ICS previously sent out this Compliance Update regarding the Financial Intelligence Centre (FIC) Directive to Provide Information, 2021 (DPI). Presumably, due to the limited information made available to the industry, the FSCA has issued a “frequently asked questions” document which confirms, amongst other things, -

• All accountable institution in terms of the FIC Act must complete and submit the DPI via the FAIS online portal between 1 and 31 March 2021. Financial services providers (FSPs) are accountable institutions in terms of the FIC Act;
• Key Individuals must register on the FAIS online system to obtain login credentials, and complete the DPI on behalf of the FSP for which they are appointed;
• The DPI consists of questions regarding a risk-based approach, risk management and compliance program, customer due diligence, training, record keeping, reporting, registration, screening and is formulated to allow ‘yes’, ‘no’ and ‘not applicable’ answers. No attachments/uploads are required.
• Failure to complete and submit the DPI may be met with enforcement action by the FIC.

To read the Frequently Asked Questions document, click here.

To prepare for the completion and submission of the DPI, you should -

• Register a Key Individual on the FAIS online system following these steps.
• Familiarise yourself with the FSPs RMCP and anti-money laundering processes;
• Set aside time to complete the DPI before the deadline. You should save your work regularly, download a copy of the DPI once complete and save it for your records;
• Provide confirmation to ICS once the DPI is completed and submitted.

ICS will endeavour to assist clients as far as possible, however, take note that we may not log on to the FSCA online system using another person’s credentials or complete the DPI on your behalf.

Feel free to contact your ICS compliance officer for more information.