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NEWSLETTER

IN THIS ISSUE

Foreword by C.E.O.

Tax Amnesty extended

Consumer Price Index - how

does it work?

FIA Regulations and Accounta-

ble institutions

VAT and Import VAT payments:

New bank account at Revenue

House and vehicle payments

Namibia's economic future

Procurements setup in Mauritius

FCS Director profile: Karl-Heinz

Schulte

CEO of the year award

New CEO for FCS

Expansion of FCS office build-

ings

New Payroll system

MDP—High Impact Manage-

ment development programme

FCS Questionnaires: summary of

the FIA regulations

Adding value……...

Tax Consultants Accountants Advisory Services Company Secretaries

Assurance Forensic Services Agreed Upon Procedures

Disclaimer: PKF-FCS Auditors is a member firm of the PKF International Limited family of legally independent firms and does not accept any responsibility or liability for the actions or inactions of any individual member or correspondent firm or firms.

Volume 6, Issue 2—OCTOBER 2017

. . .

. .

It is probably old news that Anja and I have sold our shares in FCS and will be leaving the firm at the end of April 2018 to take some time off, in order to regenerate our physical (and mental) health. We will relocate to Germany and have planned to do absolutely nothing, maybe travel a bit, do some gardening, get fit – whatever.

We are not sure how long we will take, or what we are going to do once our batteries are recharged, but we will always be available to assist our valued clients in FCS and render support whenever needed. Reflecting back on the past 24 years, from the small little office I started in Swakopmund in 1994 to today’s professional organization with 160 people, FCS and PKF-FCS Auditors have come a long way in a relatively short period of time. By now we are the second largest accounting and audit group in the country, a success unsurpassed by any of our competitors. All of this would never have been possible without the most fantastic clients, partners, managers and staff we have and have had. It has not always been plain sailing, we have been growing at a rapid rate and, like everybody else, had our up’s and down’s in the process. Not that we have always been able to provide the superior service we wanted to provide, but I think we have managed well under circumstances, despite the dramatic shortage of qualified accountants in Namibia. So time goes by and takes its toll, the pressures and deadlines are unrelenting and omnipresent – fresh blood is needed to rejuvenate the business; it’s out with the old and in with the new, time to make way for the up and coming generation. The time at FCS has been greatly rewarding for us, the University of Life has taught us many lessons but best of all were all the many friends we were able to make. The crowning moment at the end of my career was winning the CEO award for our industry in the SADC South region. Now it’s time to start the goodbyes from all we will so dearly remember. All the best wishes to Reiner, who will take over as the CEO of FCS after our departure, my partners who always stood by my side no matter what, and all our staff that’s been grafting so hard – thanks to our entire FCS family. To our clients, Anja and I wish that the economy makes a speedy recovery, that you will make lots of money and pay not too much tax, thank you all for your support and loyalty over all the years. If we don’t see you before our departure, all the best, be good and come visit us if you are in the vicinity.

Frank Moormann, C.E.O.

"Change is the law of

life and those who only

look to the past or

present are certain to

miss the future." - JFK

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By now most of you are aware that the Ministry of Finance has started with a new Tax Amnesty Run.

The new period for Amnesty has been extended from September 2017 to March 2018.

What has changed, is that Revenue has decreased the amount of interest that will be written off from 80% to 70%.

All penalties will however still be written off, provided that all returns have been submitted and assessed.

This is where the first amnesty run failed for most tax payers that want-ed to make use of this opportunity.

Most returns where not assessed in time to apply for amnesty.

We therefore urge tax payers to con-tact the Receiver of Revenue to first-ly find out if there are any outstand-ing returns and/or payments accord-ing to Revenue. This could be a cum-bersome process, but it is necessary to make use of the scheme.

If you wish for FCS to do a complete file check on your behalf, please let us know, and we will gladly assist you in this matter. As previously men-tioned these file checks will mean several trips to Revenue to obtain print-outs of your entire tax history and work through same. We will then let you know if there are any discrepancies or returns, which ac-cording to Revenue show outstand-ing.

Then these returns must be updated at Revenue, and only after the up-dates on Revenue's system you would be able to apply for amnesty.

Many clients are unaware of the regulations as contained in the Financial Intelligence Act of 2012, as amended in 2015. The act puts the responsibility of reporting suspi-cious transaction and guidelines to prevent money laundering on each party involved in the transaction. Many business owners are unaware of this, and therefore should famil-iarize themselves with the regulations.

For instance, if a cash payment is received form a client as payment for services of sale of goods over a certain amount, as prescribed by the Financial Intelligence Centre, there is a clear obligation on the person receiving these funds to make sure about the origin of these funds as well as an obligation to report such a transaction, if it is deemed to be suspicious.

It is for this reason, that our Secretarial departments request "Know Your Client (KYC)" Questionnaires from new and existing clients according to the requirements in the Regulations. These questionnaires are normally sent to the client via Email. For reference, we have attached a summary of the minimum requirements on the last two pages of this Newsletter. We kindly request that you assist our Secretarial departments by completing and returning the Questionnaires as soon as possible to FCS. Should you have any questions in this regard, please contact your FCS partner.

Tax Amnesty extended

If there is something to gain and nothing to lose by asking, by all means ask. - W. Clement Stone

FIA Regulations and Accountable institutions

Consumer Price Index – how does it work?

A lot of clients contact us on an annual basis to find out how much the “general” increases should be. Many times, we have found the clients have heard about inflation and the CPI (Consumer Price Index), but are unaware of how to use this tool in their business.

In layman's terms, inflation is the tracking of the cost of living in Namibia over a period, as calculated by the Namibia Statistics Agency. It takes into consideration the spending patterns in Namibia over a period of five years, based on Baskets. A basket contains the goods and services spent over time, containing over 350 items, which are again grouped into 12 categories and 55 subcategories. This information is collected and summarized monthly from over 900 retailers in Namibia.

The three largest baskets are:

1. Housing Cost (including rent, bond, water and electricity etc);

2. Food and Non-alcoholic beverages and

3. Transportation.

These three make up almost 60% of the disposable income of the average person in Namibia. Alcoholic Beverages and Tobacco, Furnishings, Household Equipment, Miscellaneous Goods and Services, and Communication make up just over 27%.

Incidentally, Education and Health together make up about 6% of the baskets of disposable income of Namibians. This figure might be distorted, as in Namibia Education and Health for the majority of the population is subsidised by the State. Many people have opted to go on private medical aid and are spending a bigger amount on their children’s education through private schools.

According to the Namibia Statistics Agency, the inflation rate in June 2015 was 3.0%, which increased to 6.7% in June 2016. In the current year, June 2017, it was around 6.2% and the forecasted inflation for the rest of the year should be around 6%.

According to the forecasts, the inflation rate in Namibia should increase to about 8% over the next year or two.

This should only be an indication, as we are currently in economic recession, as explained in another section of the newsletter.

VAT and Import VAT payments: New bank Account at

Revenue

The Ministry of Finance has opened a new bank account in order to keep VAT pay-ments separate from Income tax payments. Keep an eye out in the press, as this will be published soon.

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House and Vehicle payments

AS AN EXAMPLE:

• If you have a mortgage bond of say N$ 3 million, at the current prime lending (currently 10.50%) rate over a period of 20 years.

• This means your monthly payment is N$ 29,951.

• If we can assume the interest rate will not change, your total payments over 20 years will be N$ 7,188,335.

• Thus a total of N$ 4,188,335 interest repayment.

• If you could increase your bond pay-ment from the beginning to say N$ 33,000 per month, your total repayments will be N$ 5,819,035 (N$ 2,819,035 interest) and the re-payment period drops to just over 18 years.

• If however you would increase your monthly repayment by say 8% per annum, as would have been the case when you rent a fixed property, your total repayment drops to N$ 4,914.774, or just N$ 1,914,774 in interest charges.

• Also, you would have repaid your house in 12.5 years and an interest saving of about N$ 2.2 million.

This will also create the opportunity to have additional funds in your mortgage bond to provide for an emergency or un-planned event like the loss of your employ-ment or cash needed for an improvement on your fixed property.

For most clients in Namibia, your private residence, will be one of your

biggest investments in life.

Incidentally, also the biggest liability in life. It is a big decision to buy your

first property, whether it be your house or an investment property. The

mortgage bond will inevitably be a sizable chunk out of the disposable

income from any person. The common pitfalls many people fall into when

buying a fixed property, are the hidden cost, that are not taken into

consideration.

• Firstly, one should budget properly before the decision. Remember, if

you can service the monthly bond payment for 10 out of the 12

months in a year, this will inevitably create a cash flow problem soon.

• Costs such as insurance, rates and taxes and maintenance should be

budgeted for.

• Also a change in interest rates will affect the bond payment. Luckily,

in Namibia, our interest rates have been very stable over the past 10

years.

• A tip is to treat your bond payment like a normal rental. Making sure

to increase the payment annually, usually with your salary increase, to

provide funds for the “unforeseen” like maintenance and/or increases

in interest rates. If the interest rate decreases, always try to maintain

the monthly stop order. See the example on this page.

This should also apply when purchasing a new vehicle.

• For a business owner, the decision should be never to finance over

longer than 3 years. The reason is simple, as you will only be able to

deduct the purchase price over a period of 3 years. Thus the tax

saving would assist with cash outflows of the purchase of the vehicle.

• For a private person you should try not to exceed 4 years. The idea is

to continue with your monthly repayments, even after the loan was

repaid (either into your home loan or a savings account). If it comes

to replace the vehicle say after 4.5 years, you should have a substantial

amount to add to the trade in of the vehicle. This will ensure that the

new monthly repayment should not be higher than what you are

“used to” and you should most probably be able to replace the vehicle

with the same model or even higher, since your deposit is so much

bigger.

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A lot was written of the economy over the past year or so.

The biggest news was the downgrade of Namibia to junk

status by the credit rating agencies. Even though our

Ministry of Finance and President have disputed this

publically, the ratings are published, and this is how the rest

of the world sees Namibia. Also, our economic growth has

slowed down considerably to 1% in 2016. This was however

a worldwide phenomenon.

In 2017 it is expected that our economy should grow at

around 2.9%. The main contributors to this upwards curve

are the mining industry and agricultural industry. It is

expected that this trend should continue, but one must

always remember that these are exchange rate driven

industries. As long as the Namibian dollar is weak against the foreign currencies, the export driven industry should do better.

Since the Namibian dollar is linked to the South African Rand, we must accept that what happens in South Africa will affect

us directly. All eyes are now on the ANC and the possible leadership change in December. This will affect the Rand, in which

direction though, is not clear yet.

Namibia's Economic Future

With the Namibian Economy slowing down and also the volatility of the Namibian Dollar (South African Rand), many

people have looked to offshore investments and offshore business opportunities to protect the wealth that they have managed

to accumulate by transferring their wealth to USD or EURO.

This has been the driving factor why we have re-activated our business setup in Mauritius in the form of a company registered

with a Gobal Business License (GBL1 company). Mauritian Economy has been grown considerably since the 1970's. Starting

off as an agricultural economy, with sugar being the main export crop, Mauritius has transformed its economy to be more

innovation driven and focusing on technology and the service industry. Mauritius has also developed a Freeport and with it

has become a focus point of all shipping, especially with the Asian and Oceanian markets.

As such, many Mauritian Service companies have built up many business relationships in these markets, which provides a

perfect platform for procurement business. Furthermore, the

development of the Cyber City in Ebene, just south of Port Louis, in

2001 has also promoted the information technology on Mauritius

and it now serves as a link between the African and Asian/Oceanian

markets. Thus, it has also created the another platform from which

to launch your international market via the web.

For more details about these business opportunities, kindly contact

Karl-Heinz Schulte in our Swakopmund office at 064 – 415 100 or

khs@fcsnam.com.

Procurements setup in Mauritius

FCS HAS CREDIT CARD FACILITIES

We are happy to announce that we have installed credit card swiping facilities at all our branches in order to assist

clients. Many client do not have EFT facilities and with cheques phasing out by the end of the year, this was the

logical step forward.

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Karl-Heinz Schulte has been living in Swakopmund for more than 37 years. He attended the German

Primary school and matriculated at the Namib High School. Already from a young age, sports (especially

ball sports) have been at the centre of his extramural activities.

On 1st of February 1998, Karl-Heinz started working at FCS as part of a 5-man team in the offices situat-

ed at 49 Kaiser Wilhelm Street. He enrolled for the FCS internship and started his long distance studies

towards a Degree in Accounting Science at the University of South Africa.

In 2006 he completed his Degree and also his internship to become a Practising Member of the Namibia

Institute of Public Accountants. During the same year, he also became a Partner of FCS. After having

met the love of his life, he decided to stay at the Swakopmund Branch where he is now the Executive

Director.

Karl-Heinz is intrigued by the workings of the various tax systems and tax laws. He is also involved in developing and present-

ing the FCS training courses, which are available to FCS staff and the public at large. By offering these training courses, he

hopes to increase the accounting and tax knowledge throughout Namibia. He is also spearheading the Mauritian Procurement

and Marketing Project.

New CEO for FCS

After 23 years, Frank Moormann has decided to vacate the CEO position of FCS. Frank has indicated

that he would like to take a gap year to get a well-deserved rest and recharge. His wife, Anja

Moormann, will accompany him for the year. As of March 2018, Reiner Piepmeyer, from our

Swakopmund branch will take over the CEO position. In order to facilitate a smooth transition,

Reiner will already start to move into the position during the remainder of this year. Reiner has

indicated that this would be an exciting chapter in FCS, and he is very positive about the new

challenges that await him in growing FCS, and is looking forward to this and applying our policy of

“adding value” to the firm itself. On behalf of FCS, we wish both Frank and Anja the very best for

the next chapter.

If you are brave enough to say goodbye life will reward you with a new hello. - Paulo Coehlo

It is with great pleasure that we announce that our current CEO, Mr Frank Moormann, has won

the CEO Global recognition award for the category “Business and Financial Services” for the

entire SADC South Region. This prestigious award was handed over to Mr Moormann in

August 2017 in Johannesburg. Since founding FCS in 1994 from a one-man show, Mr

Moormann has grown the firm into an accounting firm of note with 13 partners and more than

160 staff. A momentous achievement, taking into consideration that this has taken him only 23

years.

We, FCS, are extremely proud of our founder and CEO for achieving this prestigious accolade.

This also automatically put him in the running for the African Continental Award in

November 2017. We keep our fingers crossed.

Director profile: Karl-Heinz Schulte — Executive Director, Swakopmund Branch

CEO of the year award

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As mentioned in our last newsletter,

our staff component has increased

substantially over the past year, main-

ly because of the merger between

FCS and PKF.

This resulted in the need to increase

our premises to house the influx of

new staff members. During the

2016/17 years, we have extended our

buildings in both our Windhoek and

Walvis Bay branches.

See some photos of the Windhoek

and Walvis Bay offices.

Expansion of FCS

office buildings

FCS Windhoek

FCS Walvis Bay

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FCS together with Syntaxes Software Development CC have over the past few years created our very own electronic payroll system. We are happy to announce that this is now available for purchase by the public. If you are interested, please contact your FCS partner.

New Payroll system

Some of the features included in this payroll program are as follows:

• On initial setup different users can be setup, each with its own specific access rights

• Multiple Branch and cost centres setup available

• For the multiple branch function a ‘bulk capture function’ is available for easy leave import by Head-office, or leave export from branch to Head office

• A user friendly ‘Input Wizard’ is available for adding new employees, editing existing employees and updat-ing the ‘Company Global Settings’

• Employees can be setup to calculate pay per day or per hour

• The payment frequency can be set on monthly, Bi-weekly & weekly increments

• Budgets can be setup for employee per grade

• Overtime has already been setup as per the Labour Law, but can be adjusted to company specific require-ments

• Annual and Sick leave are also already setup as per Labour Law requirements, but adjustments can be done to the setup, such as: extra leave days for employees who have worked a certain amount of months/years

• Other leave types already on the system that can be used, include: maternity -, paternity -, compassionate -, study – and unpaid leave.

• The program also have a function for staff loans, which is easily updated with new types of staff loans

• PAYE tax tables are already setup at current tax rates, but tax rates can be updated if needed, and the PAYE tax input sheet even have a calculator included, to test the new formula

• Quick and easy printing of PAYE5 certificates available

• Included in the PAYE certificate setups is a complete list of all current allowable benefits and remuneration for individuals

• A comprehensive list of reports is already included in the setup, all of which can be exported, emailed, saved to a specific folder on your server, etc.

SOME OF THE REPORTS INCLUDED ARE:

a template for ‘offer of employment’, but should your company already have an existing template, the program can

easily access this from your server as well;

Various leave reports and leave graphs are available;

Submission reports for (but not limited to) Pension fund, Social Security Commission, VET, Workman’s compensation,

medical aid, are also available;

Affirmative action summary report for inclusion in the yearly AA Report;

as well as the normal annual reports

PAPAS

Elios Payroll

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MDP—High Impact Management development programme

“This 5 day programme is a training invention that will equip the attendees not

only with a list of actions all leaders and managers should take and which

mistakes to avoid, but also how to build and lead teams to great performance.

The programme will cover all aspects related to leadership and management

requirements in today’s business world, including managing change, continuous

improvement, strategic planning, implementation and monitoring,

communicating powerfully and effectively motivating and inspiring a team

through emotionally intelligent behavioral management of people. It will provide

them with the knowledge and know-how to ensure sustainable successful

leadership and management into the future and help them to be smart with

people.”

In order to assist employers with the soft skill training of

managers and aspiring managers we will be presenting a

High Impact MDP programme continuously for the next

three years. Participation can be for the full 5 days or

only certain modules. Course content will not change for

the next 3 years therefore allowing attendees to spread

their attendance over three years instead of all modules in

year one.

Windhoek Venue address:

FCS Conference centre, 3 Kerby Street, Windhoek

Windhoek registration deadline: 20 October 2017

Dates:

30 October 2017 - 3 November 2017

Start time:

08h30

End time:

16h30

The High Impact MDP will cover 3 Modules

presented over 5 days as follows:

• Module 1 and 2 (2 days) - Develop your

Leadership and Emotional Intelligence

• Module 3 and 4 (2 days) - Effective

Communication, Presentation and negotiation

skills and Change and Continuous Improvement

• Module 5 (1 Day) - Delegation skills

Costs: N$ 3 490 (Excl VAT) per delegate for 2 day

Module; N$ 1 999 (Excl VAT) per delegate for 1 day

module

Aimed At: Middle Management Level Employees;

Supervisors; Team Leaders; Employees Who Have Been

Earmarked for Succession Into Management.

Registration: Space will be limited. Please register your

delegates on the MDP registration form and return to

admin@cultustraining.com before the due date.

Through our associated business, Cultus Training Academy CC, we offer a variety of short courses to the

public, dealing with a range of topics from Income Tax / VAT, the Labour Act, Company Law to soft-

skills training – a total of over 30 different courses. FCS clients and their staff qualify for reduced rates.

Please watch out for next year's training programme, starting in March 2018. See our website

www.fcsnam.com for more details or request an electronic copy of the programme at

admin@cultustraining.com

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Regulation 6

(a) full name;

(b) previous name, if any;

(c) nationality

(d) If citizen or resident of Namibia, listed below in order of preference:

(i) Namibian ID

(ii) Valid Namibian passport number or

(iii) date of birth, in case of minor; or

(e) if the person is not a citizen or resident of Namibia, one of the following, listed in the order of preference:

(i) passport number;

(ii) national identity number; or

(iii) date of birth, in case of a minor.

Regulation 12

Where an accountable or reporting institution seeks to ascertain the client and risk profile of a natural person, such accountable or reporting institution must take reasonable steps to obtain the following in relation to such person, either before the establishment of the business relationship or conclusion of single transaction above the determined amount or during the course of the business relationship or conclusion of single transaction, depending on the potential risk posed by the person:

(a) Namibian Residential address, for Namibian citizens or residents; domicile and non-Namibians residential address in foreign country and physical address in Namibia;

(b) contact particulars;

(c) Occupation or source of income, as well as any additional source of income which is not the principal source of income;

(d) nature and purpose of business relationship.;

(e) nature and location of business activities, if any; and

(f) the source of the funds involved in the transaction.

A. NATURAL PERSONS: Ascertainment of information concerning natural persons (Regulations 6 and 12)

FCS QUESTIONNAIRES - (see our article on page 2, "FIA Regulations and Accountable institutions" ) *(See Regulations 6-11, 12 and 13 of the Financial Intelligence Act 2012)

B. COMPANIES & CLOSE CORPORATIONS: Ascertainment of information concerning Companies and Close Corporations (Regulation 7)

Regulation 7

(1) For purposes of this regulation "ownership and control structure" means the principal owners of a Namibian or foreign company or Close Corporations as well as -

(a) the executive manager and chief executive officer of the company or, in the case of a close corporation, the executive manager and each member;

(b) each natural person who purports to be authorised to establish a business relationship or to enter into a transaction with the accountable or reporting institution on behalf of the company or close corporation; and

(c) each beneficial owner of such company or close corporation;

(2) Where an accountable or reporting institution seeks to ascertain the identity of a Namibian or foreign company or close corporation wishing to enter into a business relationship or a single transaction above the determined threshold amount with an accountable or reporting institution, it must ascertain -

(a) its registered name;

(b) the name under which it conducts business in the country in which it is incorporated;

(c) if the company or close corporation is incorporated outside Namibia and conducts business in Namibia using a name other than the name specified under paragraph (a) or (b), the name used in Namibia;

(d) its registration number;

(e) the registered address from which it operates in the country where it is incorporated or if it operates from multiple addresses in that country the address of its principal place of business or registered office;

(f) if the company or close corporation operates within Namibia, the address from which it operates in Namibia or if it operates from multiple addresses within Namibia, the address of the office seeking to establish a business relationship or seeking to enter into a single transaction above the determined threshold amount with the accountable or reporting institution concerned; and

(g) ownership and control structure.

(3) Where an accountable or reporting institution seeks to ascertain the beneficial ownership information of a Namibian or foreign company or close corporation wishing to enter into a business relationship or a single transaction above the determined threshold amount with an accountable or reporting institution, it must ascertain identification information referred to in regulation (6)(1)(a) and (c) or (d) of each beneficial owner or person acting or purporting to act on behalf of such beneficial owner.

(4) An accountable or reporting institution referred to in subregulation (3) must ascertain –

(a) in the instance of –

(i) an associations and other entities, the particulars referred to in regulation 8(a), (b), (c) and (e);

(ii) a partnership, the particulars referred to in regulation 9; or

(iii) a trust, the particulars referred to in regulation 10 (1) (a) to (e) and (g),

Holding beneficial ownership or acting or purporting to act on behalf of a beneficial owner.

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Regulation 8 An accountable or reporting institution must ascertain in respect of an entity such as an association, a government department, a representative office of a government, a non-governmental organisation, an international organisation, an intergovernmental organisation as well as a legal person other than a Namibian or foreign company or close corporation – (a) the registered name of the entity, from which it operates; (b) the office or place of business, if any, from which it operates; (c) the registration number, if any; (d) its principal activities; (e) the full name and one of the following, listed in the order of preference:

(i) the national identity number; (ii) the national social security number; (iii) the passport number; or (iv) date of birth, Of the natural person purporting to be authorised to establish a business relationship or to enter into a single transaction above the determined threshold amount with the accountable or reporting institution on behalf of the entity and of each beneficial owner; and

(f) the authority of each natural person purporting to be authorised to establish a business relationship or to enter into a single transaction above the determined threshold amount with the accountable or reporting institution on behalf of the entity.

C. ASSOCIATIONS AND OTHER ENTITIES: Ascertainment of information concerning associations and other entities (Regulation 8)

D. PARTNERSHIPS: Ascertainment of information concerning partnerships (Regulation 9)

Regulation 9 An accountable or reporting institution must ascertain in respect of a partnership – (a) its name or where applicable its registered name; (b) its office or place of business, if any, or where applicable, its registered address; (c) where applicable, its registration number; and (d) the full name and one of the following, listed in the order of preference:

(i) the national identity number; (ii) the passport number; or (iii) date of birth; Of each partner, including silent partners and partners en commandite, beneficial owner and any other natural person who purports to be authorised to establish a business relationship or to enter into a single transaction above the determined threshold amount with the accountable or reporting institution on behalf of the partnership; and

(e) the authority of each natural person purporting to be authorised to establish a business relationship or to enter into a single transaction above the determined threshold amount with the accountable or reporting institution on behalf of the partnership.

E. TRUSTS: Ascertainment of information concerning trusts (Regulation 10)

Regulation 10 (1) An accountable or reporting institution must ascertain in respect of a trust –

(a) its full name or where applicable its registered name; (b) the registration number, if any; (c) the country where it was set up if the trust was set up in a country other than Namibia; (d) the management company of the trust, if any; (f) one of the particulars listed in paragraph (g)(i) to (iii), in the order of preference, of each natural person who purports to be authorised to establish a business relationship or to enter into a single transaction above the determined threshold amount with the accountable or reporting institution on behalf of the trust; and (g) the full name and one of the following, listed in the order of preference –

(i) national identity number; (ii) passport number; or (iii) date of birth; of –

(aa) each trustee of the trust; (bb) each beneficiary of the trust referred to by name in the trust deed or other founding instrument in terms of which the trust is created; (cc) the founder of the trust; (dd) each beneficial owner of the trust; and (ff) any class of beneficiaries

(2) if the beneficiaries of the trust are not referred to by name in the trust deed or founding instrument in terms of which the trust is created, the accountable or reporting institution must follow the procedure in regulation 5(2) to ascertain the names of the beneficiaries and document the method of determining such beneficiaries. (3) If beneficiaries of the trust are designated by characteristics or class, the accountable or reporting institution should obtain sufficient information concerning the beneficiaries to satisfy itself that it will be able to establish the identity of the beneficiaries at the time of a pay-out or at the time when the beneficiaries intend to exercise their vested rights or claim their benefits.

Regulation 11 When a representative or agent acting on behalf of another person seeks to establish a business relationship or conclude a single transaction above the determined threshold amount with an accountable or reporting institution, that institution must – (a) take reasonable steps to ensure that the representative or agent is authorised to act on behalf of that person; and (b) establish the identity of the representative or agent as well as the identity of that other person in terms of these regulations.

F. PERSON ACTING ON AUTHORITY OF ANOTHER: additional requirements when person acts on authority of another (Regulation 11)

FCS QUESTIONNAIRES - (see our article on page 2, "FIA Regulations and Accountable institutions" ) *(See Regulations 6-11, 12 and 13 of the Financial Intelligence Act 2012)