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Nedbank failed to comply with its risk management and compliance programme in properly applying a risk-based approach across its business clusters, applying enhanced due diligence

Nedbank failed to comply with its risk management and compliance programme in properly applying a risk-based approach across its business clusters, applying enhanced due diligence controls and rating its clients for risk. Nedbank failed to comply with its record-keeping obligations in terms of sections 22, 23 and 24 of the FIC Act. These sections deal with keeping old financial records. Nedbank failed to comply with its cash threshold reporting obligations in terms of Section 28 of the FIC Act. The bank failed to report a significant number of cash transactions that exceeded the threshold of R24 999.99. Nedbank was unable to timeously determine when a transaction was reportable in terms of legislation. Nedbank failed to comply with its anti-money laundering and counter financing of terrorism governance-related obligations in that it was unable to evidence that senior management approval was obtained for its customer due diligence requirements prior to implementation. As a risk practitioner, advise or recommend any FIVE (5) techniques that Nedbank could use for treating loss exposures in its future business dealings.

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