Overview
Mesh requires every customer to be verified in accordance with the Anti-Money Laundering and Anti-Terrorism Financing regulations as implemented world-wide and per jurisdiction.
The regulations generally contain a number of control measures aimed at facilitating the detection and investigation of money laundering and terrorist financing and imposes specific responsibilities on financial institutions that relate to commencing a business relationship with a customer as well as maintaining it during the lifecycle of the business relationship with them.
This includes the requirement to “Know Your Customer” (KYC), requiring Mesh to establish and verify the identity of all customers prior to establishing a business relationship or concluding a transaction with them.
All information submitted is governed by the relevant privacy regulations per jurisdiction including the General Data Protection Regulations (GDPR) or whichever is more stringent.
Trusts
(excluding testamentary- and special- trusts)
The KYC requirements to establish and verify information for trusts are set out in regulations 15 and 16 of FICA.
The KYC requirements, for all trusts not listed under Other legal persons, are as follows:
Connected Legal Entities
The KYC requirements for trusts, also requires Mesh to establish and verify information in respect of entities who are connected to and / or who represent the trust.
These "connected entities" are as follows:
Individuals (i.e. natural persons)
The founder(s) of the trust, who is/(are) individual(s);
The trustee(s) of the trust, who is/(are) individuals;
The beneficiary(ies) of the trust, who is/(are) individuals or the manner in which the beneficiary(ies) of the trust is/(are) determined;
Agent(s) (e.g. the person/s authorised to open and / or maintain a relationship on behalf of the trust in terms of a trustee’s resolution, power of attorney, etc).
The KYC requirements, for individuals (i.e. natural persons) who are connected to trusts, are as follows:
Non-individuals (i.e. businesses and legal persons)
The founder(s) of the trust, who is/(are) non-individual(s);
The trustee(s) of the trust, who is/(are) non-individuals; and
The beneficiary(ies) of the trust, who is/(are) non-individuals or the manner in which the beneficiary(ies) of the trust is/(are) determined.
The KYC requirements, for non-individuals (i.e. businesses and legal persons) who are connected to trusts, are as follows:
Other legal persons
(including professional partnerships, testamentary- and special- trusts and other entities that cannot otherwise be categorised).
Partnerships included under other legal persons
The KYC requirements to establish and verify information for partnerships are set out in regulations 13 and 14 of FICA. Certain partnerships (as we understand/know them) are excluded from the FICA definition of partnerships. These partnerships are not excluded from KYC but are rather subject to a different set of KYC rules, under the category of other legal persons.
These partnerships are as follows:
Professional partnerships, consisting of more than twenty (20) partners, which are incorporated in terms of section 30(2) of the Companies Act, 61 of 1973 as "Professional Partnerships", limited by partners' liability, and which are recognised as such in terms of government gazette notice(s) issued from time to time, as follows:
Public Accountant or Auditor designated by Government gazette notice number R54 dated 11 January 1974;
Attorney, Notary and Conveyancer designated by government gazette notice number R57 dated 11 January 1974;
Professional Engineer designated by government gazette notice number R1813 dated 26 September 1975;
Quantity Surveyor designated by government gazette notice number R2391 dated 19 December 1975;
Pharmacist designated by government gazette notice number R1194 dated 13 June 1980;
Stockbroker designated by government gazette notice number R89 dated 22 January 1982;
Architect designated by Government gazette notice number R2398 dated 23 October 1987; and
Medical Practitioner, dentist or psychologist or a supplementary health service profession contemplated in section 32 of the Medical, Dental and Supplementary Health Service Professions Act, 56 of 1974 designated by government gazette notice number R1272 dated 2 August 1996.
Informal associations of individuals, for a common purpose/goal, where there are more than 20 individuals involved in such an informal association - e.g. stokvels, savings clubs, burial societies, etc.
Trusts included under other legal persons
Certain trusts (as we understand/know them) are excluded from the FICA definition of trusts. These trusts are not excluded from KYC but are rather subject to a different set of KYC rules, under the category of other legal persons.
These trusts are as follows:
Trusts that were established in terms of a testamentary writing (i.e. in terms of a last will and testament);
Special trusts that are established in terms of an order of court (e.g. a trust set up in terms of an order of court to administer payment of the proceeds of a settlement to applicants in respect of a land restitution claim; a trust set up in terms of an order of court for the care of minors; etc); and
Trusts established for the benefit of beneficiaries of a pension-, provident- or retirement- fund.
KYC requirements for other legal persons,
The KYC requirements for other legal persons are as follows:
Connected Individuals
The KYC requirements for other legal persons, also requires Mesh to establish and verify information in respect of individual persons who represent the other legal person.
These "connected individuals" are as follows:
Agent (e.g. a person authorised to open and / or maintain a banking relationship on behalf of the other legal person in terms of a resolution, power of attorney, etc).