This past quarter there was a spotlight on accountable institutions when onboarding clients by Financial Intelligence Centre (FIC) to combat money laundering and providing funds or financial services to obtain weapons of mass destruction also known as proliferation financing. Section 28A of the FIC Act specifically mentions that accountable institutions must scrutinise their information concerning a client.

The following needs to be scrutinised:

1. At client onboarding
2. When conducting transactions
3. When the Targeted Financial Sanctions (TFS) list is updated

Warwick follows the following process set out in our RMCP to comply with the parameters set out by the FIC.

At client onboarding and conducting a financial instruction. Warwick follows these steps.

1. Obtain FICA for every new client onboarded.
2. An internal client risk rating is done placing the client in low, medium or high risk.

3. New business runs a check for every client through a third-party system that screens the client against all the sanction lists or if the client is a PEP or PIP and against adverse media findings.

All of this is evidenced and stored on our CRM system.

The Warwick Money Laundering Officer receives any updates made to the TFS list. The MLRO will then run a check of the individuals, or entities added to the list against or client base for any matches.

The Director of Operations also does an annual screening of our clients, and this is evidenced and stored on our CRM system.

From the above it can be seen that Warwick not only meets but exceeds the required expectations for an Accountable Institution.

Here’s to a successful Q3!