Real Estate Investor Magazine June 2023 Edition | Page 61

ISK INDICATORS
MONEY LAUNDERING
Act ( FICA ) as being vulnerable to money laundering and / or terrorist finance abuse .
ISK INDICATORS
’ s trust account st accounts to purchase high-end icles where it appears to be concealing O ) anies charities and / or non-profit be concealing the UBO ime or monetary instruments nee , deposit the funds into bank issue cheques on behalf of clients for
titioners numerous times within a
etween the declared price and the movable or movable property . rd party without logical or economic
sfer of funds to or from a foreign onomical or logical reason . ssets . hase of property with cash and soon security for a loan . ed company or established entity
match the client ’ s source of funds .
How to combat it The FIC states that by filing regulatory reports , legal practitioners play an important role in fighting financial crime . Of the 6.2 million regulatory reports the FIC received in the 2019 / 20 financial year , attorneys filed a total of 2 254 .
The vast majority of these were cash threshold reports ( 2 549 ) while 205 were suspicious and unusual transaction reports ( STRs ). In terms of the FIC ’ s 2021 / 2022 Annual Report , 2 300 reactive and 782 proactive financial intelligence reports were produced , and 32 on illicit financial flows .
Of the 782 proactive reports , 131 related to high priority matters . In addition , the FIC contributed to the recovery of over R5 billion in criminal proceeds , a considerable increase in comparison to the R3.3 billion recovered in the previous year .
Another way to assist in combating ML for law firms is to implement , develop , document and maintain a robust Risk Management and Compliance Programme ( RMCP ), identifying and describing the ML / TF / Proliferation Financing risks envisaged by the AI and
SA Real Estate Investor Magazine JUNE / JULY 2023 60