- For
- Institutions without a programme, or with one that does not describe the business.
- What we do
- Registration and goAML setup where needed. The business risk assessment. The programme itself. Due diligence, screening and record keeping your staff can follow. Cash threshold, suspicious transaction and terrorist property reporting, with the register and the filing routine. Staff training with an attendance register, a refresher cycle and a process for new joiners. Management and board reporting. Preparation for an inspection, and support during one.
- What you receive
- A programme that describes your business. The risk assessment supporting it. Working procedures for the people who use them. The registers and logs an inspector will ask to see. A prioritised plan for whatever still needs attention.
What a generic programme leaves out
If your business deals in high-value goods and receives payment of R100,000 or more in a transaction, it has been an accountable institution under item 20 of Schedule 1 of the Financial Intelligence Centre Act since December 2022. The threshold reaches linked payments, so three invoices of R60,000 to the same buyer in the same week are not three small sales. Getting that wrong is how a business discovers it has been an accountable institution for nearly four years.
There is a second number, and in daily operation it can matter more. Cash received or paid out of R50,000 or more triggers a cash threshold report under section 28, within three business days. It has nothing to do with whether you are in scope under item 20. Failure to report cash transactions was the principal finding behind the penalties the Centre published against motor and Krugerrand dealers in 2022, and the register is one of the first things an inspector can reconcile against your sales ledger.
A business-specific programme contains what a generic one does not: your products and how they are paid for, your branches and who signs off at each, your customer types and what higher risk means among them, the systems your staff use, the reports you file and who files them, and the training record for the people doing the work. A downloaded programme contains none of that, and since section 21 of the Act requires due diligence to be done in accordance with your own programme, every file is then measured against a document that is not about you.
Our article on template programmes sets out what a bought document cannot do.