How to Comply

This manual provides detailed guidance on the steps that bullion dealers in South Africa need to take to comply with the Financial Intelligence Center Act (FICA) No. 38 of 2001. The manual covers the following topics:

• Risk assessment: How to conduct a risk assessment to identify and assess the money laundering and terrorist financing risks associated with your business.
• Customer due diligence: How to identify and verify the identity of your customers in accordance with the FICA Regulations.
• Monitoring and reporting: How to monitor your transactions for signs of money laundering or terrorist financing, and how to report suspicious transactions to the Financial Intelligence Center (FIC).
• Training: How to train your staff on anti-money laundering and terrorist financing compliance.

Risk Assessment

The first step in complying with FICA is to conduct a risk assessment. This assessment should identify and assess the money laundering and terrorist financing risks associated with your business. The following factors should be considered when conducting your risk assessment:

• The types of bullion transactions that you undertake.
• The customer base.
• The geographic location of your business.
• The industry sector.
• The size of your business.

Customer Due Diligence

Once you have conducted a risk assessment, you need to implement customer due diligence (CDD) procedures. CDD is the process of identifying and verifying the identity of your customers. The following information should be collected from your customers as part of the CDD process:

• Name.
• Address.
• Date of birth.
• Identity document number.
• Occupation.
• Source of funds.

Monitoring and Reporting

You are required to monitor your transactions for signs of money laundering or terrorist financing. If you suspect that a transaction is suspicious, you must report it to the FIC. The following are some of the red flags that may indicate a suspicious transaction:

• The transaction is unusually large or complex.
• The customer is acting in a way that is inconsistent with their known business or personal activities.
• The customer is using false or misleading information.
• The transaction is being conducted in a way that is designed to conceal the identity of the parties involved.

Training

You are required to train your staff on anti-money laundering and terrorist financing compliance. This training should cover the FICA Act, the FICA Regulations, and the FIC’s guidance notes.

Conclusion

This manual has provided you with a detailed overview of the steps that you need to take to comply with South African regulation for bullion dealers. By following the guidelines in this manual, you can help to ensure that your business is compliant with FICA and that you are not unwittingly facilitating money laundering or terrorist financing.

Additional Resources

• Financial Intelligence Center (FIC): The FIC is the government agency responsible for combating money laundering and terrorist financing in South Africa. The FIC website provides a wealth of information on anti-money laundering and terrorist financing compliance, including guidance notes, FAQs, and training materials.
• South African Reserve Bank (SARB): The SARB is the central bank of South Africa. The SARB website provides information on the Exchange Control Regulations, which are relevant to bullion dealers.
• Association of South African Bullion Dealers (ASABD): The ASABD is a trade association representing bullion dealers in South Africa. The ASABD website provides information on anti-money laundering and terrorist financing compliance for bullion dealers.