Every accountable person is required by Regulation 45(1) of the Anti-Money Laundering Regulations, 2015 to submit to the Financial Intelligence Authority(FIA) a compliance report setting out the level of compliance with the Act and Regulations and the Internal Anti-Money Laundering and Combating Terrorist Financing Policy of the accountable person at the end of each calendar year. The FIA developed a compliance report template to streamline and standardise the reports submitted by Accountable persons.
Accountable persons are listed under the Second Schedule to the Anti Money Laundering Act, 2013. Notably among these are NGOs, Advocates, Casinos, Financial Institutions, Registrars of Land and Companies, licensing Authorities, among others.
The compliance reports should be submitted to the Authority by the 31st day of January 2021 as per Regulation 45(2) of the Anti-Money Laundering Regulations, 2015.
- Annual Compliance Report in word format which should be emailed to firstname.lastname@example.org.
- Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) attachments;
- Copy of the AML/CFT policy and procedures
- Copies of AML risk assessment of customers, products, methods of delivery and geographical location of customers
- Copy of the independent audit report of the compliance program (2019) Suspicious transaction reports
Before filing, we recommend that institution s should have the following in place;
- A Certificate of Registration from the Financial Intelligence Authority.
- A money laundering control officer.
TASLAF Advocates remains committed to answering questions regarding anti-money laundering legal compliance as well as offering legal assistance in filing the Annual Compliance Report.
LLM(Harvard), LLB(MUK) Dip.LP(LDC)