text: PCC 46 – Guidance on the commencement and enforcement of the FIC Amendment Act | Moonstone
  Last week, the Financial Intelligence Centre published Public Compliance Communication 46 (PCC 46), the result of all comments considered as submitted on draft PCC 109.
  PCC 46 now confirms the fact that all the obligations as brought about by the FIC Amendment Act are effective and enforceable. It furthermore confirms that the Prudential Authority and FSCA may sanction non-compliance with the provisions of the FIC Act from 2 April 2019 onwards at their discretion.
  Accountable institutions must demonstrate compliance with all the obligations as set out in the FIC Act, which will apply to the accountable institution's full client database, at any given time, with the consequence of non-compliance resulting in possible administrative sanctions in terms of section 45C of the FIC Act.
  Further communication from the FIC also indicated that FSPs conducting both long-term and short-term insurance business, would only have to perform CDD on those clients to whom long-term insurance products are provided. It must, however, be kept in mind that the institution still carries the burden to monitor all transactions of its entire client base (both long-term and short-term client transactions) for possible section 29 reporting.