5 years after termination of the product or after the rendering of the financial service High Key Individual / appointed staff member Ongoing RMP – MS (MAR 09) 25 Risk Area: Control Issues Recommended Actions/Processes Financial Intelligence Centre Act Risk Rating : High Medium Low Responsible Person/s Monitoring/ Review Frequency High Key Individual Ongoing Medium Key Individual / Compliance officer Annually Key performance dat
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