In accordance with global anti-money laundering and anti-terrorist financing regulations, the Financial Intelligence Centre Act (FICA) was amended in 2017 requiring accountable institutions to implement a risk-based approach instead of the traditional rules-based approach which relied mostly on the collection of documents.
Accountable Institutions are required to continuously monitor the investment activities of their clients and may from time to time need to contact certain clients in order to understand the nature of those activities better.
Because of the unique nature of our business and the fact that most of it is conducted with little contact with our clients, we've devised a mechanism we call the Upper Deposit Limit to give us the opportunity to conduct our ongoing customer due diligence as required.
Upper Deposit Limit (UDL)
We use the "Earnings Status" you captured on registration to allocate you an Initial Upper Deposit Limit as per the table below:
Current Earnings Status
Initial Upper Deposit Limit
Private Sector Employment
Public Sector Employment
Self-employed / Consultant / Entrepreneur
You then start funding your account and we keep a tally of the value of the total deposits made across all your accounts (ZAR, TFSA, USD (in rand equivalent), RA etc) in the tax year (1 March to end-February every year).
When a new deposit causes that total cumulative deposit value to exceed your UDL we:
1. Direct the deposit to a special account, where your money attracts interest at the same rate as if it were allocated directly into your investment account. This is to ensure that your cash remains safe.
The deposit is visible on your account overview page (as highlighted in yellow in the image below) and the value reflected in your NAV but cannot be invested until we've had a chat.
2. Have one of our Client Engagement Champions call you to ask some questions about:
- The source of funds, and
- Your annual income so that we can consider increasing your Upper Deposit Limit to operate in line with what we think you're reasonably able to invest in a year.
Can you do anything in advance?
Yes, of course. Should you believe that the UDL is too low and that you're likely to breach it in a year, or you've already deposited more so your next deposit will breach, please email one of the documents listed below to email@example.com, so that we can evaluate a possible increase to your UDL or work closely together with you to reset the rules according to how you plan to invest:
- Copy of IRP5 (no older than the previous tax year)
- Copy of a payslip (no older than 3 months old)
- Copy of minimum of two (2) months bank statements (no older than 3 months old)
- Any other 'formal' documents that may be able to prove your earnings to us
If the deposit is a larger than normal sum and of an irregular nature (e.g. a bonus, inheritance, commission, proceeds on sale of assets) you can also email documentary evidence of that particular deposit to us so that we can take that into account too.
- This is not meant to be an onerous or difficult process, but rather a consultative one in which we have a chat, get to know you a bit better and update some of your information.
- We assure you that we will safeguard the security, integrity, and confidentiality of any information sent to us as we are required to do as an authorised FSP and in terms of the Protection of Personal Information Act, 2013.
Should you notice a deposit is Uncleared and haven't been contacted yet, or have any questions / concerns with regard to the operation of our UDL, please call into our Client Service department on the usual number + 27 (0)87 940 6106 stating that you have an Uncleared Deposit or want to talk about your UDL so that an agent can help you immediately.