2026 RCR

I, Click or tap here to enter text. Of the abovementioned institution do hereby certify that this declaration was read and understood, that the information provided in this risk and compliance return is accurate and complete, and that I am duly authorised to execute this declaration on behalf of the abovementioned institution.

Confirm the authorised signatory and retain approval evidence before electronic submission.

Institution details and declaration; All specified Schedule 1 items; evidence: Authority to submit, approval record, signatory details and final answer pack

What percentage of your clients are natural persons?

Calculate the percentage from documented client or transaction records for each period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

What percentage of your natural person clients are foreign nationals?

Calculate the percentage from documented client or transaction records for each period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

What percentage of your clients are foreign legal persons?

Calculate the percentage from documented client or transaction records for each period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

What percentage of your clients are trusts?

Calculate the percentage from documented client or transaction records for each period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: CDD files, beneficial ownership records and trust records

Does your institution conduct business with any domestic politically exposed persons (PEPs) or their close family members or close associates?

Reconcile client risk records, PEP screening results and enhanced due diligence decisions.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: PEP screening, risk-rating and enhanced due diligence records

What percentage of your clients have been identified as high- risk domestic PEPs?

Reconcile client risk records, PEP screening results and enhanced due diligence decisions.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: PEP screening, risk-rating and enhanced due diligence records

What percentage of your clients have been identified as high- risk Domestic Prominent Influential Persons?

Calculate the percentage from documented client or transaction records for each period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution conduct business with any foreign PEPs?

Reconcile client risk records, PEP screening results and enhanced due diligence decisions.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: PEP screening, risk-rating and enhanced due diligence records

What percentage of your clients have been identified as foreign PEPs?

Reconcile client risk records, PEP screening results and enhanced due diligence decisions.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: PEP screening, risk-rating and enhanced due diligence records

Does the institution onboard clients on a non- face-to-face basis (i.e. social media platforms, electronic platforms or agents?)

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution accept cash in the conclusion of any transactions (not applicable to electronic funds transfers)?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Cash transaction records and FIC reporting records

Do you allow third parties to transact on behalf of your clients?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Has your institution refunded or reversed client monies paid into your accounts where a client had not provided KYC documents?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution conduct cross - border transactions?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution screen employees against the TF list?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Do you “risk rate” your products and services for ML/TF/PF when introducing new products and services?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Is your institution situated within 100km of an international border?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution conduct business with clients from countries regarded as high- risk for ML/TF/PF purposes?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution conduct business with clients from countries regarded as tax havens or high- secrecy jurisdictions?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution conduct business with clients from countries on the Financial Action Task Force blacklist?1

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution screen potential clients against the TFS list before onboarding?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Does your institution screen its clients against the TFS list when the list is updated?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Are you aware of the appropriate compliance obligations that arise when conducting business with individuals and institutions on such lists? 1 Democratic Republic of North Korea, Islamic Republic of Iran, and Republic of Myanmar

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution have a risk management and compliance programme (RMCP) implemented?

Use the current approved RMCP and implementation evidence; do not answer from policy wording alone.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Approved RMCP, implementation evidence and review records

Does your institution have branches and/or subsidiaries?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution have a compliance function?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution provide ongoing training to its employees to enable them to comply with the FIC Act and the RMCP? Identification of clients and other persons.

Use the current approved RMCP and implementation evidence; do not answer from policy wording alone.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Approved RMCP, implementation evidence and review records

Does your institution have processes and procedures in place for the identification and verification of clients? Politically exposed persons, family members and known close associates

Reconcile client risk records, PEP screening results and enhanced due diligence decisions.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution have processes and procedures in place to establish whether a prospective client or beneficial owner of the prospective client in a business relationship is a:

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: CDD files, beneficial ownership records and trust records

Foreign politically exposed person?

Reconcile client risk records, PEP screening results and enhanced due diligence decisions.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Family member or known close associate of the foreign politically exposed person?

Reconcile client risk records, PEP screening results and enhanced due diligence decisions.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Domestic politically exposed person

Reconcile client risk records, PEP screening results and enhanced due diligence decisions.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Family member or known close associate of the domestic politically exposed person Understanding and obtaining information on business relationships

Reconcile client risk records, PEP screening results and enhanced due diligence decisions.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution establish the:

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Nature of the business relationship?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Intended purpose of the business relationship?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Source of funds? Additional due diligence measures relating to legal persons, trusts, and partnerships

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: CDD files, beneficial ownership records and trust records

When the client is a legal or natural person who is acting on behalf of a partnership, trust, or similar arrangements between natural persons, does the institution establish the:

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: CDD files, beneficial ownership records and trust records

Ownership and control structure of the client?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution establish the identity of the ultimate beneficial owner/s of the client?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: CDD files, beneficial ownership records and trust records

Does your institution establish the identity of the natural person who exercises effective control of the legal person client?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution establish the identity of each founder and trustee and beneficiary of the trust (where the client is a trust)?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: CDD files, beneficial ownership records and trust records

Does your institution establish the identity of the f ounder / trustee / beneficiary of the trust if the founder / trustee / beneficiary is a legal person? (where the client is a trust) Ongoing due diligence

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: CDD files, beneficial ownership records and trust records

Does your institution monitor transactions undertaken throughout the course of the business relationship, including:

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Ascertaining the source of funds

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Background and purpose of complex, unusual large transactions

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Unusual patterns of transactions which have no apparent business or lawful purpose

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution keep the customer identification and verification documents up to date?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution take additional steps when it has doubts about the veracity or adequacy of previously obtained information? Inability to conduct customer due diligence

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution file regulatory reports with the FIC under section 29 of the FIC Act if unable to conduct customer due diligence?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution keep records on clients?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution keep records of client information?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution keep records of transactions?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution keep client records for five years after the termination of a business relationship?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution use a third party to keep client records?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

If yes to the previous question, does your institution have sufficient information about the third party and does the institution:

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Have free and unencumbered access to the relevant records?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Are the records kept by the third party readily accessible to the FIC and/or the relevant supervisory body when required?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Are the records capable of being reproduced in a legible format?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Have the full name and contact particulars of the individual who exercises control over access to those records?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Have the address where the records are kept? Regulatory Reporting

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Did your institution file section 28 reports (cash threshold reports) for the reporting period?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Cash transaction records and FIC reporting records

Has your institution filed reports under section 28A i.e., terrorist property reports, during the reporting year?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Cash transaction records and FIC reporting records

Does your institution have a process in place for the identification and reporting of suspicious and unusual transactions S29 reporting?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Is your institution’s staff aware that they may not disclose information about the contents of section 29 reports?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Was your institution served with any subpoenas in terms of section 205 Criminal Procedures Act, 1977 (Act 51 of 1977), received any enquiries or requests for information from the FIC, investigative authorities or other regulatory bodies in respect of any transaction concluded with a client?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Have any clients of your institution enquired as to whether your institution had reported them to the FIC?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution have processes and procedures in place to deal with a section 32 request from the FIC?

Prepare a source-backed answer from the institution's records for each required period.

Part 1 - General risk questions; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you have any dealings/interactions with clients that provide products and services to the three countries that are on the FATF Blacklist (Democratic Republic of North Korea, Islamic Republic of Iran, and Republic of Myanmar), considered high risk for PF purposes.

Prepare a source-backed answer from the institution's records for each required period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you have any dealings/interactions with the three countries listed on the FATF Blacklist [See 2.1 above]?

Prepare a source-backed answer from the institution's records for each required period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you produce or deal in products that may be used in the proliferation of weapons of mass destruction?

Prepare a source-backed answer from the institution's records for each required period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you assess PF risks related to dual- use goods2?

Prepare a source-backed answer from the institution's records for each required period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you screen for PF red flags from FATF Guidance 2024?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Do you have PF risk factors unique to identify possible instances of PF when dealing with clients?

Prepare a source-backed answer from the institution's records for each required period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you have clients that are nationals of countries that are FATF black-listed? Which percentage?

Calculate the percentage from documented client or transaction records for each period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you have clients that process funds to or from countries that are on the FATF blacklist? 2 For guidance on dual-use goods or “controlled goods and activities” - Refer to Public compliance communication 44A https://www.fic.gov.za/wp-content/uploads/2024/02/2027.2-PCC-PCC-44A- Targeted-financial-sanctions.pdf

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Do you follow a process to screen all existing client information against updates to the TFS list without delay?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Do you have clients that deal with controlled good or dual use goods? Refer to PCC 44A on targeted financial sanctions.

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Do you follow a process to freeze without delay funds that are linked to a designated person?

Prepare a source-backed answer from the institution's records for each required period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you follow a process to report without delay funds or business relations that are linked to a designated person?

Prepare a source-backed answer from the institution's records for each required period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you identify beneficial owners of clients that are foreign legal companies or arrangements?

Prepare a source-backed answer from the institution's records for each required period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: CDD files, beneficial ownership records and trust records

Do you provide training to staff on aspects of proliferation financing?

Prepare a source-backed answer from the institution's records for each required period.

Part 2 - Proliferation financing; All specified Schedule 1 items; evidence: Training attendance registers, materials and completion records

Does your institution operate in any areas that are considered a high risk from a TF perspective? Consider media reports and crime statistics.

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you have customers that are citizens from countries that are subject to UNSC sanctions measures?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Do you conclude transactions to or from the geographic locations that pose a heightened risk of terrorist financing?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you transact with CASPs or accept crypto assets as payment from countries that are pose a high risk for terrorist financing?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you have clients that are complex legal structures, legal persons or trusts that are from countries that are highlighted in the SA 2024 TF NRA 3?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: CDD files, beneficial ownership records and trust records

Do you accept payments of prepaid cards, Money Value Transfer Services (mobile money) or Alternative remittance services?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you accept third parties to collect cash on behalf of money remitters?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Cash transaction records and FIC reporting records

Do you send funds to countries in Africa that are known for terrorist activity?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you conduct transactions with clients that facilitate transfers to high- risk countries from a terrorist financing perspective?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you conduct transactions with hawala and remittance networks?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you facilitate travel to and from conflict areas?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you conduct transactions in crypto assets or trade in commodities (oil, diamonds, or gold?)

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you establish business relationships with clients using passports, asylum seeker/ refugee permits as proof of identity?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you conduct transactions of Krugerrand gold / silver coins and / or foreign currency? 3 Refer to the South African National Terrorism Financing Risk Assessment dated 24 June 2024 https://www.fic.gov.za/wp-content/uploads/2024/06/National-risk-assessment-%E2%80%93-Terrorist- financing-national-risk-assessment-2024.pdf

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution conduct business with dealers of precious metals or stones (DPMS) that are in proximity (less than 1 00 kms) to conflict areas?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you conduct transactions with non- profit organisations and/or non- governmental institutions?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you conduct business with unregistered or voluntary NPOs?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you conduct business with charities and organisations involved in health, faith based, humanitarian and educational work operating in terror/ conflict areas?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

If answered yes above, do you ensure that the use of the funds and / or properties involved are used in accordance with the stated objectives of these organisations?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Have you submitted an STR/SAR relating to TF/PF in the last year?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution conduct business with clients in the arms/ national defence industry?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution conclude transactions with customers from countries that are involved in armed conflict or terrorist activity?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Does your institution conduct business with customers that have a significant social media presence, and allege to be raising funds for charitable organisations in conflict areas?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you monitor TF crowdfunding typologies?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you track clients linked to the Islamic State of Iraq and the Levent (EI/ISIL) returnees? 3.26 Where you suspect that a potential client is a sanctioned person or entity or is linked to a sanctioned person or entity?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

1 Do you have processes to further investigate the validity of this suspicion (e.g. do you scrutinise their information against the TFS list, do you conduct an adverse media search)?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Do you have a process in place to report without delay to the FIC where a designated person or entity tries to transact with you?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you follow a process to scrutinize client information against the TFS lists without delay from date of updates to the TFS list?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Within which period do you screen you client data against the TFS list?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Do you monitor developments on domestic terrorist activity?

Prepare a source-backed answer from the institution's records for each required period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Working papers and source records supporting the answer

Do you screen your client information without delay against the section 23 POCDATARA court orders as published by the from time to time?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 3 - Terrorist financing; All specified Schedule 1 items; evidence: Sanctions/TFS screening logs and escalation records

Which category of legal practitioners do you belong to?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Do you provide any of the following services in your legal practice? a) Conveyancing: Assisting with the transfer of property, including drafting of documents, managing property transactions with overstated or understated values, or facilitating the transfer of properties to third parties.

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

b) Business in a Customer Account: Assisting with financial transactions where funds are placed in your client account, including situations where purchases or investments may not take place or where funds are transferred to a third-party account.

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

c) Formation and Management of Legal Entities: Creating and managing legal entities such as complex legal structures, or shell companies that could obscure the true ownership of assets. Cash Payments and Trust Accounts

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Cash transaction records and FIC reporting records

Do you accept cash payments for services or payments into trust accounts?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Cash transaction records and FIC reporting records

If yes, do you have procedures in place to assess and mitigate the risks associated with cash payments, particularly those that might indicate money laundering activity? Anonymity and Complex Transactions

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Cash transaction records and FIC reporting records

Have you provided legal advice or services for clients that are complex in nature and where the client’s identity (including Beneficial Ownership) is not clear?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: CDD files, beneficial ownership records and trust records

If yes, do you verify the legitimacy of these clients to prevent the potential misuse of your services for money laundering or terrorist financing?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Have you provided legal advice or services for transactions that are complex in nature and the transaction’s purpose is not clear?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you verify the legitimacy of these clients and transactions to prevent the potential misuse of your services for money laundering or terrorist financing? New Payment Technologies

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Do you accept payments through new technologies, such as crypto assets, for your legal services?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you have measures to mitigate the risks associated with these payment methods, particularly in relation to money laundering or terrorist financing? International Payments

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Do you receive payments from clients located in foreign countries?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you have measures to ensure that these payments are legitimate, especially when there is no apparent connection between the country and the client? Extraordinary Fees

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Have you encountered situations where clients offer or pay extraordinary fees for services that would not typically warrant such high fees?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you assess and address the risks associated with these unusual payment arrangements? Fictitious or questionable debts

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Have you ever encountered instances where clients have requested your services to recover fictitious or questionable debts?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you have measures in place to identify fictitious debt? Transactional reversal

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Have you encountered an instance where your client requests reverse transactions with repayment of funds, or transactions that do not make economic sense?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you evaluate whether a transaction makes economic and business sense?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Do you accept Third -Party Payments?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you have controls in place to verify the source and legitimacy of these payments? Handling of Funds and Real Estate Transfers

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If you physically handle the receipt and transmission of funds through accounts you control, have you been requested to transfer real estate between parties in an unusually short period?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you have controls in place to ensure that these transactions do not contribute to concealing the beneficial ownership of the client or other parties involved? Funds from or to Foreign Countries

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: CDD files, beneficial ownership records and trust records

Have you received or sent funds to a foreign country when there is no apparent connection between the country and the client?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you conduct due diligence measures to verify the legitimacy of these transactions? Multiple Bank Accounts

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Do any of your clients use multiple bank accounts or foreign accounts without an apparent legitimate reason?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

How do you assess and manage the risks associated with such practices? Changes in Transaction Patterns

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Have you observed instances where clients change the way transactions are concluded or alter their instructions on short notice without apparent reason?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you have measures in place to assess whether these changes make economic sense, and how do you manage the associated risks? Complex Legal Structures

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Do you deal with clients who establish complex structures involving companies, trusts, or partnerships?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: CDD files, beneficial ownership records and trust records

If yes, do you take steps to identify and verify the ultimate beneficial owners (UBOs) in such complex structures? Intermediaries and Third -Party Service Providers

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: CDD files, beneficial ownership records and trust records

Do you use third -party service providers or intermediaries to assist with client identification, verification, or onboarding?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you conduct due diligence measures to assess the intermediary’s business, including their risk mitigation processes and procedures? Indicators of Suspicious Client Behaviour

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Have you encountered any of the following client behaviours that may indicate potential money laundering?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

a) Clients attempting to conceal their identities

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

b) Transactions inconsistent with the client's stated income or occupation.

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

c) The use of unusual sources of funds for transactions.

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

d) Transactions lacking a legitimate or economic reason.

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

e) Clients ceasing their business relationship upon a request for customer due diligence (CDD) information. Verifying Source of Funds

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Do you inquire about the source of funds involved in legal matters, such as property transactions or trust establishment? Cross-Border Transactions

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: CDD files, beneficial ownership records and trust records

Do you engage in cross -border legal transactions?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

If yes, do you assess and manage the risks related to these transactions, especially those linked to countries with higher ML/TF/PF risks? ML/TF Awareness

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Do you detect abuse of legal structures using global typology indicators?

Prepare a source-backed answer from the institution's records for each required period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Working papers and source records supporting the answer

Do you perform sanctions screening for cross -border fund flows?

Use screening logs, escalation records and evidence of list-update checks for the period.

Part 9 - Legal practitioners; Item 1 legal practitioners; evidence: Sanctions/TFS screening logs and escalation records