Everything you should know about South Africa's commercial

forensic industry

March 2020

THE PRACTITIONERFORENSIC

Inside this issue ...

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4 Important note from the ICFP Board of Directors

Ask the Practitioner - Predictions for 2020- Recovery from "guilty" employee's pension fund Pro�le: Meet Ansie Ramalho- Corporate governance in a time of corruption

Quick guide to follow the money- Stephen Ratcli�e provides valuable insight

Tackling the illegal wildlife trade and why it matters- Ursula M'Crystal & John Cusack look at this crime to identify money laundering

Financial Intelligence Centre- Legislative changes to strengthen the �ght against money laundering

Bitcoin & Co- Understanding crypto assets and how they are exploited by cybercriminals

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Important Notice

The COVID-19 virus is expected to have a signi�cant impact on our daily lives and, as such, we fully support the initiatives that our President, Mr Cyril Ramaphosa has announced. We believe that it is important to take the necessary precautionary steps to reduce the risks associated with COVID-19.    For that reason, we have decided to postpone all ICFP-related contact sessions until further notice.    We are, however, considering alternatives to the physical contact sessions and will inform you of our new initiatives in due course. Our o�ce remains in full operation and you are welcome to contact us if you require assistance or more information.

We were looking forward to welcoming you at our annual conference this year, however, circumstances have changed dramatically since the President announced a state of disaster in response to the COVID-19 threat.    In this time of uncertainty, it is impossible to predict the scope and e�ect of this global crisis.    We have, accordingly, decided to put the interests of all of our stakeholders, supporters and strategic partners �rst by postponing the Annual Conference to 22nd and 23rd July 2021. We will appreciate your consideration to transfer your 2020 conference registration to the 2021 conference.    It will provide us with the opportunity to continue with the planning of the conference, and by doing so you will also not be subject to annual registration fee adjustments.    However, if you have already made payment and prefer a refund, please advise us by sending an email to membership@icfp.co.za as soon as possible. Yours faithfully,

Annual Conference 23rd and 24th July 2020

ICFP Board of Directorsboard@icfp.co.za

Dear ICFP members and valued strategic partners

Ask

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the practitioner?What are the predictions in 2020 for Fraud,

Anti-money Laundering Compliance and Security?

Fraud in Five | 5 Predictions in 2020 for Fraud, AML Compliance and Fraud in Five | 5 Predictions in 2020 for Fraud, AML Compliance and ……

Stu Bradley, the Vice President of Fraud Security Intelligence, forecasts �ve trends that will impact the industry in 2020. The predictions are as follows:Prediction 1: Financial intelligence �nally becomes intelligent. Prediction 2: Identity is still king.Prediction 3: Computer vision joins the front-line in the war against crime.Prediction 4: A marketplace forms for Arti�cial Intelligence innovation in anti-money laundering.Prediction 5: Public and private partnerships become more than just talk.

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?Section 37D(1)(b) of the Pension Funds Act provides the trustees of a pension fund the discretion to deduct an amount of money from an employee's pension fund bene�ts to compensate the employer for the damage caused by such employee as a result of the employee's theft, dishonesty, fraud or misconduct, when two essential requirements are met:(1)        There must be a written admission of liability by the employee; or(2)        The employer must have obtained judgment against the employee.

Do you have a question which you want answered by a professional?

Send your questions via e-mail to:

chrisdebeer@icfp.co.za

https://www.youtube.com/watch?v=jEESSDIaPIE

Can an employer recover money lost due to fraud committed by an employee from an employee’s pension fund?

Corporate governance in a time of corruption

Ansie Ramalho

Meet ...

What takes up the bulk of your time?I would say KPMG, as it is busy stabilising. I expect that to lessen as 2020 progresses and where we, as non-executive independent directors, can take a step back.

Was it a failure of corporate governance structures that contributed to the events of the last few years?It was a combination of factors of which one is the way that audit �rms are set up, traditionally as partnerships, though legally they may not operate under that structure any longer. But that ethos, that partnership element, is still strong. And a partnership ethos is supported by closeness of relationship, by trust, by lack of formality and the belief we don’t need formality because we are partners. We are a family of sorts.

As the public anticipates the arm of the law reaching out to those implicated in the capture of the South African state, Ansie Ramalho talks about corporate governance and the role it could play in preventing a repeat of the past.

A lawyer by training, but a corporate governance practitioner by practice, Ms Ramalho was one of the main architects of the King Codes IV. She is also a former CEO of the Institute of Directors of Southern Africa. Ms Ramalho is currently a non-executive independent director of KPMG, as well as the National Blood Service. She is also a consultant to an array of entities on all matters relating to corporate governance, both in South Africa and across the continent.

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Is that what failed in the VBS matter (where former partner Sipho Malaba is alleged to have played a role in the fraud scheme that brought down the mutual bank)?One of the things that may have gone wrong in the VBS matter, and which KPMG has de�nitely put steps in place to do things di�erently going forward, is when somebody says to you, I did “x” and you accept that statement on trust. Now we ask for the paper trail, the supporting documents, regardless of whether the auditor in question is a senior partner or not. Remember, as human beings we are wired to trust, rather than to distrust. We have a trust default. The amount of evidence that points to dishonesty needs to be overwhelming against an individual before we will go there. This is laid out in detail in Malcolm Gladwell’s excellent book Talking to Strangers. And I thought it was very poignant in the case of KPMG. Is South Africa lagging behind in terms of corporate governance?We are a little bit ahead, in fact, because of the set of circumstances we have to deal with as an emerging economy. If you read the South African codes and compare them to the Australian codes, for example, you will �nd some clear di�erences. Woven into the SA code is very much the idea of leadership. It’s about leveraging the system. It’s about ethics and leadership, as well as sustainable development and sustainable development being part of ethics. What direction will corporate governance take in the next decade?One question I am often asked is whether we cannot develop codes for our government leaders. But my stock response is that our Constitution is the equivalent of a governance code for government. You get national governance and corporate governance. And governance, be it national or corporate, is about checks and balances essentially. I also hope that ten years from now, we will not only have all of the checks and balances, structures and processes, segregation of powers, etc, in place, but that we will begin to �ll in the dots with values. Our leadership need to be exemplary. We need to begin to switch from processes to taking personal responsibility. It starts with the person before it becomes an issue of corporate or national governance. It’s about personal belief systems, and collective belief systems. Regulation is not enough. If we have a spate of road tra�c crashes, reducing the speed limit will not solve the problem. That’s just tinkering at the edges. Corporate governance has to be more than a compliance exercise. We have to align our personal and collective belief systems. But when there are humans involved, there is always vulnerability. How long will that take?We are where we are because there has been a long development of events. This won’t come with the �ick of a switch. It will have a very long tail because it has had such a long genesis. But I am hopeful we can get to a much better place than where we are today. Would it help if we had a watchdog for corporate governance?I don’t think so. We don’t need any more layers. There is enough in place. We just need to enforce what we already have.

Do you think there will be a King V?Not just now, but eventually yes. Corporate governance as a discipline is very new. It has only been around for 30 years. It’s young. So there will be room for changes in the future, but not just now.

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By Stephen Ratcliffe

Stephen Ratcli�e’s quick guide to followthe money

“Follow the money!” Everyone’s talking about it, especially with regard to corruption, fraud and organised crime.What does “following money” actually mean in this context? How do we do it in practice? And what are some of the wider possibilities?

Tracking down high-level criminals and their networks

“Follow the money” is a snappy way to say: investigate �nancial transactions and use them to extract information or evidence about a crime, suspect or criminal network.In the case of acquisitive (money-oriented) crimes, including serious organised crime and corruption, there are sizeable assets at stake and the perpetrators are ultimately connected and motivated by money. This o�ers investigators an opportunity to trace the illicit �nancial �ows back to and between the high-level criminals and their networks. This is essential if we want to arrest and prosecute the masterminds behind organised crime and corruption – not only the low-level actors caught red-handed – and to break down their networks.Financial transactions reveal links between criminals and their networks or family members. The investigator can use this information to broaden the investigation or obtain evidence for use in court. A few bank statements have the power to lay bare connections and conspiracies, especially in bribery and corruption cases.

And it’s not just about banks: consider utility bills, store loyalty cards, receipts and insurance documents for a start.

Seizing and confiscating criminal assets Following the money also leads investigators to criminals’ assets, which might be money in a bank account or Bitcoin (crypto currency) wallet, a house, a car, or another fund or item of value. The assets might be held by another person on behalf of the main criminal.Tracing a suspect’s �nancial transactions reveals how the illicit proceeds of their crime were laundered and spent and where the resulting assets now lie. The information could be used to obtain evidence for a civil recovery case aimed at getting those assets back. This can often be done even when a criminal conviction is not possible.

Following the money isn’t just about money Thorough investigators don’t stop at the obvious sources of �nancial transactions such as bank accounts and credit card accounts. Sometimes it’s about following physical clues. The suspect has a satellite dish or an Internet connection: how is she or he paying for the satellite TV subscription? Many of these companies do not accept cash payments. A court order can be obtained to request the answer from the satellite provider which may reveal new possibilities to investigate the suspect’s �nances.

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Gaps in transactions are also a red �ag. Why does a suspect’s credit card suddenly show a three-month gap? Was he using cash to make his routine purchases, and if so, what was the source of this cash?

Opportunities and challengesOne bene�t of using �nancial transactions to investigate crimes and trace criminal assets is that the evidence is hard to destroy. Bank accounts, Bitcoin (crypto currency) transactions and other �nancial records can be accessed years after a crime has taken place and allow investigators to do their work long after the physical evidence has gone. They are also records produced in the course of business and are likely to be accepted as evidence by a court.On the other hand, thorough �nancial investigations take time and money, so investigators face the risk that the assets will dissipate before they have enough evidence to request their seizure. This is even more likely to happen in grand corruption cases, as funds are moved through o�shore companies whose main purpose might be to distance and obscure the details of the bene�cial owner of the company.Money laundering investigations take even longer when they require international cooperation – which in the case of grand corruption and serious organised crime, they almost always do. Gaining information from abroad takes some serious persistence and paperwork for some of the reasons described in this quick guide to international cooperation. (This guide can be accessed at https://www.baselgovernance.org/blog/shane-nainappans-quick-guide-international-cooperation-asset-recovery.)That is one reason the global money laundering watchdog, the Financial Action Task Force (FATF), now focuses on the e�ectiveness of countries’ tools for cooperation on requests relating to money laundering, not just their existence. Some countries score zero for e�ectiveness. Many others score poorly, causing them to plummet down the Basel AML Index ranking of money laundering risks.The international aspect presents an opportunity, however. Money trails or illicit �nancial �ows, criss-cross the world, which means they can be followed from either end. If a criminal in Country A stashes money in Country B, the authorities in both countries – theoretically – have the possibility of uncovering enough �nancial information to bring him or her to justice and recover the assets.Indeed, the activity that takes place in Country B after the money has arrived – such as buying property or forming a sham company with associated bank accounts to move the money around – might itself be a money laundering o�ence in that country.This happens a lot. That’s why international guidelines recommend that countries that receive enquires from law enforcement bodies abroad related to money laundering and corruption should independently consider launching their own domestic investigation. (For more information about these guidelines, visit https://guidelines.assetrecovery.org/guidelines/guideline-8-parallel-investigation.)

Creative concepts around following moneyThe most popular use of the phrase “follow the money” refers to the type of criminal and civil investigations described above. But looking at �nancial �ows has much wider uses in the �ght against crime.Following money �ows in real time, for example through automated or manual monitoring of live banking transactions for speci�c red �ags, can help to detect crimes as they’re happening. This might be invaluable in cases of wildlife tra�cking, for example, so the relevant authorities can be alerted in time to seize the suspect goods when they arrive at their destination.Data on �nancial �ows can also support the work of intelligence and social network analysts in mapping how criminal networks are formed and operate.Finally, there’s another buzzword to think about: how big data on �nancial transactions can help us to understand money laundering trends at a higher level and shape policy accordingly. But that's a whole other story.

About the authorStephen Ratcli�e is a senior investigation specialist within ICAR, having joined the Basel Institute on Governance in August 2015. Most recently he has been working for the Royal Cayman Islands Police and was in charge of their �nancial crime and intelligence departments. He co-chaired the group, which wrote the money laundering risk assessment in advance of the FATF inspection due in 2017.He holds a Master of Studies degree from the University of Cambridge in Applied Criminology and Management.Stephen can be contacted via email: stephen.ratcli�e@baselgovernance.org

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Tackling the illegal wildlife trade and WHY it matters

By Ursula M’Crystal & John Cusack

Is it possible that there are ICFP practitioners who might not have heard the starter’s gun signalling the urgent need to tackle wildlife trafficking? In the last few years there have been a significant upsurge in awareness, research, debates, campaigns and media articles addressing this topic. At the end of 2019, the Financial Action Task Force (FATF) commendably hosted one of the first regional meetings on tackling illegal wildlife trade as a financial crime (FATF, 2019). A number of significant seizures and arrests have been reported in the media (Livni, 2019), and more recently links have been reported between the Coronavirus and the consumption of wildlife products (Mallapaty, 2020). One thing is certain, this is not a time to be jogging - the marathon for those tasked with financial crime investigation and control has become a sprint.

In order to fully understand the magnitude of the problem in sub-Saharan Africa (SSA), the Financial Crime News (FCN) has been working on creating some context that highlights high-risk crimes across SSA, and has estimated the value of proceeds of crime that �ow from there (Cusack, 2019). In this unique approach to evaluating crime risk in SSA, we have posed and answered some questions relating to the criminal markets which generate the majority of proceeds of crime, in which countries and for whose bene�t. Perhaps surprisingly, environmental or "green" crimes are a top three criminal market in SAA at almost $40 billion. Green crimes re�ect large amounts generated from illegal logging, wildlife tra�cking, illegal mining and �shing and waste dumping. More information on these numbers and how they �t into the broader sub-Saharan African context is coming soon from FCN, in a publication of a dedicated comprehensive Regional Threat Assessment. According to an INTERPOL report (Enact, 20I8), wildlife crimes in South Africa are estimated to constitute 21% of organised crimes detected in the Southern African region. Although rhino horn and ivory tra�cking receive most attention, other wildlife crimes of note are the poaching of abalone and the illegal �shing of sea turtles and sharks.

DW (2018) reports that illegal �shing of seafood species in South Africa are estimated to generate up to $900 million (from 2001 to 2018) for criminal gangs, averaging eight tonnes a day. There are also touch points with other organised crime activities, when products are exchanged for drugs such as methamphetamine (Tik). Illicit trade in natural resources is a major domestic threat to South Africa, crowding out legitimate economic activity, depriving the government of revenues for investment in vital public services, dislocating legitimate jobs and causing irreversible damage to ecosystems and natural resources. The meeting hosted under FATF’s current Chinese presidency, has made it a priority to help countries disrupt criminal networks that bene�t from these crimes. Critically, it was acknowledged that sharing knowledge and information between the public and private sectors was vital in understanding the evolving risks, and adopting e�ective practices that can be used by �nancial crime investigators to address illegal wildlife trade.

This sentiment was echoed in a recent paper published by the Basel Institute of Governance, Wannenwetsch and Aiol� (2019) acknowledge that there is widespread and increasing awareness that illicit wildlife tra�cking is not only a conservation dilemma, but that these crimes represent signi�cant risks to organisations, both reputationally and �nancially. As expected, transport and �nancial companies are most vulnerable, but there are also additional heightened risks for organisations due to the overlaps and similar challenges faced with tackling corruption.

An e�ective opportunity for �nancial institutions to contribute to, and bene�t from, expertise relating to the illegal wildlife trade is available through joining the United for Wildlife Financial Taskforce (the Taskforce) and signing the Mansion House Declaration (the Declaration) to partner with others to combat illegal wildlife tra�cking, including through information sharing. A shout out to all South African signatories to the Declaration, including ABSA, Standard Bank, Investec, Standard Chartered Bank and Tra�c – all leaders in this �ght!

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If you want to be a part of this race, you need to do the necessary preparation. This means that you need do the basics well, and then take one step further to go the extra mile. Investigations that relate to green crimes should include various methods and techniques already adopted by �nancial crime combatting specialists, but these can be enhanced by essential knowledge of methods used to commit these crimes in South Africa. Awareness is key. Sharing intelligence (within appropriate and controlled mechanisms) is equally, if not more, important. The use of software, data mining techniques and front-line information are all valuable components that can lead to identi�cation of potential perpetrators and the �nancial �ows from these crimes. Key areas to consider can include smuggling routes, supplier and destination countries, use of import/export companies as well as other logistics providers.

The usual vigilance applied by accountable institutions in relation to their clients in relation to client due diligence, geographical risk, types of funds �ows, monitoring of business types, and analysing inter-related company activities need to be enhanced. Critically, high quality intelligence should be obtained and considered in context of these speci�c environmental crime risks.

There is no doubt that government agencies and the private sector have a dual role to play in collaborating and uniting to combat these crimes. Taking the next steps from collaborative engagements to action will take commitment and drive for all sectors a�ected. Regulators, supervisors, law enforcement agencies, accountable institutions, and other private sector institutions should not be absent, or mere observers, but they should rather be at the forefront of these collaborations and action plans, with a mandate to develop and deliver e�ective solutions.

About the authors

Ursula M’Crystal is an independent consultant and mentor, who is able to rely on her local and international experience over 26 years in law enforcement, government and private sectors, to guide clients and learners on a holistic approach to effectively adopting AML/CFT solutions and investigative techniques.

John Cusack is a leading financial crime fighter, Editor of the Financial Crime News, former Global MLRO at UBS and Standard Chartered Bank, two-time Co-Chair of the Wolfsberg Group (to end 2019), Ambassador to the United for Wildlife Financial Taskforce and to Stop the Traffic, a human trafficking NGO, and adviser to Leading Regtech Providers Quantexa and Caspian.

There is no organisation or person that should feel that they cannot contribute to tackling illegal wildlife crime in South Africa, or beyond the borders if required.    The only question that remains is: are you running this race, cheering on the sidelines or are you still sitting on the couch watching the race?

List of referencesCusack. J. 2019. “South Africa country threat assessment by FCN.” Financial Crime News. 22 November. - Accessed at https://thefinancial-crimenews.com/south-africa-country-threat-assessment-by-fcn on 24 February 2020.Deutsche Welle (DW). 2018. “Chinese gangs fuel illegal South Africa abalone trade: report.” -    Accessed at https://www.dw.com/en/chinese-gangs-fuel-illegal-south-africa-abalone-trade-report/a-45567801 on 24 February 2020.Enact. 2018. “Interpol overview of serious and organised crime in the Southern African Region 2018.” - Accessed at https://enactafrica.org/ research/analytical-reports/interpol-overview-of-serious-and-organised-crime-in-the-southern-african-region-2018 on 24 February 2020.Financial Action Task Force (FATF). 2019. “Tackling the illegal wildlife trade as a financial crime.” - Accessed at http://www.fatf-gafi.org/countries/a-c/china/documents/illegal-wildlife-trade-beijing-nov2019.html on 24 February 2020.Livni, E, 2019. “The world’s largest-ever wildlife trafficking bust saves thousands of animals.” Quartz. 14 July. - Accessed at https://qz.com/1665989/ massive-wildlife-trafficking-operation-saves-thousands-of-animals/ on 24 February 2020. Mallapaty, S, 2020. “China set to clamp down permanently on wildlife trade in wake of coronavirus.” Nature. 21 February. - Accessed at https://www.nature.com/articles/d41586-020-00499-2 on 24 February 2020. United for Wildlife Taskforce. 2019. Accessed at https://www.unitedforwildlife.org/wp-content/ uploads/2018/09/FT-Signatories-Sept-2019.docx on 24 February 2020.Wannenwetsch, S and Aiolfi, G. 2019. “Private-sector engagement in the fight against illegal wildlife trade.” Working Paper 32. December. Basel Institute of Governance.    - Accessed at https://www.baselgovernance.org/sites/default/files/2020-01/WP32_IWT%20Collective%20Action.pdf on 24 March 2020.

Financial Intelligence Centre

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Legislative changes to strengthen the fight against money laundering

Cash is king to many criminals, but even when they have loads of cash, they cannot simply flash it at any and every occasion such as by walking into a vehicle dealership to buy a luxury vehicle without having to declare the source of that cash. Criminals therefore devise ways to pretend as that the money is from a legitimate source, through a process referred to as money laundering. That is why it is important for any state to be one step ahead of criminals by developing anti-money laundering processes and legislation.

Legislation

By Annalise Kempen

Among others, the aim of the Financial Intelligence Centre Act 38 of 2001 (FIC Act) was to establish the Financial Intelligence Centre (FIC) to impose certain duties on institutions and other persons who might be used for money laundering purposes and the �nancing of terrorist and related activities. The FIC was therefore established as an institution outside the public service but within the public administration as envisaged in section 195 of the Constitution of South Africa, 1996 and functions as a juristic person.

The FIC is South Africa’s national centre for the receipt of �nancial data, analysis and dissemination of �nancial intelligence to the competent authorities. The Centre has the mandate to identify the proceeds of crime, combat money laundering and terrorist �nancing.

What is money laundering?The FIC Act de�nes “money laundering” or a “money laundering activity” as an activity which has or is likely to have the e�ect of concealing or disguising the nature, source, location, disposition or movement of the proceeds of unlawful activities or any interest which anyone has in such proceeds, and includes any activity which constitutes an o�ence in terms of section 64 of this Act or section 4, 5 or 6 of the Prevention of Organised Crime 121 of 1998.

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The FIC explains that when criminals generate an income from their criminal activities there are typically three stages how they go about to launder the proceeds of their crimes. The �rst stage is referred to as placement where criminals would, for example, introduce their illegally derived proceeds into legitimate �nancial systems by depositing smaller amounts of cash into a bank account. During the second stage, which is referred to as layering, the criminal will engage in a series of transactions, conversions or movements of the funds in order to cloud the trail of the funds and separate them from their illegitimate source. Typically, activities can range from purchasing and selling investment instruments, purchasing property and selling it soon after, or by simply wiring funds through a series of accounts at various international banks. The integration stage, generally follows the successful stages of placement and layering. At this latter stage, the criminal (money launderer) ensures that the funds re-enter the economy by making it appear to be legitimate.

This can be done by investing the funds into real estate, luxury assets or business ventures. In some cases, criminals are so arrogant that they simply “place” the proceeds of their crimes into the economy by depositing money directly into their bank accounts, whereafter they can withdraw and spend it at their will. Therefore, accountable institutions such as practising attorneys, estate agents, banks, long-term insurance, �nancial service providers, gambling institutions and motor vehicle dealers have to comply with legislation to report such irregular activities.

Legislative amendmentsThe FIC Amendment Act 1 of 2017 of which speci�c sections came into operation between June 2017 and April 2019, amends the FIC Act, as a result of the 2009 Mutual Evaluation and to align to the Financial Action Task Force (FATF) requirements and United Nations obligations. Among others, this Amendment Act aims to –• extend the functions of the FIC to provide for additional sharing of information;• provide guidance to accountable institutions regarding the freezing of property and transactions in accordance   with resolutions adopted by the United Nations Security Council; • provide for a risk-based approach to client identi�cation and veri�cation, rather than a rules-based approach;• provide for the strengthening of customer due diligence measures including regarding bene�cial ownership and persons in prominent positions;• provide for the obligation to keep identity, veri�cation and transaction records;• provide for risk management and compliance programmes (RMCP), governance and training related to anti-money laundering and counter terrorist �nancing; and• increase the maximum penalties that may be imposed in the regulations.

An article published by BusinessTech in January 2020, states that these legislative amendments oblige accountable institutions to gather su�cient information to mitigate the potential risks they could impose on the business. The writer further states that the traditional identi�cation methods through ID documents and utility bills are no longer the alpha and omega, but that institutions’ approach should rather focus on assessing the risk for money laundering and terrorist �nancing for every transaction and customer.

The FIC explains this risk-based approach in terms of accountable institutions’ assessment of whether clients aim to misuse products and services o�ered by such institutions for money laundering and terrorist �nancing purposes. If a risk-based approach is applied, it ensures that accountable institutions are able to implement measures that are proportionate with the money laundering and terrorist �nancing risks identi�ed. This means that accountable institutions must identify, assess, monitor, mitigate and manage the risk of whether the goods and services provided by the accountable institution may involve or facilitate money laundering and/or terrorist �nancing.

Through the risk-based approach, accountable institutions must, inter alia, evaluate each of the following aspects in order to identify possibly money laundering or terrorist �nancing:• Products and services relating to cross-border �ow of money; third-party payments; the depositing and withdrawing of cash and EFT transactions; and the duration of the business relationship.•        Determine whether the client operates within our borders or from a foreign jurisdiction especially from a so-called high-risk country with weak regulatory oversight or where the client might enjoy con�dentiality in this jurisdiction.• Establish whether the client has a direct relationship with the accountable institution which include face-to-face interaction or whether he or she (or the company) works through an intermediary?• Con�rm whether the client is a natural or legal person, possibly with prominence, negative media exposure or political exposure and whether he or she operates with complex structures or where money laundering �ndings have been made.

Accountable institutions must identify, assess, monitor, mitigate and manage the risk of whether the goods and services provided by the accountable institution may involve or

facilitate money laundering and/or terrorist financing.

The risk-based approach

Accountable institutions can assign di�erent ratings or categories to clients to indicate their likelihood of money laundering and terrorist �nancing. The risk scale must also be tailored according to the size of an accountable institution and need to be re-evaluated periodically. Take the following example of a potential high-risk client relating to money laundering and terrorist �nancing for an accountable institution: An unemployed individual who resides in Iran, which is a high-risk country according to the corruption perception index, wants to pay in cash for a property he wants to purchase in South Africa without any face-to-face interaction. The fact that this client is unemployed but has access to large amounts of cash, sets in motion issues pertaining to the source of the funds, the client’s preferred anonymity of not wanting any face-to-face contact and not having any prior relationship with the accountable institution.

In another example, a prospective client, namely a company registered in South Africa wants to buy a property in an expensive suburb on the Atlantic seaboard in Cape Town. The owner of the company is a prominent and in�uential person who has been linked to alleged criminals in media reports. Before entering into a relationship, the accountable institution should consider the risks associated with the negative media reports about the owner, even though the transaction is for the company.

Prior to October 2017, the FIC Act and regulations related to money laundering and terrorist �nancing, prescribed the type of information that was needed to verify di�erent types of persons’ identity. Following legislative changes, the FIC Act is no longer prescriptive, although Chapter 4 of the Money Laundering Terrorist Financing Control Regulations (MLTFC Regulations) sets out the minimum information that must be provided in reports. Section 42 of the FIC Act also places an obligation on accountable institutions to develop, document, maintain and implement a risk-management and compliance programme (RMCP), which should state which documents are relied on for veri�cation.

In terms of the RMCP, customer due diligence is a comprehensive process according to which client information must be veri�ed by comparing it against the original source, electronic data issued or reliable third party such as that of the Department of Home A�airs or SARS. Although the accountable institution has �exibility in terms of choosing the type of information needed to establish the client’s identity and the means to verify information, the nature and extent of the veri�cation have to be assessed in terms of the risk and in terms of the RMCP. During the course of conducting a single transaction/business relationship, the veri�cation must be completed before the transaction is concluded. In cases where an accountable institution doubts accuracy or adequacy of previously obtained information, the accountable institution must repeat the identi�cation and veri�cation steps taken.

When accountable institutions deal with legal persons, trust and partnerships, additional due diligence measures apply which require of accountable institutions to obtain information in line with its RMCP relating to the nature of the client’s business; and the ownership and control structure of the client. The FIC Act de�nes a “bene�cial owner” in respect of a legal person as the natural person who, independently or together with another person, owns the legal person or exercises e�ective control of the legal person. The FIC warns that the lack of adequate, accurate and timely bene�cial ownership information facilitates money laundering or terrorist �nancing as the identity of known or suspected criminals; the true purpose of an account or property held by the legal entity; and the source or use of funds or property associated with the legal entity, are disguised. In order to understand the customer pro�le to assess the money laundering or terrorist �nancing risks associated with the business relationship, and to take appropriate steps to mitigate the risk, it is vital for accountable institutions to establish the bene�cial ownership in companies.

If an accountable institution is unable to conduct customer due diligence; obtain additional due diligence information or conduct ongoing due diligence, such an institution must not establish a business relationship or conduct a single transaction; or terminate an existing client relationship and consider �ling a section 29 suspicious transaction report (STR).

When an accountable institution deals with a foreign prominent public o�cial, a domestic prominent in�uential person and/or their family members or known close associates of these persons, such an institution must establish the individual’s source of wealth; obtain senior management approval to establish a business relationship and ensure enhanced due diligence monitoring. Schedule 3B of the FIC Act lists those who are regarded as foreign prominent public o�cials such as heads of states, while Schedule 3A lists those who are regarded as domestic prominent in�uential persons such as the president and ministers, CEOs and CFOs of state entities such as Eskom and Telkom.

According to section 28 of the FIC Act, an accountable institution must report cash transactions of R24 999.99 and more, irrespective of whether that transaction is conducted with cash, coins, paper money and travellers’ cheques (EFTs are excluded), within two days of the transaction (pending a regulatory update). Accountable institutions are also obliged to keep record of a variety of information for a period of at least �ve years after the client relationship has been terminated. Both hard and soft copies of this information must be kept safe, must be accessible and the accountable institution can make use of third party storage providers. Accountable institutions are also obliged to provide their employees with ongoing training about compliance with the FIC Act and the institution’s RMCP, of which the training levels and intervals must be speci�ed in the programme.

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The FIC’s responsibility regarding the FATFThe FATF is an inter-governmental policy-making body consisting of members of more than 30 countries. The countries that have joined the FATF or a FATF-style regional body, have committed to implement the FATF standards at a ministerial level and to have their anti-money laundering and combating of terrorist �nancing (AML/CFT) systems assessed. The Eastern and Southern African Anti-Money Laundering Group (ESAAMLG) was established to serve as a FATF-style regional body for eastern and southern African countries. South Africa’s mutual evaluation is undertaken by both these organisations, namely the FATF and the ESAAMLG.

Each member of these two latter organisations undertakes peer reviews of their members and South Africa’s evaluation is part of this process with the International Monetary Fund as the third member of the evaluation team. The FIC notes that a mutual evaluation is an important opportunity for a country to have its anti-money laundering and combating of terror �nancing framework reviewed by its peers. During the latest peer review process, members of the evaluation team have met representatives from the South African government and industry to understand how they carry out their respective functions in implementing South Africa’s measures against money laundering and terrorist �nancing. It is expected the �nal draft containing the assessment team’s conclusions will be issued in the second part of 2020 which will be a re�ection of how well South Africa is doing in maintaining the integrity of its �nancial system.

The FIC is not merely another statutory body with no teeth. Already in March 2015, the FIC imposed the �rst administrative sanction in terms of the FIC Act and by July 2019, the FIC had issued in excess of 60 sanctions to the total value of approximately R42.3 million. A case in point is that of a commercial bank that was penalised for non-compliance with section 28 of the FIC Act relating to the �ling of cash transaction records (CTRs) and section 43(a) relating to the training on the FIC Act and accountable institutions internal rules. This bank incurred a �nancial penalty of R5.25 million.

The FIC is a vital player in the �ght against money laundering and combating terrorist �nancing which it does by sharing the products of its analysis derived from reports with competent authorities such as law enforcement agencies, the intelligence services, South African Revenue Service and supervisory bodies. They are however dependent on the receipt of the relevant reports submitted by accountable institutions to do their work so that this information can assist these authorities to discharge their responsibilities such as conducting investigations, prosecutions and forfeiting assets which were acquired from the proceeds of crime. Together they can make a lasting di�erence in the �ght against money laundering and terrorist �nancing.

Anon. 2020. “How to reduce money laundering in 2020.” BusinessTech. 23 January. – Accessed at https://businesstech.co.za/news/industry-news/367824/how-to-reduce-money-laundering-in-2020/The Financial Intelligence Centre Act 38 of 2001.The Financial Intelligence Centre Amendment Act 1 of 2017. – Accessed at https://www.gov.za/documents/ �nancial-intelligence-centre-amendment-act-1-2017-english-afrikaans-2-may-2017-0000www.�c.gov.za and additional information provided by the Financial Intelligence Centre.

List of references

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Bitcoin & Co

Understanding crypto assets and how they are exploited by cybercriminals

The mere mention of the word “Bitcoin” is enough to block many people’s minds as the concept of virtual or digital money simply does not make sense in a world where we are still used to exchanging hard cash for goods and services. In fact, according to Cash Connect (2019), about 85% of all transactions in South Africa are still in the form of cash. Although many of us are using bank cards as a presumably safer way to transact, the choice of approximately 2000 cryptocurrencies or crypto assets (https://coinmarket-cap.com) of which Bitcoin is the most active is still unknown territory for the average man on the street. Yet, investors are increasingly finding cryptocurrencies more appealing as safe havens for assets in times of global political uncertainty and turmoil. One of the reasons is that they are not directly subject to market forces such as interest rates or currency devaluation (Reinicke, 2019).

By Annalise Kempen

Few of us can remember the days when the Internet was still in its infancy in the early 90s when we were told that we would be able to access a world of information at the click of a button from the comfort of our o�ces or homes. In those early days we did not realise the extent to which we would become dependent on the Internet. Only time will tell whether the same will apply in future about the use of crypto assets, which has already celebrated its tenth anniversary since the �rst Bitcoin was sold in 2009. Despite a market capitalisation of $830 billion by 8 January 2018 according to the Financial Stability Board (2018), which is small compared to the global �nancial system and crypto assets not being widely used yet for �nancial transactions, the use of crypto assets has already been identi�ed as an emerging threat by the �rst INTERPOL Working Group on DarkNet and cryptocurrencies. This comes after INTERPOL has in recent years witnessed a sharp rise of phenomena such as DarkNet markets, cryptocurrencies and speci�c Bitcoin mixers and tumblers, which pose a major threat as they are not only limited to cybercrime but cut across a multitude of crime areas (2018).

Criminals are experts in �nding loopholes in systems and with the increasing use of crypto assets, this is yet another area which they will exploit. In an attempt to describe and answer many of the challenges of providing a legal framework, regulations and the challenges dealing with crypto assets, the Financial Intelligence Centre (FIC) arranged an informative workshop focusing on crypto asset investigations in August 2019 in Pretoria. The workshop was attended by a variety of role-players who are already or will in future be challenged by crypto asset investigations. According to Adv Xolisile Khanyile, the Director of the FIC, it is important to understand how this world works and how crypto assets are used by criminals. An article that was published in the Fortune magazine dated 24 April 2019, states that criminals who use crypto assets, prefer using Bitcoin for their illicit activities.

Crypto assets: a new player

According to Jonathan Levin, co-founder and COO of Chainalysis, who is quoted in the article, Bitcoin accounts for 95% of the cryptocurrency cases law enforcement investigates. It seems that the same reasons that have made Bitcoin the top digital crypto asset on the market, namely that it is the most valuable and also has the highest transaction volume of any of its peers, have also made it the criminals’ crypto asset of choice. Mr Levin further notes in the article that the majority of recent opioid busts in the United States of America stemmed from blockchain analysis, allowing authorities to trace illegal purchases of fentanyl and other drugs paid for in cryptocurrency (Wieczner, 2019).

Adv Khanyile noted at the FIC conference that due to the anonymity of those who buy, sell and use crypto assets, it would be a challenge to identify the originator and the bene�ciary of transactions. Yet, she advised that as with all white-collar type crime, it was important to use traditional investigative techniques and “follow the money”. She also told the delegates that South Africa's FIC will in future be assessed on the investigation of crypto assets in terms of whether it complies with anti-money laundering measures. She noted that the rest of Africa needs us to lead the process on dealing with investigations involving crypto assets especially since South Africa is still the only African country that is part of the Financial Action Task Force (FATF).

Understanding the terminologyCrypto/virtual assets and virtual asset service providersIn order to frame this discussion, it is important to have a clear understanding of the term “crypto/virtual assets”. The FATF is the inter-governmental body that sets international standards and promotes e�ective implementation of legal, regulatory and operational measures for combating money laundering, terrorist �nancing and weapons of mass destruction, and other related threats to the integrity of the international �nancial system. During the FATF plenary that was hosted in October 2018, the following de�nition for virtual assets was adopted. “A digital representation of value that can be digitally traded or transferred and can be used for payment or investment purposes. Virtual assets do not include digital representations of �at currencies, securities and other �nancial assets that are already covered elsewhere in the FATF recommendations.” (Fiat currency is money that does not have intrinsic value but is recognised or accepted as a form of legal tender through government regulation (https://whatcurrency.net/world-�at-money-list/).) For their purposes, the SARB and the SARS have adopted a similar de�nition namely that “crypto assets are digital representations of value that is not issued by a central bank, but traded, transferred or stored electronically by natural or legal persons for payment, investment or utility purposes”. SARS makes it clear that crypto assets are not regarded as legal tender or e-money in South Africa and that crypto assets are not recognised as a currency. SARS regards crypto assets as assets of an intangible nature and the gains or losses in relation to crypto assets are therefore taxable. It is, however, an instrument that can be used for the payment of goods and services and has the ability to be used as a store of value for investment.

On 6 April 2018, SARS noted in a media statement that it would continue to apply normal income tax rules to crypto assets and would expect a�ected taxpayers to declare crypto asset gains or losses as part of their taxable income. Thus, the onus is on taxpayers to declare all crypto asset-related taxable income in the tax year in which it is received or accrued. Those who fail to declare this income might be subjected to paying interest and penalties. The FATF de�nes virtual asset providers as follows: “Any natural or legal person who is not covered elsewhere under the Recommendations, and, as a business conducts one or more of the following activities or operations for or on behalf of another natural or legal person:• Exchange between virtual assets and �at currencies;• exchange between one or more forms of virtual assets;• transfer of virtual assets (in this context of virtual assets, transfer means to conduct a transaction on behalf of another natural or legal person that moves a virtual asset from one virtual asset address or account to another);• safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets; and• participation in and provision of �nancial services related to an issuer’s o�er and/or sale of a virtual asset.”

Bitcoin; Ethereum; XRP; Bitcoin Cash etcDuring the FIC workshop, Marius Reitz from the virtual asset service provider Luno described Bitcoin as a new way of moving and storing money. It is the world’s �rst public digital payment infrastructure or globally accessible public money. It is a relatively new global “currency” (although the SARS does not recognise it as such) where no-one is in charge and everyone can use it - all that is needed is a computer (or an electronic device such as a smartphone) and Internet connectivity. Bitcoin is further described as a consensus network that enables a new payment system and is a completely digital money. It is the �rst decentralised peer-to-peer payment network that is powered by its users with no central authority or middlemen. From a user perspective, Bitcoin is pretty much like cash for the Internet (https://bitcoin.org/en/faq#general).    XRP; Ethereum and Bitcoin Cash are examples of the more than 2000 virtual assets in which one can trade or invest and have di�erent values.

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The regulation of Crypto Asset Service ProvidersThe amendment of the FATF Recommendation 15 requires that all Crypto Asset Service Providers (CASPs) be regulated for anti-money laundering and combating of �nancing of terrorism purposes and that they should be licensed or registered and subject to e�ective systems for monitoring or supervision. Due to the potential for increased anonymity of virtual asset �nancial �ows and the challenges with conducting e�ective customer identi�cation and veri�cation, virtual assets and CASPs may be exposed to higher money laundering and terrorist �nancing risks which is why enhanced due diligence measures should be implemented where appropriate. This implies that CASPs should identify their customers and verify their customers’ identity. CASPs will also be required to maintain all records or transactions and customer due diligence measures for a certi�ed period, similarly to what is expected in the Financial Intelligence Centre Act 38 of 2001 (as amended) of accountable institutions such as banks and other �nancial service providers. In addition, countries will also be required in terms of the updated FATF Recommendations to determine whether customers or bene�cial owners are foreign politically exposed persons, or related or connected to such persons. If that is the case, enhanced measures need to be taken to determine whether they are doing business with them, including identifying the source of funds when relevant. In order to comply with these updated FATF Recommendations, the FIC is in the process of dealing with amendments to items listed in Schedule 1 of the FIC Act to include certain activities carried out by virtual/crypto asset service providers, thus making them accountable institutions. That means that such CASPs would have to comply with provisions such as customer due diligence, record-keeping and reporting. Currently, crypto asset service providers only have an obligation to �le suspicious and unusual transaction reports under section 29 of FIC Act. The South African Reserve Bank, the Financial Intelligence Centre, the Financial Sector Conduct Authority and the National Treasury have established an Inter-governmental Fintech Working Group (IFWG) to enable policymakers and regulators to understand, more broadly, the �ntech developments and relevant policy and regulatory implications for the South African �nancial sector and economy in order for a coordinated approach to �ntech policy-making to be developed and adopted. According to the FIC’s Compliance and Prevention division, the items in Schedule 1 that will be amended to include crypto asset service providers, relate to the following:A person who carries on the business of one or more of the following activities or operations for or on behalf of a client:• Exchanging a crypto asset for a �at currency or vice versa;• exchanging one form of crypto asset for another;• safekeeping or administrating a crypto asset or an instrument enabling control over a crypto asset; • conducting a transaction that moves a crypto asset from one crypto asset address or account to another; and/or• participating in and providing �nancial services related to an issuer’s o�er or sale of a crypto asset.

Understanding Bitcoin and CoAccording to Marius Reitz from Luno, a crypto asset service provider, a company such as theirs facilitates Bitcoin (or other crypto asset) storage and transactions such as buying, selling and paying through a digital wallet. In addition, it operates as an exchange platform between �at currency and crypto assets and also provides secure storage via sophisticated and layered security processes and procedures.

The price of crypto assets such as Bitcoin and Ethereum is determined by supply and demand and not by service providers. For example, by 14 March 2020, one Bitcoin was worth R94 200 while one Ethereum was worth R2245 (https://www.luno.com/en/price#ETH). Bitcoin can however be bought in “bits”, for example one can buy R10 000’s worth of Bitcoin, because it is dividable into units. As noted earlier, the value of crypto assets depends on supply and demand and with Bitcoin, the total supply is limited to 21 million Bitcoins which gives it its value. Yet, one has to realise that Bitcoin transactions are not reversible and that some of the other challenges of crypto assets include that they are not yet accepted everywhere or anywhere; they are not used often to quote prices; and they are not the most stable in value.

Due to the potential for increased anonymity of virtual asset financial flows and the challenges with conducting effective customer identification and verification, virtual assets and CASPs

may be exposed to higher money laundering and terrorist financing risks which is why enhanced due diligence measures should be implemented where appropriate.

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In order to be able to transact with Bitcoins, one will be issued with both a Bitcoin address as well as a Bitcoin private key. The latter is usually a 256-bit number and is regarded as the golden ticket that allows individuals to spend their Bitcoins, which is why it needs to be kept safely and securely (Chokun, 2018). Those individuals who lose their private key, will not be able to access their crypto asset. Ironically, crypto asset service providers such as Luno store private keys for digital “currency” such as Bitcoin in physical bank vaults and detached from the Internet. They are however only accessible with strict access controls such as �ngerprint and retina scans, and across continents necessitating the user to put them together to be able to extract the Bitcoin (www.luno.com).

Common scams and crime involving crypto assetsThere is no doubt that criminals are in a very competitive business and with the advent of technology this is increasingly resulting in them abusing technology, including crypto assets and those investing in these assets. Despite the general public’s uncertainty about crypto assets such as Bitcoin, criminals have already cast their net into this digital world in an attempt to exploit new users. This means that crypto assets have also become a target for cybercrime in the form of phishing attacks and scams, invoice interception, fake accounts, whaling and exchange deposits.

In order to mitigate the risk for any form of phishing attack such as that one should always:• Check the browser address bar to verify that one is visiting the correct website address and not a fake site;• never click on links that are sent via e-mail;• never open attachments sent via e-mail if one is not 100% sure of its authenticity;• always use two-factor authentication on all �nancial transactions, including when dealing with crypto assets such as Bitcoin wallets; and• use a password manager programme to store passwords in an encrypted format (www.luno.com).

Furthermore, some of the scams which Luno has noted relating to crypto assets are the following:• Cloud mining scamsAccording to the information published on Luno’s website, the majority of cloud mining operations are suspicious since nobody who is mining Bitcoin can make pro�ts ranging between 10% and 30% per month as such scams are promising. Legitimate Bitcoin miners will be upfront that the pro�t margins on crypto asset mining are razor-thin which is why one has to avoid falling in the trap set by these scammers.

• Multi-level marketing scamsAnother tactic to watch out for is if a company is promoting its referral programme harder than its product. Such tactics bear the characteristics of Ponzi schemes where existing investors are most probably paid with new investors' deposits. Similarly, Bitcoin "doublers", or high yield investment programmes would try to convince investors that they have found a special or secret method to making incredible returns either by trading on behalf of or exploiting technical aspects of cryptocurrency. The truth is that no such method has been found and that their only skill is to try to con individuals out of their money.

Anyone who is considering buying or trading in crypto assets such as Bitcoin should, as with any investment, do proper research on which service provider to use and their track record. In future, and following the proposed legislative amendments, one should also enquire whether the company is registered with the FIC. In the meantime, one can look at the Safe List and the Bad List of service providers to use or to avoid on www.badbitcoin.org (www.luno.com).

In a further attempt to mitigate its risk, Luno, for example, does not allow cash deposits as a method of payment to open an account or buy Bitcoin. Neither does it allow third party access or usage. As is currently required in terms of the reporting of suspicious transactions, Luno is already working with the FIC by reporting on any suspicious Darknet marketplace activities which their systems �ag. Examples of illicit crypto transfers have been noted (not necessarily involving Luno clients) on gambling; child abuse and child pornography sites as well as for terrorist funding.

International perspectives on crypto assetsDuring the FIC workshop, a few examples of countries where trading in crypto assets has been banned were shared. These include:• In Morocco transactions of crypto assets constitute a violation of the exchange regulations and are subject to penalties and �nes.• India has banned crypto assets as a means of payment. Banks, lenders and other regulated �nancial institutions are not allowed to engage in virtual currency transactions or provide services for facilitating any person or entity in dealing with or settling in crypto.• China has banned all crypto asset-related activities such as the o�ering, buying, selling and exchange of �at/legal tender for crypto assets. The banking system is also not accepting any existing virtual assets or providing relevant services. Foreign crypto exchanges (service providers) are not allowed to do business with the Chinese market and to this extent websites related to crypto asset trade are blocked.• In the United Arab Emirates all transactions in crypto assets are prohibited and not approved by the central bank as a caution against money laundering issues.• Thailand has also placed a prohibition on �nancial institutions doing business involving crypto assets.

Crypto asset service providers extend a helping hand to law enforcersTwo of the crypto asset service providers who were present at the FIC workshop, namely AltCoinTrader and Luno, who have already worked with South African law enforcement, prosecuting agencies and the FIC in dealing with cases involving crypto assets, committed to continued working with law enforcement. AltCoinTrader indicated that they have a 24-hour fraud line available for use by both banks and law enforcement agencies which can be utilised to con�rm any suspicions about multiple deposits being made to buy crypto assets. Similarly, Luno indicated that they are able to assist with section 205 subpoenas depending on the type of information law enforcers required.

It is clear that a process to identify the beneficiaries in crypto asset transactions was urgently needed and that the industry should come up with a solution for this. Similar to the banking industry which is supporting law enforcement in various ways to fight money laundering and terrorist financing by reporting suspicious transactions, the time has come for crypto asset service providers to do the same. It has been heart-warming to hear about two of these, namely Luno and AltCoinTrader who are already doing their part and have already made valuable contributions in the fight against money laundering. Hopefully the rest of the industry will show the same willingness to support law enforcement’s efforts since the fight against cybercrime has only begun - it requires all hands on deck to fight a crime which does not have boundaries.

List of references

Cash Connect. 2019. "Will we see a spike in cash crime this long weekend?" - Media statement issued by Cash Connect dated 6 August 2019.Chokun, J. 2018. "What is a Bitcoin private key, how to use it, keep it safe!" 99 Bitcoins. 18 June. - Accessed at https://99bitcoins.com/ bitcoin-private-key-safe-how-use/ on 8 September 2019.Financial Stability Board. 2018. "Crypto-asset markets Potential channels for future �nancial stability implications." 10 October 2018. - Accessed at https://www.fsb.org/wp-content/ uploads/P101018.pdf on 5 September 2019.INTERPOL. 2018. "INTERPOL holds �rst DarkNet and Cryptocurrencies Working Group." 3 April. - Accessed at https://www.interpol.int/en/News-and-Events/News/2018/INTERPOL-holds-�rst-DarkNet-and-Crypto-currencies-Working-Group on 5 September 2019.Reinicke, C. 2019. "Bitcoin has become an unlikely safe haven as global turmoil has rocked markets. But not everyone thinks that's a good idea." Market Insider. 19 August. - Accessed at https://markets. businessinsider.com/currencies/news/bitcoin-safe-haven-asset-commentary-pros-cons-2019-8-1028457025 on 5 September 2019.

South African Revenue Service (SARS). 2018. "SARS'S stance on the tax treatment of cryptocurrencies." - Media statement issued by SARS dated 6 April 2018. Wieczner, J. 2019. "Bitcoin accounts for 95% of cryptocurrency crime, says analyst." Fortune. The ledger. Balancing the ledger. 24 April. - Accessed at https://fortune.com/2019/04/24/bitcoin-cryptocurrency-crime/ on 5 September 2019. Other referenceshttps://bitcoin.org/en/faq#general - Accessed on 5 September 2019.https://coinmarketcap.com/all/views/all/ - Accessed on 5 September 2019.https://www.luno.com/en/price#ETH - Accessed on 8 September 2019.https://www.luno.com/learn/en/article/how-do-i-keep-my-private-keys-safe - Accessed on 8 September 2019.https://www.luno.com/learn/en/article/how-do-i-keep-my-bitcoin-safe - Accessed on 8 September 2019.https://whatcurrency.net/world-�at-money-list/ - Accessed on 5 September 2019.

* This article was originally published in Servamus: October 2019 and is republished with the permission of Servamus's editor.

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Contact usChris de Beer Executive Manager Tel No: +27 12 663 1961 Cell No: 082 902 4667 Email: chrisdebeer@icfp.co.za

Madeleine du Preez Administrator Tel No: +27 12 663 0193 Email: membership@icfp.co.za

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