Subject Title - INSETA

In an FSB FAIS Newsletter, the FSB suggested the following measures topromote compliance with the FICA requirements. 161Formulation and implementation of internal rulesSection 42 of the FICA requires accountable institutions to formulate andimplement internal rules concerning:client identification and verification record-keepingsteps taken to determine and report such other matters as may besuspicious transactionsprescribed from time to timeInternal rules must be made available to every employee involved intransactions to which FICA apply, and on request, a copy thereof must bemade available to the FIC and relevant supervisory bodies.Training of employeesThe FICA requires accountable institutions to provide training to itsemployees to enable them to comply with the provisions of FICA and internalrules applicable to them. 162Note that FICA does not prescribe the format of training required. Bothformal training and FICA awareness campaigns are recognised. Thesemethods are both designed to raise the level of awareness of employeesregarding their obligations.As in the FAIS Act, record of training attended must be kept as proof.Appointment of a compliance officerSection 43(2) of the FICA requires accountable institutions to appoint aperson with a responsibility to ensure compliance by:the accountable institution with its employees of the accountableobligations under FICA.institution with the provisions of FICAas well as internal rules applicable tothem161 Volume 6, June 2008162 Section 43(1)254 © INSETA - Section 1 12a