CISA Newsletter | Issue 4 2023

If you can't see this email click here.
Compliance Newsletter | Issue 4, 2023
The Compliance Institute Southern Africa brings you the community newsletter for compliance professionals. This newsletter provides you with compliance thought leadership, regulatory updates and keeps you up to date with CISA's latest news, training and events.
Informed. Proactive. Relevant.
That is the purpose of our newsletter. Welcome to the December 2023 edition!

The past year was breathtaking in more than one way. As Covid subsided in the rearview mirror, new crises and events unfolded. ‘Polycrisis’ was an often-used term, some even started to call it ‘permacrisis’.

The year was characterised by an increasing interdependence and confluence of risks, instability, volatility, war, the weaponizing of food and energy, the cost-of-living crisis, social unrest and widening inequality. In short, black swans are not as scarce as I once thought.

Read More
👉 Useful tips on how NOT to tip-off your client 👈
👉 Useful tips on how NOT to tip-off your client 👈
👉 Useful tips on how NOT to tip-off your client 👈

Tipping off is prohibited in most #AML regulations and can have serious consequences for the individual who commits this offense. ❌

𝐖𝐡𝐚𝐭 𝐢𝐬 𝐭𝐢𝐩𝐩𝐢𝐧𝐠-𝐨𝐟𝐟?

Tipping-off is when an employee notifies a customer that a Suspicious Transaction/Activity Report (STR/SAR) was filed with the relevant Financial Intelligence Unit (FIU) or that a customer is under a #moneylaundering (ML) investigation. 🔎

𝐓𝐢𝐩𝐬 𝐭𝐨 𝐚𝐯𝐨𝐢𝐝 𝐭𝐢𝐩𝐩𝐢𝐧𝐠-𝐨𝐟𝐟 𝐲𝐨𝐮𝐫 𝐜𝐥𝐢𝐞𝐧𝐭

What happens if a company needs more information on the nature of specific transactions as part of identifying suspicious transactions ❓

Read More
It's up to us to build the next generation of compliance professionals
It's up to us to build the next generation of compliance professionals
Mentorship goes far beyond mere knowledge-transfer, it's about making a profound impact inspiring the next wave of compliance professionals. It is a profound act of giving back, shaping careers and changing lives.
Your wisdom and experience is not just valuable, it is transformative. We need you to guide our mentees.

Click the link below to join us and to hear more from Marelize Gloy, Chair, Young Professionals Steering Committee.

Read More
Stay up to date with the latest news surrounding grey listing, financial crime, money laundering and terrorist financing
2023 ROUND-UP: A look back on FICA & AML changes
2023 ROUND-UP: A look back on FICA & AML changes
2023 has been a year of significant change within South Africa’s Anti-Money Laundering, Combating the Financing of Terrorism and Counter Proliferation Financing environment. From cash threshold increases for reporting, Schedule 1 Accountable Institution additions, to new Directives 6, 7 and 8 among others. It has been a year fully loaded with reform.
Read More
This issue of the AML Corner is proudly sponsored by DocFox
Pro-active Compliance
Pro-active Compliance

These updates overview new relevant National laws up to 27 November 2023.

Log-in to, peruse the list, and follow the hyperlinks to laws that interest you. Please note that you can keep up to date, in-between newsletters and by visiting latest updates. Members can also find the updates on the self-serve platform in the Library, under the Proactive compliance widget.
Read More
Generally Accepted Compliance Practice (GACP)
Generally Accepted Compliance Practice (GACP)
The revised GACP was released in November and will be effective on 2 January 2024.
Read More
Thokozani embarked on her journey at CI SA on the 1st of July 2013, and over the years has proven to be an invaluable asset.

Her career took flight in the dynamic world of events, training and later professionalism. She honed her skills in customer service, communication including the members, trainers and partners, ensuring effective coordination and successful execution of training events.

She has demonstrated leadership skills in overseeing co-workers, fostering a productive workplace culture, and aligning committee activities with overarching training and professionalism strategies.

She is eager to drive the Institute’s mission to maintain and promote best practice standards for the compliance profession by facilitating professional development and accreditation for the members.

Thokozani steps into a new role as Business Manager in 2024. We wish her all the best in this new role. 
When you are passionate about something, you invest yourself in that cause. When you are invested in something, you commit your time and talents to being part of the change - to make an impact and realise common goals.

Marianna’s love for compliance and making a difference to the profession is the reason she volunteered at CISA in 2019. When the opportunity arose towards the end of 2020, she joined the Institute as the Business Support Manager.

Marianna quotes “I am proud of what we have achieved as a team over the past 4 years. I am thankful to my family for their patience and sacrifices, as co-investors in this journey. We often joke about it between the team, but this is a reality for each team member’s family – the extended CISA family. Now I embrace a new purpose for YOU, our members.”

Marianna steps into the new role of Education Training and Professionalism (ETP) Manager in 2024. We wish her all the best in her new role. 
Explore opportunities to get involved with various initiatives. Let us know what your areas of interest are. 

Vodacom's Compliance Team has demonstrated exceptional innovation through their ground-breaking initiatives, particularly in the areas of Anti-Money Laundering, Anti-Bribery and Corruption, Economic Sanctions, and Trade Controls.

Vodacom Group’s vision is to build a future ready compliance function built on a technologically sound and innovative foundation by utilising; big data; RPA; data analytics; algorithms and scrap data.

Vodacom’s data analytics process seamlessly integrates manual data into the organisation’s advanced Governance, Risk, and Compliance (GRC) platform.

Inkanyezi means "A shining star, brightness, hope and light"

Chair of the Africa Chapter: The Global Coalition to Fight Financial Crime, Former Chair of the Egmont Group, Former Head of the FIU SA (FIC)

Xolisile Khanyile was the Head of the South African Financial Intelligence Centre (FIC) and Egmont Chair to August 2023. She has spent 28 years dedicated to fighting financial crime, 5 of which were as the head of the FIC in South Africa, supporting and guiding the efforts in combating money laundering, terrorist financing and assisting in the identification of proceeds of crime.
She was responsible for the establishment of the first Public-Private partnership in Africa known as the South African Anti-Money Laundering Integrated Task Force (SAMLIT) in 2019, which has to date garnered much success and is recognised internationally for its best practice. In 2022, she was awarded the prestigious “Financial Crime Fighter of the Year” award from the GCFFC.

The Global Coalition to Fight Financial Crime announced the establishment of the African Regional Chapter (sub-Saharan Africa), and its inaugural chair, Xolisile Khanyile on 31 August 2023.

Samantha spearheaded the enhancement of the Compliance function in the organisation and introduced the use of automation in the compliance processes through all 6 markets through Africa.

She is currently rolling out the introduction of data analytics and the use of robotics improved culture of compliance.
Samantha takes mentoring and coaching seriously. She is dedicated to ensuring that more young people come through the ranks. She is driven by a selfless need to build the profession and impart knowledge.
Efficient Wealth's vision is to grow into South Africa’s financial services advisory business of choice, representing qualified, experienced, and professional financial advisors devoted to the financial well-being of our clients.
The Culture Club initiative enhances this strategy by focusing on championing professionalism, a form of self-regulation that allows us to trust our advisors to do the right thing even when nobody is watching. This means that our advisors act with integrity which is core to Efficient Wealth’s culture and hence the name Culture Club.
A culture of compliance integrates compliant behavior into the everyday practices, policies, procedures, and ethos of Efficient Wealth. It involves more than just compliance; it means promoting a work environment that values integrity and ethical behavior: professionalism at all levels of the company.
By reframing the approach on how we deliver the requirements of regulations by being professional, our advisors have embraced compliance in their day-to-day operations. They now see the advantage of being professional at all times. This then enables them to embrace the essence of good governance and deliver a client-centric experience. Doing the right thing even when nobody is watching
Various initiatives that have been implemented by Compliance in Segments across FirstRand (Group Compliance (FCC), Retail and Commercial, RMB and Broader Africa):
  • The Leatherman project: Omnibus policies
  • The winning Formula: Compliance Essential
  • The Transformer: Fin Crime RBA risk assessment
  • The Influencers: The Market Conduct Newsletter
  • KISS(Keep it simple stupid(note to self): Compliance Programme Tracking tool
All the initiatives have achieved the above vision and objectives of the Compliance Programme. The initiatives have been designed to be proactive, agile, effective and support the digital strategy of the organisation.
The value of these initiatives are not once off, but rather permanent strategic tools that form part of the FirstRand Compliance Programme and provide constant and consistent value for our people and the organisation.
The initiatives have all played a part is embedding the ONECompliance philosophy that was started in 2022. The analogy of the tree that shows singularity and togetherness was taken to the next level in 2023, with a physical tree being created to symbolize how far we have come through the initiatives that have been implemented. The tree compliments the branded t-shirts we introduced last year.

ONE Home, ONE Voice, ONECompliance.
Various initiatives that have been implemented by Compliance in Segments across FNB Retail and Commercial and FNB in our Broader Africa segment:
  • Treating Customers Fairly (TCF) practical training for CEOs
  • Automated Monitoring Tool
  • Compliance Risk Register
  • Risk Management Plan (RMP) Optimisation Tool
  • Market Conduct Key Risk Indicators
  • Bespoke Compliance Training for staff and agents
  • Automated Solution for Cash Threshold Reporting (CTR), Electronic Funds Transfer (EFT) and International Funds Transfer (IFT) GoAML reporting
  • Combined Assurance Initiatives
We strive to manage compliance risk on a pro-active, agile, and effective basis, supported by a digital strategy.

The initiatives have been designed to be pro-active, agile, effective and support the digital strategy of the organisation.
The value of these initiatives are not once off, but rather permanent strategic tools that form part of the FirstRand Compliance Programme and provide constant and consistent value for our people and the organisation.
The initiatives have all played a part is embedding the ONECompliance philosophy that was started on 2022.
The team in 2023 has made exceptional contributions to both industry and Investec’s compliance efforts. The team has consistently demonstrated a forward-thinking approach to compliance and has been instrumental in driving innovation and best practices across our industry. To this fact, in May 2023 the team launched what would become the inaugural SA Market Surveillance Conference.

The conference was sponsored by Bloomberg and Nasdaq with support from the Financial Sector Conduct Authority (FSCA). It took place at a critical time as the local financial sector is actively working on reforms and new legislation to modernise the regulatory framework that governs financial institutions and align with international standards to bolster market surveillance.

The team’s ability to anticipate and adapt to regulatory changes has been truly impressive. They have been proactive in identifying potential compliance risks and have encouraged dialogue relating to innovative solutions to address these risks. The team has also been instrumental in the drafting the SA Market Surveillance Code of Conduct. The first draft is to be discussed at the 2024 SA Market Surveillance Conference, the code of conduct procedures will be adopted by other organisations across the industry and have been worked on in collaboration with industry peers, the JSE Surveillance team, A2X, FSCA, South African Institute of Stockbrokers (SAIS) and South African Institute of Financial Markets (SAIFM) to name a few.

In addition to their technical expertise, the trailblazing team has also demonstrated a strong commitment to collaboration and thought leadership. They have worked closely with other teams across the organisation and industry to develop and potentially implement best practices and have been proactive in sharing their insights with colleagues throughout the industry.
The Luno Anti-Financial Crime team has been on the forefront of driving industry awareness, not only for internal stakeholders, but also for regulators, law enforcement and the banking industry. This awareness focussed on aspects like defining the regulatory environment for the crypto industry, driving awareness from a law enforcement perspective on aspects such as investigative techniques and tools and also sharing trends and typologies to the finance industry to improve the way in which we identify, mitigate and manage the risk associated with this industry.

This team has, during a time that it was not formally regulated, chosen to apply global regulatory frameworks / legislation within South Africa (and all other jurisdictions in which Luno operates) to ensure that we protect not only Luno and it's reputation, but also our customers and to promote consumer protection.
In addition, this approach has enabled Luno to play a material role in supporting regulators, law enforcement and the banking industry in obtaining an understanding of the crypto industry, enabling risk identification and mitigation and to play a role in influencing the regulatory framework that the country is in the process of developing - to essentially learn from other countries and develop a framework that works for us.
The above mentioned initiatives all contribute to the development of a regulatory framework that did not exist 12 months ago and would contribute to the remediation of findings raised by FATF as part of our Mutual Evaluation.
As compliance officers who are passionate about education as well as ensuring that individuals from all walks of life are equipped with skills sets that will not only ensure that they are employable, but also that they are able to keep up with the changing demands of the job market, the challenge meant that we could work with an organization that also shares the same sentiments as we do and ensure that we contribute to shaping compliance officers of the future.

On the 27th of October the Compliance With A Purpose team hosted a career day for the grade 9 learners at Rays of Hope. The event took place at the Nedbank Offices at 135 Rivonia Campus. The day has an exciting programme filled with speakers from not only compliance but also other areers in medicine, media, engineers, robotics, policing and air force. The main aim of the event was to expose the leaners to the endless possibilities and opportunities that they will have the day they leave school have matric. As a team we wanted the leaners to hear stories from successful people who didn’t have it easy growing up but who made it and are now successful in their respective fields.
Nedbank launched several initiatives over the past three years in alignment with its strategic drive to use technology to improve the efficiency of the Compliance function and assist business to manage compliance requirements more proactively. 

The outcomes of these initiatives, among other, include the business being enabled to effectively and ongoing monitor their activities thereby ensuring their proactive management of compliance risk. Furthermore, said automation has resulted in greater efficiencies, for example it allows for total populations to be tested as opposed to mere samples.
The value of automated monitoring is clear from the increased number of requests received from business, for recent historical data on e.g AML outcomes to ensure previously identified shortcomings have been addressed, which is now produced with great ease. 
A further result of the increased automation is the optimal utilisation of compliance and business resources who can now focus on areas that specifically require human input. Automation has resulted in improved trend analysis and dashboard reporting not to mention reduced travel and printing which has had a very positive effect on Nedbank’s carbon footprint!

A further key initiative is to use available management information more effectively. Compliance developed an in-house tool referred to as the One Compliance Portal, which offers a variety of functionalities all aimed at improving efficiencies in Compliance Officer administration.

These initiatives complement the Compliance function’s strategy which fits into the broader Nedbank strategy of “leading in digital” and “leading in client experience”, to continue its drive to efficiency and freeing up skilled resources to focus their efforts on compliance advice, as opposed to spending time on repetitive tasks. It enables business to self-detect non-compliance on an ongoing basis and take immediate corrective action as and when issues are identified.
Very knowledgeable, hardworking , one of very few people who have the all-round practical experience (you can’t cheat time), to question a lot of what proposed to be implemented by the Regulator, where as it was not feasible to implement by the FPSs eg, the fundamental differences a CAT I and CAT 4 service provider and had to argue on our behalf with the Regulator and the Insurers and actually show that they are the same and so it was not necessary to apply for a CAT IV. In this regard his experience and knowledge of this industry was clearly shown.
  • Roger has been in the Assistance Business Standing Committee (ABSC) since 1988 and has been instrumental in developing the sliding scale of benefits in the industry.
  • He is also on the Gauteng Chapter of the Forum for Assistance Business (FAB) that deals directly with the FSB.
  • External Compliance Officer to 124 Financial Services Providers covering the Long-term Insurance Act, the Short-term Insurance Act, the Medical Schemes Act, the Financial Advisory and Intermediary Services Act (FAIS) and the Financial Intelligence Centre Act (FICA).
Maria is an Advocate of the High Court of South Africa and a Certified Director. Maria has keen interest in corporate governance, ethics, and risk. 
Maria has been involved in the drafting and review of the compliance risk management processes and manuals for the current and previous employers and had added much needed efficiencies to the organisation.

She advocates for the empowerment of persons from previously disadvantage communities and is currently providing mentorship to those who are interested in compliance as a career. She is passionate about growing young ladies and gentlemen into the compliance fraternity and has recently launched a CSI initiative where the RBB Compliance team partnered with an NGO to market compliance as a career of choice to students who from Grade 9 -12.

She is a public Servant at heart and believes that this country needs more deliberate, ethical, intentional, qualified, and experienced individual to move this country in the right direction.
Ms. Kaunda was the first ever person to be appointed in her current position and she had to start from scratch to bring up a compliance function that has become recognized and appreciated in the Bank.

Compliance by itself has challenges such as the constant changing of laws, updated policies/regulations, revised contracts, unclear laws and misinterpretations and not forgetting the ever-changing operating environment. Ms. Kaunda has sailed through these challenges and overcome some due to legal understanding as she is qualified legal practitioner (advocate of the High Court of the Zambia).
She is also a certified ISO 37301 and ISO 31000 which has given her an edge in her discharge of work and establishment of a Compliance Function in the Bank of Zambia.
Her recognition as a three-time All Star winner for the First National Bank Retail Recognition awards Programme and awarded the Retail and Commercial Compliance Risk Professional of the year 2022 attests to the consistently exceptional caliber of her contributions. 
Avitha’s impact in the financial industry reverberates through her involvement in critical compliance aspects, including but not limited to risk mitigation, regulatory compliance, and robust policy frameworks.
Beyond her technical proficiency,
 Avitha’s strategic insights and collaborative approach underscores her role as a driving force in ensuring First National Banks’s adherence to the highest compliance standards, making her a true leader in the field.
Rethabile is an LLB graduate, UCT Compliance Management Certificate holder and member of CISA.
She is currently undertaking an initiative that seeks to automate compliance systems within the organisation. Rethabile is committed to giving back to the compliance fraternity by mentoring those coming up the compliance ranks. 
Themba has consistently demonstrated an exceptional level of dedication and expertise in ensuring Investec Limited's compliance with markets surveillance regulatory requirements and has had a significant impact on the industry.

Themba was instrumental in launching the the inaugural SA Market Surveillance Conference which took place in May 2023. The conference has enabled a collaborative effort between industry players and opened up a dialogue regarding various challenges and opportunities the financial services industry faces and for all industry players to collaborate to ensure that the South African financial services market remains an attractive alternative market globally. 

Themba’s effort became instrumental in developing a first ever SA Market Surveillance Code of Conduct, the first draft to be discussed at the 2024 SA Market Surveillance Conference.

Themba is proactive and a forward thinker in finding innovative solutions through the risk-based approach and usage of data analytics to address potential compliance risks in market surveillance activities.
His experience is on prudential, exchange control, payment system, and financial crime risks. Within the payment system environment, Stephen was part of the team that started the concept of regional payment system for the South African Development Community.
Cash threshold reporting in terms of the Financial Intelligence Centre was operationalized under his management. With the Prudential Authority, he established the Financial Intelligence Centre Act supervisory programme and further represented the supervisor at Financial Action Task Force, Basel Committee on Banking Supervision and Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG). He was also leading the Financial Stability Board initiative of addressing de-risking of correspondent banking relationship within developing countries, especially the Southern Africa region.

 As Head: Group Financial Crime Compliance Officer within FirstRand Limited, he has established a Centre of Excellence (COE) inclusive of banking, insurance and invest business of the group across all jurisdictions where the Group operates. He also chairs the Financial Crime Compliance Committee responsible for the oversight of the programme. In addition, he is a member of the SAMLIT Steering Committee and AML/CFT STEERCO with the regulators.
Tebogo diligently established and maintains a cohesive monitoring and reporting interface that extends throughout the business, thereby enabling a robust information and assurance framework for the functional area. His meticulous review of the integrity of functional compliance information stands as a testament to his commitment to upholding the highest standards.

Tebogo remains vigilant in monitoring the ever-evolving legislative, regulatory, and policy landscape, ensuring that Eskom Generation remains agile and adaptable in the face of potential compliance challenges.

Tebogo has played a vital role in the development of clear guidelines for achieving compliance through the creation of specific functional processes, policies, and procedures.
Viola Pamela Ndlovu is a Governance and Compliance Executive who values dedication, service, and excellence. She holds the position of Co-Chairperson of the Beneficial Ownership Sub-Committee for the National Task Force on Anti-Money Laundering (NTF).

Viola is an accomplished leader with a number of accolades: 2022 Award recipient of the Zimbabwe CEO's Network Outstanding Women of Elegance, Style and Repute; recipient of the National Task-Force on AML commendation for the diligence and professionalism shown in leading the Banker’s Association of Zimbabwe (BAZ) Compliance Committee in public-private sector collaboration for 2 years and during the FATF onsite visit to Zimbabwe to assess the country's progress in addressing deficiencies in AML in January 2022 resulting in the removal of Zimbabwe from the FATF grey list in March 2022, among many others.
She has been a mentor to many young professionals, mentoring with passion, and guiding her mentees to effectively strengthen and elevate their leadership vision to new heights.
Charmaine serves as the Chief Executive Officer (CEO) of The Compliance Toolbox.

The Kotive System (Cloud-based Compliance Management Software System) was identified as a unique business (irrespective of size and or complexity) enabler for the purposes of managing tasks and activities associated with regulatory matters. Charmaine is the living blueprint for the architecture the system provides today. Furthermore, Charmaine has leaned heavily on CISA’s GACP as well as the principles of King IV to inform the development of the system features.

Charmaine is a solutions-orientated individual, always keeping the client at the core of the work being and the ongoing development of Kotive. Charmaine’s leadership remains pivotal in CTB’s success. 
In 2018, Mr. Van Zyl embarked on an entrepreneurial journey by establishing Outsourced Compliance Services. Under his leadership, the company has flourished, establishing branches in Cape Town and Johannesburg, and providing a wide array of compliance services to a diverse range of clients both domestically and internationally.
In addition to his role at Outsourced Compliance Services, Mr. Van Zyl co-founded KYCDD, a cloud-based platform revolutionizing client onboarding processes. 
Isaac Zhou is an award-winning vigilant security risk, fraud investigator and intelligenceprofessional with vast unquestionable knowledge, experience and expertise in managing security risks, intelligence operations, compliance operations and emergencies. He is currently the Co- Founder and Board Chairman for the Global Institute of Security Management,
Administration Director and Pastor for MountainTop Apostolic Ministries, and also Teamlead- Zimbabwe for International Security Organization. He is currently employed full-time by Probrands as the Head of Risk, Security and Loss Control.

Isaac worked in different organizations including the Zimbabwe Republic Police’s special branch - the Police Intelligence Directorate, Manicaland State University of Applied Sciences and Telecel Zimbabwe.

Isaac spearheaded the re-establishment of the Risk Committee for the company through thought leadership approaches. He also established Risk and Compliance Culture enhancement systems at Probrands, including the risk awareness campaigns, risk meetings, safety workshops, risk reporting methods for employees, and risk inclusion culture on the board.


Powered by Glue Up
All-in-one CRM Software for Growing Communities