The Financial Sector Conduct Authority (FSCA) has imposed administrative sanctions on Sanlam Collective Investments (RF) (Pty) Ltd (SCI) for non-compliance with provisions of the Financial Intelligence Centre Act, 2001. The sanctions include a ZAR 10.6 million financial penalty, a directive to remedy the contraventions, and a caution against future breaches. The action follows an FSCA inspection conducted in March 2024 under section 45B of the Financial Intelligence Centre Act, which found shortcomings in SCI’s Risk Management and Compliance Programme (RMCP) and customer due diligence controls. Although SCI had an RMCP, it was not effectively implemented, particularly for client risk-rating, and it did not adequately address enhanced due diligence for partnerships, scrutiny of complex or unusually large transactions, termination of business relationships, identification and reporting of reportable transactions, and the justification for inapplicable RMCP requirements. The inspection also found failures to adequately identify and verify certain clients and beneficial owners and to conduct required ongoing and enhanced due diligence, including in respect of high-risk politically exposed persons; the FSCA also took account of SCI’s prior regulatory history, including an enforceable undertaking under the Financial Sector Regulation Act and a prior Collective Investment Schemes Control Act contravention. The FSCA suspended ZAR 3.6 million of the penalty for two years, conditional on SCI fully remediating the issues and maintaining sustained compliance with the relevant Financial Intelligence Centre Act provisions during the suspension period.

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