New FICA legislation prescribes that in addition to verifying a potential clients identity before beginning a business relationship, Accountable Institutions need to continuously monitor the behaviour of that client account and potentially subject it to a higher level of due diligence if that behaviour deviates significantly from what is expected.

In the case of EasyEquities, if a new deposit causes the value of the total deposits made in any tax year (1 March to end-February every year), to exceed an amount we expect the client to be able to make, then we contact the client to get to know them better, and may request certain additional documentation from them.

During this time, the deposit is temporarily held in an accrual account where it earns interest at the same rate as a client would earn on free cash. 

Once this exercise has been concluded, the deposit is immediately released back into the client account.