By now you’ll be familiar with the risk-based approach Sanlam Collective Investments (SCI) applies to Customer Due Diligence.
This approach is guided by the new amendments to the Financial Intelligence Centre Act (FICA). Adhering to FICA legislation is one of the many ways Sanlam plays its part in protecting the integrity of South Africa’s financial system. It aligns to international standards to curb money laundering and counter terror-financing measures.
Key features of the risk-based approach to Customer Due Diligence
SCI will not conclude any transaction or enter into any business relationship with a client before identifying and verifying the individual client, third-party payers and parties acting on behalf of the client.
Controlling persons and authorised signatories of non-individual clients will also require verification. All investors will be screened against the sanctions lists and risk-rated in line with the SCI risk-rating methodology.
When will we conduct an Enhanced Due Diligence?
If a client is risk-rated as high, SCI will perform an Enhanced Due Diligence (EDD) on new or existing investors, where we might ask for additional information over and above the standard Customer Due Diligence documentation.
We’ll conduct EDD depending on the information provided on the instruction form, what we already know about the client and additional information identified from other sources, for example, the screening results.
We’ll also conduct EDD if a client falls under the definition of any of the following:
- Domestic prominent influential person (DPIP)
- Foreign prominent public official (FPPO). This includes all individuals who hold prominent public positions, such as government ministers, leaders of political parties, mayors and traditional leaders, or executive positions at companies.
Due to the complex nature of EDD, this may cause a delay between opening a unit trust and receiving confirmation via a Welcome Letter.
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For any enquiries or additional assistance, contact us directly on 0860 100 266 or email email@example.com.