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      Remediation

      Prepared by

      Operations

      Date

      25-06-2024

      Below are the queries that remediation  team will handle:

      • Risk Based Approach Remediation (1,2, or 3 years)
      • Trigger event remediation (change in AML status, breach of expected account activity, etc)
      • Account closure that will require remediation

      Team members

      Jaydin Flusk
      Suvira Singh
      Sinelizwi Diko

      Escalation

      Hitesh Palla

      Process that would need to be followed per query

      Remediation types

      • Trigger event Remediation (Account closure/ Withdrawals/Transfers + closure)
      • Account closure remediation (Remediation in line with PCC 11 ITO the FIC)
      • RBA Remediation
      • Transactional monitoring remediation (Breaches in intended investment amount over the next 3 years)
      • Bulk remediation
      • Remediation queries

      Account closure remediation (KYC and Regulatory compliant)

      • Account closure remediation involves ensuring that our institution has complied with both Part 1 and Part 2 of Chapter 3 of the Financial Intelligence Centre (FIC) Act, along with the relevant regulations. The closure of a client’s account constitutes a transaction and may not proceed unless the institution has adhered to the identification, verification, and record-keeping requirements as mandated by the FIC Act.

      Withdrawals (Full remediation)

      • Considering our ongoing business relationships, it is imperative that we maintain updated and accurate information for all clients, including their financial profiles, demographic details, and tax regulatory documents (such as W-8BEN and SARS DWT).

      RBA Remediation (Full Remediation)

      The frequency and depth of ongoing due diligence for any business relationship should be guided by the accountable institution’s assessment of money laundering and terrorist financing risks linked to that relationship. It is essential for the institution to outline in its Risk Management and Compliance Program (RMCP) the procedures and methodologies it will employ for ongoing due diligence and monitoring of these relationships. Furthermore, the RMCP must detail how the institution will scrutinize complex or unusually large transactions, as well as detect and handle unusual transaction patterns lacking apparent business or legal justification. It should also specify how the institution will document its findings regarding such transactions.

      Clients are remediated according to the below frequency at DMA
      – Low Risk – Every 2 years 9 months
      – Medium Risk – Every 1 year 9 months
      – High Risk and PEP – Every 9 months

      Transactional monitoring remediation (Breaches in intended investment amount over the next 3 years)

      Suspicious Financial activity – request EDD
      Breach due to Dated account = Full Remediation

      An accountable institution must, in accordance with its Risk Management and Compliance Programme and to combat Money Laundering, Bribery and Corruption as well as Terrorist Financing Activities, conduct ongoing due diligence in respect of a business relationship which includes and is most pertinent in this instance monitoring transactions undertaken throughout the course of the relationship including where necessary , the source of funds, to ensure that the transactions are consistent with the accountable institution’s knowledge of the client and the client’s business and risk profile; and the background and purpose of all complex, unusual large transactions, and all unusual patterns of transactions.

      Transactional analysis is an important business factor, that is undertaken which entails reviewing a client’s profile, as part of remediation this must be reviewed to check if a client’s transacting patterns has changed over a period and if it still corresponds with a client’s profile. We are required to perform Enhanced Due Diligence and re-risk rate the client in accordance with the new transactional activity.

      Documents that need to be provided to remediate the client account

      Entity Types and remediation:

      Additional information can be requested if deemed necessary for the purposes of the remediation

      Special notes:

      1) Two certified proofs of residence for countries consider high risk in terms of FATF.
      2) Certified proof of residence and banking for non-local residence or banking
      3) We Can accept Joint proof of residence and proof of banking given it displays both the clients name, if we accept a Joint proof of banking for an individual client account, 3rd party process needs to be followed.
      4)Minor accounts Guardian consent form and surety. If minor is of the legal age (over 18) an ID document will be required

      Wrapper: N/A

      Individual

      Remediation form (Digital; /Manual)

      If we do not have of the below documents on file, we will request them (reliance agreement, novation, etc)

      ID (Especially if accounts were opened for SA Citizens with passport)
      Proof of residence dated no older than 3 months
      Proof of banking is not a FIC requirement however to avoid delays in deposits and withdrawals its requested
      Relevant tax doc (SARS DWT / W8ben)
      Original account opening docs if not on record – This is due to transfers / Novation’s / book moves or non-submission at onboarding)

      • Cover letter
      • Power of attorney
      • Original CAF

      Joint account

      Remediation form (Digital; /Manual)

      If we do not have of the below documents on file, we will request them (reliance agreement, novation, etc)

      ID (Especially if accounts were opened for SA Citizens with passport)
      Proof of residence dated no older than 3 months
      Proof of banking is not a FIC requirement however to avoid delays in deposits and withdrawals its requested
      Relevant tax doc (SARS DWT / W8ben)
      Original account opening docs if not on record – This is due to transfers / Novations / book moves or non-submission at onboarding)

      • Cover letter
      • Power of attorney
      • Original CAF

      Trust

      Remediation form (Digital; /Manual)

      If we do not have of the below documents on file, we will request them (reliance agreement, novation, etc)

      Letter of Authority;
      The Trust Deed/Will;
      Any Resolutions;
      Signatory Rules;
      Proof of ID for the Donor, Trustees and beneficiaries;
      Proof of residential address for the Donor, Trustees, beneficiaries and any other authorised person.

      Corporate

      Remediation form (Digital; /Manual)

      If we do not have of the below documents on file, we will request them (reliance agreement, novation, etc)

      Certificate of Incorporation
      Moi – Memorandum
      Certificate of Name Change (If applicable)
      Proof of Registered Address
      Register of Directors
      Registration of Local Company
      Articles of Association
      Copy of Licence (if applicable)
      Shareholders Register
      Any Resolutions That Have Been Made by The Board of Directors
      Certificate of Incumbency (if applicable)
      Signatory Rules
      Proof of ID for each Director, Shareholder and authorised person;
      Proof of residential address for Director, Shareholder and authorised person (not older than 3 months;

      Account closure process that will trigger remediation.

      Withdrawal

      Initial Notification

      • Upon receipt of an account closure request or a request for a total or significant withdrawal of funds with no open positions, the Treasury will notify the Remediation Team and CC the client/Investment Manager (IM) to initiate the remediation process before the withdrawal.

      Compliance Check

      • The Remediation Team will assess the client’s compliance status, determining if they are compliant, non-compliant, a wrapper, or an asset swap.
      • If the client is non-compliant, the remediation process will be initiated. Once remediation is complete, the Remediation Team will notify the Treasury to proceed with the account closure, CC’ing the client/IM to indicate the completion of the remediation process and the start of the account closure, withdrawal, and payment process.

      Commencement Notification

      • A notification email will be sent to the client/IM, CC’ing the Remediation and Institutional Support teams, to announce the start of the account closure, withdrawal, and payment process.
      • This email will also instruct the client/IM to review the expiry dates on corporate actions and submit an additional withdrawal request for all dividends to be paid out.

      Fund Retention

      • Treasury will retain a surplus of funds in the client’s account for any fees that may be incurred after the withdrawal is processed, as a precaution:
      • USD 10
      • AUD 10
      • CHF 10
      • EUR 8
      • GBP 6
      • ZAR 100

      Post-Withdrawal Processing

      • After processing the withdrawal, Treasury will compile a spreadsheet of accounts requiring a sweep after all fees (administrative, management) are processed in the first week of the new month.
      • Once funds have been swept, Treasury will inform Institutional Support to close the accounts.

      Account Closure Confirmation

      • Institutional Support will confirm the account closures with Treasury. If any accounts cannot be closed, Support will provide the reasons.
      • Support will notify the Helpdesk and DQM/Remediation to close the accounts on the Helpdesk and Refinitiv.

      Minimum Payout Thresholds

      • DMA cannot process payouts below the following amounts due to intermediary bank fees on withdrawals:

      o USD 40
      o ZAR 150

      Position Movement and Account Closure Process

      Template and Journal Submission:

      • The position movement template, along with the cash journal, will be sent to the Transfers team.

      Share Transfer:

      • The DMA Transfers team will transfer the shares to the new account.

      Final Calculation and Fund Transfer:

      • The DMA Treasury team will calculate the final figures, including accumulated interest, and transfer the funds accordingly.

      Corporate Actions Review:

      • The client/IM will review the expiry dates on corporate actions and submit an additional cash journal.

      Spreadsheet and Account Closure:

      • A spreadsheet will be sent to Institutional Support, and the account will be closed.

      Inter-Account Transfer (Cash Only)

      Cash Journal Submission:

      • The cash journal will be sent to transfers who will forward the journal DMA Treasury team after the positions have been transferred.

      Final Calculation:

      • The Treasury team will calculate the final figures, including accumulated interest.

      Fund Transfer:

      • The Treasury team will transfer the funds from one sub-account to another.

      Corporate Actions Review:

      • The client/Investment Manager (IM) will review the expiry dates on corporate actions and submit an additional cash journal if necessary.

      Account Closure:

      • A spreadsheet will be sent to Institutional Support, and the account will be closed

      Remediation that would need to be done on a stock transfer account closure

      • Transfers team to receive the instruction which includes a transfer out and account closure.
      • Transfers team to find out from remediation team if the account needs to be remediated.
      • Transfers team to send the IM an email requesting the following:
      • Client statement as proof of account
      • Excel transfers sheet/ or complete the sheet from the client from PowerBi dash built
      requesting an approval
      • Requirements needed from Remediation
      • A withdrawal form and proof of banking.
      • Once received transfers team need to send the documents to remediation team.
      • Transfers team need to send full withdrawal instruction to Vault & Vault can proceed
      with the withdrawal.