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FSCA COVID-19: What if I can't update my existing Clients information?

The Financial Intelligence Centre (FIC), South African Reserve Bank (SARB) and Financial Sector Conduct Authority (FSCA) have today issued a new combined notice to provide guidance to Accountable Institutions (AI's) that are (or have been) unable to obtain information required to undertake the ongoing due diligence requirements of existing clients due to the level 4 and 5 COVID restrictions in place. For example, where information may only be obtained face-to-face or a legal person has not been in a position to operate their business.

The Authorities do not expect that there should be any freezing or closure of existing client accounts due solely to the inability of AIs to obtain such information due to the COVID restrictions.

However, where an AI has been unable to undertake ongoing due diligence of any existing clients, the Authorities do expect AIs to document their detailed plans with requisite deadlines around how such affected clients will be updated during and after Level 3 of the lockdown period. This plan must include completion dates that do not extend further than eight (8) months from day one of the Level 3 lockdown period.

These plans must then be submitted in writing to their respective supervisory body by no later than seven (7) days post the Level 3 lockdown period.

The full communication may be found here.

Joint Communication 2A of 2020
Download PDF • 194KB

Requests for further information may be submitted via email to: for the Prudential Authority, for the Financial Surveillance Department, for the National Payment System Department, and, for the Financial Sector Conduct Authority.

Note: AIs are urged to continue to act in good faith towards fulfilling their obligations to the greatest extent possible, and to make prudent decisions regarding the management of money laundering, terrorist financing, and proliferation financing risks. The provisions discussed in this communication should not be seen as any relaxation of the Authorities’ supervisory body powers, regulations or requirements.