Enforcement Process
The Compliance Monitoring Committee
The Compliance Monitoring Committee (CMC) is an internal organ set up by the FIAU to assist in carrying out its enforcement powers, by considering potential breaches of AML/CFT obligations and determining the most appropriate administrative measures to address identified breaches. The members of the CMC are the FIAU Director, FIAU Deputy Director and senior representatives of the Supervision and Enforcement Section and the Legal Affairs Section, whereas the FIAU Director is the Chairman of the CMC (or the Deputy Director, in his absence).
Potential breaches of AML/CFT obligations presented at CMC may be the result of the following:
1. A compliance review carried out by Supervision which leads to the identification of potential breaches of AML/CFT obligations as stipulated in the PMLFTR or the FIAU’s Implementing Procedures;
2. The subject person failed to submit information demanded by the FIAU within the stipulated timeframe as required in terms of Regulation 15(8) of the PMLFTR; or
3. The subject person failed to submit periodical reports as requested by the FIAU in terms of Regulation 19 of the PMLFTR.
Administrative Measures
Identified breaches of AML/CFT obligations may result in the CMC enforcing administrative measures on the subject person concerned, and in some cases the CMC may also decide to impose two or more measures simultaneously. Administrative measures that can be applied include:
Prior to the CMC evaluating and deciding upon potential breaches of AML/CFT obligations, subject persons are granted the opportunity to submit their representations within a stipulated time frame following notification of the potential breach. It is on the basis of the representations as well as on the extent to which a breach is considered to be serious, systematic and repetitive that the CMC will decide the administrative measures to be applied if it is concluded that a breach was committed by the subject person.
2023

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Act III of 2015 provided for the publication of administrative penalties imposed by the FIAU. Over the years the relevant provisions within the Prevention of Money Laundering Act governing publication have undergone numerous amendments, with publication being subject to different thresholds and conditions over the years. As of 7 February 2020, the FIAU is to publish any administrative penalty and/or measure it imposes, including any appeal therefrom, independently of the amount involved.
In line with the FIAU’s Publication Policies and Procedures, any notice published on the FIAU’s website is removed following the lapse of five years from its date of publication. Where an appeal was filed, the five years are considered to start running from the date on which the Appeal Decision Notice is published. Due to the said time limit and the differing publication requirements that may have been applicable at the time, the notices on the website do not necessarily represent all the administrative penalties and/or administrative measures taken by the FIAU over the years.
2022

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Act III of 2015 provided for the publication of administrative penalties imposed by the FIAU. Over the years the relevant provisions within the Prevention of Money Laundering Act governing publication have undergone numerous amendments, with publication being subject to different thresholds and conditions over the years. As of 7 February 2020, the FIAU is to publish any administrative penalty and/or measure it imposes, including any appeal therefrom, independently of the amount involved.
In line with the FIAU’s Publication Policies and Procedures, any notice published on the FIAU’s website is removed following the lapse of five years from its date of publication. Where an appeal was filed, the five years are considered to start running from the date on which the Appeal Decision Notice is published. Due to the said time limit and the differing publication requirements that may have been applicable at the time, the notices on the website do not necessarily represent all the administrative penalties and/or administrative measures taken by the FIAU over the years.
2021

Read More
Act III of 2015 provided for the publication of administrative penalties imposed by the FIAU. Over the years the relevant provisions within the Prevention of Money Laundering Act governing publication have undergone numerous amendments, with publication being subject to different thresholds and conditions over the years. As of 7 February 2020, the FIAU is to publish any administrative penalty and/or measure it imposes, including any appeal therefrom, independently of the amount involved.
In line with the FIAU’s Publication Policies and Procedures, any notice published on the FIAU’s website is removed following the lapse of five years from its date of publication. Where an appeal was filed, the five years are considered to start running from the date on which the Appeal Decision Notice is published. Due to the said time limit and the differing publication requirements that may have been applicable at the time, the notices on the website do not necessarily represent all the administrative penalties and/or administrative measures taken by the FIAU over the years.
2020

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Act III of 2015 provided for the publication of administrative penalties imposed by the FIAU. Over the years the relevant provisions within the Prevention of Money Laundering Act governing publication have undergone numerous amendments, with publication being subject to different thresholds and conditions over the years. As of 7 February 2020, the FIAU is to publish any administrative penalty and/or measure it imposes, including any appeal therefrom, independently of the amount involved.
In line with the FIAU’s Publication Policies and Procedures, any notice published on the FIAU’s website is removed following the lapse of five years from its date of publication. Where an appeal was filed, the five years are considered to start running from the date on which the Appeal Decision Notice is published. Due to the said time limit and the differing publication requirements that may have been applicable at the time, the notices on the website do not necessarily represent all the administrative penalties and/or administrative measures taken by the FIAU over the years.
2019

Read More
Act III of 2015 provided for the publication of administrative penalties imposed by the FIAU. Over the years the relevant provisions within the Prevention of Money Laundering Act governing publication have undergone numerous amendments, with publication being subject to different thresholds and conditions over the years. As of 7 February 2020, the FIAU is to publish any administrative penalty and/or measure it imposes, including any appeal therefrom, independently of the amount involved.
In line with the FIAU’s Publication Policies and Procedures, any notice published on the FIAU’s website is removed following the lapse of five years from its date of publication. Where an appeal was filed, the five years are considered to start running from the date on which the Appeal Decision Notice is published. Due to the said time limit and the differing publication requirements that may have been applicable at the time, the notices on the website do not necessarily represent all the administrative penalties and/or administrative measures taken by the FIAU over the years.
2018

Read More
Act III of 2015 provided for the publication of administrative penalties imposed by the FIAU. Over the years the relevant provisions within the Prevention of Money Laundering Act governing publication have undergone numerous amendments, with publication being subject to different thresholds and conditions over the years. As of 7 February 2020, the FIAU is to publish any administrative penalty and/or measure it imposes, including any appeal therefrom, independently of the amount involved.
In line with the FIAU’s Publication Policies and Procedures, any notice published on the FIAU’s website is removed following the lapse of five years from its date of publication. Where an appeal was filed, the five years are considered to start running from the date on which the Appeal Decision Notice is published. Due to the said time limit and the differing publication requirements that may have been applicable at the time, the notices on the website do not necessarily represent all the administrative penalties and/or administrative measures taken by the FIAU over the years.
2017

Read More
Act III of 2015 provided for the publication of administrative penalties imposed by the FIAU. Over the years the relevant provisions within the Prevention of Money Laundering Act governing publication have undergone numerous amendments, with publication being subject to different thresholds and conditions over the years. As of 7 February 2020, the FIAU is to publish any administrative penalty and/or measure it imposes, including any appeal therefrom, independently of the amount involved.
In line with the FIAU’s Publication Policies and Procedures, any notice published on the FIAU’s website is removed following the lapse of five years from its date of publication. Where an appeal was filed, the five years are considered to start running from the date on which the Appeal Decision Notice is published. Due to the said time limit and the differing publication requirements that may have been applicable at the time, the notices on the website do not necessarily represent all the administrative penalties and/or administrative measures taken by the FIAU over the years.
2016

Read More
Act III of 2015 provided for the publication of administrative penalties imposed by the FIAU. Over the years the relevant provisions within the Prevention of Money Laundering Act governing publication have undergone numerous amendments, with publication being subject to different thresholds and conditions over the years. As of 7 February 2020, the FIAU is to publish any administrative penalty and/or measure it imposes, including any appeal therefrom, independently of the amount involved.
In line with the FIAU’s Publication Policies and Procedures, any notice published on the FIAU’s website is removed following the lapse of five years from its date of publication. Where an appeal was filed, the five years are considered to start running from the date on which the Appeal Decision Notice is published. Due to the said time limit and the differing publication requirements that may have been applicable at the time, the notices on the website do not necessarily represent all the administrative penalties and/or administrative measures taken by the FIAU over the years.
2015

Read More
Act III of 2015 provided for the publication of administrative penalties imposed by the FIAU. Over the years the relevant provisions within the Prevention of Money Laundering Act governing publication have undergone numerous amendments, with publication being subject to different thresholds and conditions over the years. As of 7 February 2020, the FIAU is to publish any administrative penalty and/or measure it imposes, including any appeal therefrom, independently of the amount involved.
In line with the FIAU’s Publication Policies and Procedures, any notice published on the FIAU’s website is removed following the lapse of five years from its date of publication. Where an appeal was filed, the five years are considered to start running from the date on which the Appeal Decision Notice is published. Due to the said time limit and the differing publication requirements that may have been applicable at the time, the notices on the website do not necessarily represent all the administrative penalties and/or administrative measures taken by the FIAU over the years.