Risk and compliance programme relating to FICA

 

The Donford Group

 

1. Introduction

 

The Donford Goup is committed to preventing money laundering and counter-terrorist financing activities within our operations. This Risk and Compliance Programme aims to ensure compliance of the Financial Intelligence Centre Act (FIC Act) in South Africa.

The programme focuses on identifying, assessing, monitoring, mitigating, and managing risks associated with money laundering and terrorist financing.

 

2. Program Objectives

 

Our Risk and Compliance Programme is designed to achieve the following objectives:

• Develop, document, maintain, and implement robust risk management and compliance procedures.
• Establish procedures to verify the identity of clients and understand the nature of their business relationships.
• Conduct due diligence on clients, including the verification of beneficial owners.
• Identify and examine complex or unusually large transactions and patterns that lack a lawful purpose.
• Address the requirements for dealing with domestic prominent influential persons or foreign prominent public officials.
• Ensure ongoing monitoring and reporting of suspicious transactions or activities.

This RMCP has been developed with reference to Guidance Note 7A, PCC 53, PCC 54, PCC 59, and the General Laws Amendment Act No. 22 of 2022, to ensure alignment with current regulatory expectations.

The RMCP will be part of the annual training session we conduct. Furthermore, the RMCP will be available via the website where all staff will be able to read it.

 

3. Identifying Risks

 

Certain steps need to be taken to mitigate these risks.

This could happen at various stages in the customer engagement process. Below describes how to act during those different stages:

To effectively mitigate the risks of money laundering and terrorist financing, defined procedures must be followed at each stage of the customer engagement process.

Customer Due Diligence (CDD) is required in the following cases:

• Customer vehicle transactions: CDD must be done for every transaction when we sell a vehicle to a customer
• Wholesale vehicle trade transactions (i.e., sales to other dealerships): CDD must be conducted at least once per year to ensure that client information remains current and accurate.

All purchases exceeding R250,000 are classified as high-risk transactions and must undergo comprehensive Customer Due Diligence (EDD) in accordance with the institution’s risk management and compliance framework found below.

3.1 Identifying the client and Customer Due Diligence

The Donford Goup will, when engaging with a prospective client during the transaction process:

• Verifying the client’s identity.
• If the client is acting on behalf of someone else, verifying the identity of that person and their authority to act.
• If someone else is acting on behalf of the client, verifying their identity and authority to act.

Below shows the documents which are required before entering in a business relationship.

For individuals with Finance:

Information Required	Method of Obtaining Information	Means of Verification
ID of Client and Principal or Representative (if applicable)	Received from client	Copy of client’s ID (identity document, driver’s licence, or passport)
Verification of Residential Address	Received from client	Copy of a client statement less than 3 months old
Proof of Driving Licence	Received from client	Proof of driving licence
Bank Statements	Received from client	3 months’ bank statements
Payslips	Received from client	3 months’ payslips
Client’s Employer’s Name and Address	Questionnaire completed by client	Payslip and online search to verify
Source of Funds (if cash & pre-arranged deal)	Questionnaire completed by client	Client to complete questionnaire
For clients acting on behalf of others	Received from client	Verification of client details and proof of authority

 

For individuals with Cash:

Information Required	Method of Obtaining Information	Means of Verification
ID of Client and Principal or Representative (if applicable)	Received from client	Copy of client’s ID (identity document, driver’s licence, or passport)
Verification of Residential Address	Received from client	Copy of a client statement less than 3 months old
Proof of Driving Licence	Received from client	Proof of driving licence
Source of Funds (if cash & pre-arranged deal)	Questionnaire completed by client	Client to complete questionnaire
For clients acting on behalf of others	Received from client	Verification of client details and proof of authority

The process that describes the way in which documents are collected and signed off can be found in Appendix A.

For corporations, partnerships, trusts, associations, etc.:

Identification and Verification of Beneficial Owners (UBOs)

In line with the Financial Intelligence Centre Act (FIC Act), Section 21B, and Public Compliance Communication 59 (PCC 59), the Donford Goup follows a structured process to identify and verify all natural persons who directly or indirectly own 5% or more of a legal entity, as well as those who exercise effective control over such entities, regardless of ownership percentage.

We apply the following steps:

• Identify and verify all natural persons who hold, directly or indirectly, 5% or more of the ownership interest or voting rights in the client.
• The ownership structure must be documented clearly through shareholding records, trust deeds, company organograms, and/or public registries such as CIPC or the Department of Social Development.
• All identified UBOs must be verified using appropriate documentation (e.g., certified ID copies, proof of address, and supporting ownership evidence).
• The Donford Goup will maintain records of all steps taken to identify UBOs, including those instances where a process of elimination was followed.

The documents required for the legal entities (including corporations, partnerships, trusts, associations) are:

Information Required	Method of Obtaining Information	Means of Verification
Legal Entity Documentation
Nature of Company/Trust/Partnership	Received from company	Company/Trust/Partnership registration documentation
Bank Verification	Received from company	3 months’ bank statements of the Company/Trust/Partnership
Proof of Address	Received from company	Copy of a company statement less than 3 months old
Financial Standing	Received from company	Latest signed-off financial statements
Ownership Structure	Questionnaire completed by representative	Ownership structure declaration of the company and associated UBOs, plus a copy of the share certificate
UBO/Partners/Trustees Information
Identity Document of all UBOs/Partners/Trustees	Received from UBOs	Copy of client’s ID (identity document, driver’s licence, or passport)
Driver’s Licence	Received from UBOs	Driver’s licence of one director
Proof of Residential Address of each UBO/Partner/Trustee	Received from UBOs	Copy of a client bill less than 3 months old
Source of Funds (if cash & pre-arranged deal)	Questionnaire completed by client	Client to complete questionnaire

 

3.2 Dealing with domestic prominent influential persons or foreign prominent public officials:

• If a prospective client or their beneficial owner is a domestic prominent influential person (DPIP), the Donford Goup will:
  • Obtain senior management approval.
  • Establish the source of wealth and funds.
• The Donford Goup will verify if a potential client is a DPIP by obtaining confirmation and conducting online searches.
• Factors considered include the risk profile of the DPIP, understanding the client’s wealth profile, and obtaining required approvals.

The Appendix checklist of Domestic Prominent Influential Persons (DPIPs) is available in cases where a DPIP is suspected. In addition, the client will be screened via Signio and/or an equivalent approved system) to determine whether they qualify as a DPIP, Foreign Politically Exposed Person (FPEP), or Prominent Influential Person (PIP). Screening outcomes must be documented and retained on file.

3.3 Examining complex large transactions and unusual patterns:

• The Donford Goup will scrutinize complex or unusually large transactions and transactions with no apparent lawful purpose.
• Different factors need to be considered in these transactions that include:
  • the nature of the vehicle
  • legislation and regulations
  • amounts involved
  • sourcing of funds
  • mismatched vehicles
  • multiple bank accounts
  • large deposits without business activities
  • unusual payment instructions
  • large transactions for new entities without economic reason
  • transactions inconsistent with the client’s profile or status

3.4 Ongoing Customer Due Diligence (applicable for Wholesale Trade Deals ONLY)

Wholesale vehicle trade transactions (i.e., sales to other dealerships) are considered lower risk, but CDD must be conducted at least once per year to ensure that client information remains current and accurate. The same documentation is required for trade deals mentioned in section 3.1 under the company/partnership/trust section.

Each other high value transaction with clients are done on a per transaction basis and therefore ongoing CDD is not required.

3.5  Re-verification of Client Information

If, at any stage, the institution has reason to doubt the accuracy, validity, or completeness of previously obtained client information, or when preparing a Suspicious Transaction Report (STR), the client’s identity and supporting documentation must be re-verified.

Re-verification may include:

• Requesting updated copies of identification and proof of address;
• Conducting new Targeted Financial Sanctions (TFS) and Politically Exposed Person (PEP) checks;
• Comparing existing records against current client information to detect discrepancies; and
• Recording the verification steps and outcomes in the client file.

If discrepancies cannot be resolved, the matter must be escalated to the Risk Officer or Reporting Officer for assessment and possible reporting to the Financial Intelligence Centre (FIC).

3.6 Determining Whether Future Transactions Are Consistent with Client Knowledge

Although ongoing customer due diligence applies only to wholesale trade deals, the institution must still ensure that each transaction is consistent with its knowledge of the client at the time of sale.

To meet this obligation:

• For retail vehicle sales, staff must confirm that the nature, value, and payment method of the transaction align with what is known about the client (e.g., employment, source of funds, or business activity).
• For wholesale trade transactions, where an ongoing relationship exists, transactions are reviewed periodically to ensure they remain consistent with the dealership’s knowledge of the trading partner.
• Any transaction that appears inconsistent, unusually large, or without an apparent lawful purpose must be escalated to the Risk Officer or Reporting Officer for review.
• The outcome of such reviews must be documented and retained in the client file.

If the inconsistency cannot be reasonably explained, the transaction will be treated as suspicious and reported to the Financial Intelligence Centre (FIC) in line with reporting procedures.

 

4. Assessing Risks:

 

We need to understand the risks associated with the services we provide and the money deposited into our accounts. The risks depend on the specific services we offer. The assessment process helps us understand the client and the following aspects:

• Client or potential client knowledge.
• Regulatory requirements if applicable.
• Nature and location of the business structure.
• Details of the beneficial owner.
• Details of the client’s representative if applicable

4.1 Examples of risks associated with the sale of HVG include:

• Criminals using HVG transactions to launder funds from illegal activities.
• Criminals hiding their identities or proceeds of crime within complicated legal structures or shelf companies.
• Criminals using intricate transactions to facilitate the flow of illegal funds.
• Criminals appointing attorneys as directors or trustees in trust-related services to create a sense of legitimacy for concealed criminal activities.
• Deceased criminals transferring proceeds of unlawful activities through structures created under their wills.

4.2 Risk Scoring

All prospective clients will undergo an automated risk assessment using Signio (or an equivalent approved system). The system will assign a Low, Medium, or High risk rating to each client as shown below:

Various factors are taken into consideration by Signio including:

• Client Type
• Client Business Activities
• Client Co-operation And Behaviour
• Client Interaction
• Client residency and nationality
• Transaction Type
• Transaction Size
• Client affordability and financial means
• Products and Services offered to the client

An example of a report is found in Appendix C.

Any high risk outcome must be escalated and checked by the Compliance Officer or dealer principle before client onboarding is finalised. Any overrides of the automated outcome must be documented with supporting reasons and authorised by the Compliance Officer.

4.3 TFS Screening

All prospective clients are to be screened against the TFS list on the FIC website and records must be kept on file for every screening, irrespective of nationality and a screenshot is taken. The TFS list is to be checked monthly to ensure screening measures remain current. If any prospective client, beneficial owner, representative, or related party is identified as being listed on the TFS list, the transaction must be halted immediately, all funds and assets frozen without delay, and the matter escalated to the Reporting Officer for reporting to the FIC. No business relationship may be established or continued with a listed person or entity.

Example of the screenshot below:

4.4 Assessing suspicious behaviour

Frontline and sales staff play a critical role in detecting suspicious activity, as they interact directly with clients and handle transaction information. The following are examples of suspicious behaviour and transactions commonly relevant in a motor dealership context:

Client Behaviour

• The client is overly secretive or reluctant to provide identification, proof of address, or other standard documentation.
• The client insists on completing the transaction in cash, particularly when the amount is high or close to the reporting threshold (R50,000 or more).
• The client becomes defensive or evasive when asked for source of funds or proof of payment details.
• The client attempts to split payments across multiple transactions or under different names to avoid reporting requirements.
• The client appears uninterested in vehicle details (e.g., price, specifications) and is focused only on completing the purchase quickly.
• The client attempts to purchase multiple vehicles without a clear business reason or explanation for their use.
• The client requests that ownership or delivery be made in another person’s name or insists that payment comes from a third party.

Transaction or Payment Irregularities

• Payments are made from foreign accounts or countries not associated with the client’s profile.
• Payments are made from multiple accounts or by unrelated third parties.
• The client provides unclear or inconsistent information regarding the source of funds.
• The transaction involves overpayment, followed by a request for refunds or redirection of funds to other accounts.
• A trade-in vehicle is overvalued or used to offset cash payments without clear rationale.
• A company or trust purchases a vehicle that appears inconsistent with its normal business activities (e.g., a logistics company buying luxury sports cars).
• The client requests to register the vehicle in another name or store it indefinitely without clear explanation.

General Red Flags

• The client has been associated with negative media or listed on sanctions/PEP databases.
• The client frequently changes contact details, delivery addresses, or account information during the transaction process.
• The client pressures staff to bypass standard procedures or offers a gratuity for speeding up compliance checks.
• The client refuses to engage through normal channels or insists on meeting off-site to complete the deal.

4.5 High risk factors and escalation

We consider the following factors for determining higher risk clients that need to be taken into consideration:

• Enabling company formation and asset administration across multiple countries without legitimate reasons.
• Engaging in transactions with complex ownership or control structures lacking an economic purpose.
• Using new technologies that may be exploited by criminals.
• Operating non-profit organizations involved in transactions with no logical economic purpose.
• Acting on behalf of undisclosed persons.
• Using virtual assets mainly for anonymity without a clear motivation.
• Offering unusually high fees for services without legitimate reasons.
• Engaging in transactions with unexplained and unusually high levels of assets or amounts.
• Engaging in transactions beyond our understanding of the client’s business or economic situation.
• Suspected involvement in falsifying or misleading activities.
• Deviating from industry norms in terms of business operations and staff numbers.
• Seeking advice for arrangements indicating tax evasion purposes.
• Providing incorrect or insufficient information.
• Conducting business with domestic prominent influential persons or their close associates.
• Engaging in business relationships under unusual circumstances.
• Obscuring the identity of beneficial owners through shelf companies or nominee shares.

Transaction Risks:

We consider the following services as presenting higher risks:

• Receiving and transmitting funds through our accounts for clients’ refund transactions.
• Clients requesting financial transactions outside their own bank accounts, using our general, personal, or business accounts.
• Services that represent or assure clients’ reputation and credibility to third parties without appropriate knowledge of the client’s affairs.
• Services that facilitate the concealment of beneficial ownership from competent authorities.
• Services outside our expertise, unless referred to trained professionals.
• Services heavily relying on new technologies vulnerable to exploitation by criminals.
• Payments received from unfamiliar or unknown third parties, including unconventional cash payments.
• Transactions involving inadequate consideration and lacking legitimate reasons.
• Deceased estates involving persons convicted of proceeds-generating crimes.

In addition, any transaction or deal exceeding R3,5 million must be reviewed and authorised by the Dealer Principal of the site before it is finalised, to ensure enhanced oversight and compliance with FIC obligations.

4.5 Terminating existing business relationships:

The Donford Goup will not establish a relationship or conclude a transaction if unable to establish and verify the client’s identity, obtain necessary information

If unable to meet the above requirements for an existing client, the relationship will be terminated, and a report may be considered under the FIC Act.

 

5. Reportable information

 

All employees must remain alert to activities that could indicate money laundering, terrorist financing, or proliferation financing. If an employee knows or reasonably suspects that any of the following situations apply, they must immediately report it to the Risk Officer or Reporting Officer.

5.1 Situations Requiring Immediate Reporting on GoAML website

Scenario	Description	Deadline to Report
Receipt or possession of criminal proceeds	The business has received, or is about to receive, money or property obtained from illegal activities, or related to the financing of terrorist activities.	Within 15 days of suspicion
Transactions linked to illegal funds or terrorist financing	The business is or has been involved in transactions that: • Assist in transferring or concealing funds from illegal activities • Are unusually large, complex, or without legitimate purpose • Appear structured to avoid reporting requirements • Are connected to tax evasion • Are linked to terrorist financing	Within 15 days of suspicion
Use of the business for criminal purposes	The business has been, or is about to be, used for money laundering, terrorist financing, or proliferation financing.	Within 15 days of suspicion
Large cash transaction received	A transaction where the business receives R50,000.00 or more in cash from a client, representative, or principal.	Within 3 days
Large cash payment made	A transaction where the business makes a cash payment of R50,000.00 or more.	Within 3 days

 

5.2   Reporting Processes and Responsibilities

The institution has established clear processes for reporting information to the Financial Intelligence Centre (FIC) in terms of Part 3 of Chapter 3 of the FIC Act.

To ensure clarity of duties within the dealership, responsibilities are divided as follows:

• The Reporting Officer is responsible for all reporting obligations to the Financial Intelligence Centre (FIC), including the assessment and submission of Suspicious and Unusual Transaction Reports (STRs), Terrorist Property Reports (TPRs), and Cash Threshold Reports (CTRs) via the goAML platform.
• Customer Due Diligence (CDD) is managed by the F&I Manager are responsible for implementing and maintaining client identification, verification, and ongoing monitoring processes in line with this RMCP. This includes ensuring that client information remains current and accurate, conducting annual reviews for trade partners, and escalating any unusual activity or suspicion to the Reporting Officer.

This separation of responsibilities ensures appropriate checks and balances between client monitoring and statutory reporting functions.

As mentioned, reporting is managed by the Reporting Officer, who is responsible for the following:

• Submitting Suspicious and Unusual Transaction Reports (STRs), Terrorist Property Reports (TPRs), and Cash Threshold Reports (CTRs) via the FIC’s goAML electronic platform;
• Ensuring all reports are submitted within prescribed timelines;
• Maintaining a register of all reports filed, including submission date, goAML reference number, and confirmation receipt from the FIC;
• And coordinating with the Compliance Officer to ensure staff awareness and adherence to reporting procedures.

All employees are prohibited from informing or alerting any client or third party that a report has been or will be submitted to the FIC (“tipping off”).

5.3 Attempts and Other Reportable Situations

If an employee knows or suspects an attempted transaction that would have triggered any of the above obligations, they must also report it in writing to the Risk Officer immediately. This includes incomplete or failed attempts that show intent to engage in suspicious activity.

If an employee knows (not just suspects) that the business possesses or controls property or assets belonging to:

• Any person or entity listed under UN Security Council Resolution 1267,
• The Targeted Financial Sanctions (TFS) List, or
• Any other person or entity involved in terrorist or proliferation-related activities, they must report it immediately to the Risk Officer.

5.4  Internal and External Reporting Procedure

Internal Escalation:

• Employees must report suspicions directly to the Reporting Officer, who is responsible for reviewing and assessing the information.
• Where the transaction/incident is complex or further guidance is required, the Reporting Officer will escalate the matter to the Compliance Officer and/or Dealer Financial Services. Thereafter, a report will be filed with the Financial Intelligence Centre (FIC) via the goAML platform.

External Reporting:

• The Reporting Officer must submit reports to the FIC using its electronic reporting system.
• The report must include all relevant details and supporting documentation.

Confidentiality and Non-Tipping Off:

• Employees must not inform the client or any third party about the submission or intended submission of a report.
• No discussion or disclosure about the contents of the report may take place outside of the designated reporting chain.

5.5 Designated Reporting Officer

The Reporting Officer is the individual responsible for receiving internal reports of suspicious or unusual transactions and for ensuring compliance with statutory reporting timelines.

Full contact details of the appointed Reporting Officer are included in Annexure B of this RMCP.

 

6. Mitigating Risks:

 

The Donford Goup understands that the risk profile of clients can change over time, especially in long-term relationships.

To mitigate risks related to anti-money laundering and counter-terrorism financing, the Donford Goup implements relevant policies. Some specific measures we consider include:

• Utilizing more or higher quality sources to verify information
• Involving senior management in decisions to onboard clients where risks are perceived higher
• Assigning dedicated specialists to manage enhanced due diligence for specific clients

Training

The business recognises the importance of ensuring that all employees, particularly those in frontline positions, are equipped to identify and manage risks related to money laundering, terrorist financing, and proliferation financing.

Formal training is conducted annually in collaboration with Dealer Financial Services for all frontline staff. These sessions serve as a refresher on the institution’s Risk Management and Compliance Programme (RMCP) and include updates on any legislative or regulatory changes that impact our compliance obligations.

In addition to the annual training, all newly appointed frontline employees are required to complete an online training module covering the RMCP, key compliance concepts, and reporting procedures. A comprehensive assessment follows the training, which must be passed with a minimum score of 75%. The same assessment standard applies during the annual refresher training to ensure that all employees maintain a consistent and adequate understanding of their obligations under the FIC Act.

Records of all training sessions, attendance, and assessment results are maintained by the Compliance Officer and are available for inspection upon request by the Financial Intelligence Centre (FIC) or other relevant authorities.

Recruitment

When we recruit and train staff in front line staff positions, we will check for characteristics of honesty and integrity.

 

7. Record-keeping and reporting

 

Regarding record-keeping and reporting, the Donford Goup maintains records as required by the Act for a minimum period of 5 years. These records include:

• Verification of client details.
• Information about the nature and purpose of the business relationship, as well as the source of funds used in transactions during the relationship.
• Details of each transaction, including the amount, currency, parties involved, date of the transaction, and relevant business correspondence.

In accordance with section 29 of the FIC Act, employees of the Donford Goup are required to report suspicious and unusual transactions related to unlawful activities connected to our business. Reporting to the FIC may be necessary if:

• We have received or are about to receive proceeds from unlawful activities or property connected to financing terrorist and related activities.
• We are involved in a transaction that facilitates or is likely to facilitate the transfer of proceeds from unlawful activities or property related to financing terrorist and related activities, has no business purpose, or is designed to avoid reporting obligations under the FIC Act.
• Our business has been or is about to be used for money laundering purposes or to facilitate offenses related to financing terrorist and related activities.

Additionally, when the client, someone representing the client, the beneficial owner, a transaction participant, or the end user of the client’s goods or services is a sanctioned individual listed on a TFS list, and DFS has possession or control over the sanctioned person’s property (including funds, vehicles, etc.), we are required to promptly freeze the sanctioned person’s property. You can search for people on the sanctioned list on the below

https://www.fic.gov.za/International/sanctions/Pages/search.aspx

Where multiple group businesses are involved, each business unit must perform its own CDD and risk assessment processes. Information may be shared across businesses strictly on a need-to-know basis, subject to confidentiality safeguards. Shared information must be transmitted securely, and access limited to authorised compliance personnel only, in line with the requirements of Section 42(2)(qA) of the FIC Act.

The Donford Goup will not enter into or continue any business relationship or transaction involving jurisdictions identified by the Financial Action Task Force (FATF) as high-risk or on the FATF blacklist. Clients or transactions linked to such jurisdictions must be escalated to the Compliance Officer, and no further activity may proceed without senior management approval and documented risk mitigation measures.

If our employees have knowledge or suspicions related to the above scenarios, they are required to report the grounds for their knowledge or suspicion and provide the necessary details about the transactions within the prescribed timeframe.

 

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Appendix A

 

Customer Due Diligence Process:

 

Appendix B

 

Compliance Officer:   Robert Philp                0719020833    robert.philp@donford.co.za

The FIC Act ascribes the following meaning to the following definitions:

‘unlawful activity’ -“conduct which constitutes a crime or which contravenes any law, whether such conduct occurred before or after the commencement of this Act and whether such conduct occurred in the Republic or elsewhere.

‘Money laundering’ or ‘money laundering activity’ means an activity which has or is likely to have the effect of concealing or disguising the nature, source, location, disposition or movement of the proceeds of unlawful activities or any interest which anyone has in such proceeds, and includes any activity which constitutes an offence in terms of section 64 of this Act or section 4, 5 or 6 of the Prevention of Organised Crime Act, contains the following definitions:

‘Money laundering’ – any person who knows or ought reasonably to have known that property is or forms part of the proceeds of unlawful activities and-

(a) enters into any agreement or engages in any arrangement or transaction with anyone in connection with that property, whether such agreement, arrangement or transaction is legally enforceable or not; or (b) performs any other act in connection with such property, whether it is performed independently or in concert with any other person, which has or is likely to have the effect-

(i)         of concealing or disguising the nature, source, location, disposition or movement of the said property or its ownership or any interest which anyone may have in respect thereof; or

(ii)        of enabling or assisting any person who has committed or commits an offence, whether in the Republic or elsewhere- (aa) to avoid prosecution; or (bb) to remove or diminish any property acquired directly, or indirectly, as a result of the commission of an offence, shall be guilty of an offence.

‘Assisting another to benefit from proceeds of unlawful activities’ – means any person who knows or ought reasonably to have known that another person has obtained the proceeds of unlawful activities, and who enters into any agreement with anyone or engages in any arrangement or transaction whereby-

(a)        the retention or the control by or on behalf of the said other person of the proceeds of unlawful activities is facilitated; or

(b)        the said proceeds of unlawful activities are used to make funds available to the said other person or to acquire property on his or her behalf or to benefit him or her in any other way, shall be guilty of an offence.

The term “terrorist activity” and the offence of terrorism and offences associated or connected with terrorist activities were introduced into FIC Act when the Protection of Constitutional Democracy Against Terrorist and Related Activities Act (POCDATARA) was enacted. With the enactment of POCDATARA, FIC Act imposes a reporting obligation in connection with property associated with terrorist and related activities which may come into the dealerships/HVGT’s possession or under its control.

DOMESTIC PROMINENT INFLUENCIAL PERSONS	YES	NO
President or Deputy President of South Africa
Government minister or deputy minister
Premier of a province
Member of the Executive Council of a province
Executive mayor of a municipality
Elected in terms of the Local Government: Municipal Structures Act
Leader of a political party registered in terms of the Electoral Commission Act, 1996
Member of a royal family or senior traditional leader as defined in the Traditional Leadership and Governance Framework Act, 2003
Head, accounting officer or chief financial officer of a national or provincial department or government component, as defined in section 1 of the Public Service Act, 1994
The municipal manager of a municipality or chief financial officer
Chairperson of the controlling body, the chief executive officer, or a natural person who is the accounting authority, the chief financial officer or the chief investment officer of a public entity listed in Schedule 2 or 3 to the Public Finance Management Act. List inserted below.
the chairperson of the controlling body, chief executive officer, chief financial officer or chief investment officer of a municipal entity as defined in section 1 of the Local Government: Municipal Systems Act, 2000
a constitutional court judge or any other judge as defined in section 1 of the Judges’ Remuneration and Conditions of Employment Act, 2001
an ambassador or high commissioner or other senior representative of a foreign government based in the Republic
an officer of the South African National Defence Force above the rank of major- general
chairperson of the board of directors; (ii)  chairperson of the audit committee; (iii)  executive officer; or (iv)  chief financial officer, of a company, as defined in the Companies Act, 2008 (Act No. 71 of 2008), if the company provides goods or services to an organ of state and the annual transactional value of the goods or services or both exceeds an amount determined by the Minister by notice in the Gazette; or
the position of head, or other executive directly accountable to that head, of an international organisation based in the Republic.

 

Additional Reading list:

1. Financial Sector Conduct Authority AML/CFoT. Body of Knowledge, April 2022;
2. Media Release Cash Threshold reporting now R50’000.00, Financial Intelligence Centre; October 2022
3. Amendments to Money Laundering and Terrorist Financing Control regulations,2002 in terms of Fic act,2001, Threshold increase to R49’999.99
4. South Africa Financial Sector Assessment Program, Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT)—Technical Note, International Monetary Fund, March 2015
5. Definition of a Motor Vehicle Dealer for the purpose of Schedule 3 of the FIC act.
6. FIC Amendment Act MLTFC Regulations introducing High Value Goods Traders. HVGT.

 

Appendix C