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Guidance For Drafting FIA Compliance Program For Accountable And Reporting Institutions

To ensure effective compliance with the Financial Intelligence Act (FIA), Accountable Institutions (AIs) must develop a comprehensive FIA Compliance Program that aligns with the Act's requirements. This involves conducting a thorough risk assessment to identify and manage risks related to clients, products, services, delivery channels, and geographical areas.

The program should include detailed procedures for client identification (KYC), maintaining accurate client records, and conducting ongoing due diligence, particularly for high-risk clients like Politically Exposed Persons (PEPs). Proper record-keeping, reporting of Cash Threshold Reports (CTRs), and suspicious transactions are critical, along with rigorous client screening against sanctions lists. An independent audit function, designated compliance officers, and regular staff training are essential to ensure adherence to the FIA's regulations.

Finally, senior management must approve and oversee the program's effective implementation.


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