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The Financial Transactions Reporting Act applies to accountants when providing services for clients relating to:

  1. trusts or companies such as providing a registered office or business address or acting as a director, secretary or trustee of the entity;
  2. buying or selling real estate;
  3. managing client money, securities or other assets;
  4. managing bank, saving or securities accounts;
  5. organizing contributions for the creation, operation or management of companies;
  6. creating, operating or managing legal persons or legal arrangements (including trusts, partnerships, companies and unincorporated associations) and
  7. buying and selling business entities;

Accountants are also covered under the FTR Act in their capacity as auditors of a covered financial institution.

Your key obligations under this Act are as follows:

  1. Identify and verify your clients;
  2. Monitor your clients transactions;
  3. Maintain proper clients records;
  4. Report transactions to the Financial Intelligence Unit;
  5. Implement appropriate internal controls and systems to protect your business from being used for money laundering and terrorist financing purposes.

Client Identification and Verification

You must undertake specific procedures to identify your clients. You must also ensure that accounts are opened and maintained in the true name of the client.

For further guidelines refer to

Monitor your Clients transactions

You must scrutinize or monitor your client's transactions to ensure that the transactions being conducted are consistent with your knowledge of the client and his or her background.

For further guidelines refer to: 
Guideline 1 of 26 October 2007 – Suspicious Transactions


Maintain proper Clients records

You must establish and maintain records of your clients' identity, transactions and records of all reports of transactions made to the FIU. Any enquiries made to your firm by the FIU and other law enforcement agency must also be recorded.

For further guidelines refer to Policy Advisory 7/2007- Record Keeping

Report transactions to the Financial Intelligence Unit

You must report the following types of transactions to the FIU:

  • All Cash transactions of $10,000 or more including equivalent amounts in foreign currency. "Cash" includes currency, bank drafts, bank cheques, bearer bonds, traveller's cheques, postal notes and money orders.
  • All Suspicious transactions including transactions or attempted transactions for which satisfactory evidence of identity was not obtained from the client.
  • All Suspicious transactions noted during your external or internal audit of another covered financial institution or business.

Terrorist Property

If you have in your possession or your control any property which is owned or is controlled by a terrorist or terrorist group or if you have information on a transaction or proposed transaction relating to a terrorist property, you must report this information to the FIU.

For further guidelines refer to: 
Guideline 2 of 26 October 2007 - Reporting a Suspicious Transaction by Paper
Guideline 3 of 22 May 2009 - Reporting Cash Transactions of $10,000 or above by Paper


Internal controls and systems

Other measures that your firm must implement are:

  • Develop and implement internal policies and procedures to comply with the FTR Act.
  • Appoint a "Compliance Officer" to be responsible for ensuring compliance with the FTR Act and Regulations.
  • Regularly review your compliance with your internal anti money laundering and terrorist financing polices and procedures.
  • Implement adequate recruitment procedures to screen potential employees.
  • Have regular training for staff on anti-money laundering and terrorist financing issues and legislative requirements.
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