PwC's Academy - Standard operating procedures

Access the Standard Operating Procedures_________________________________________________________________________________________________________________________________

3. Client onboarding

3.1. Risk management procedures

Exit SOPs

Risk management procedures

For closed/client specific sessions, the following risk management procedures will come into effect at Step 3 as per above. The  training coordinator is responsible for triggering off the risk management procedures and for handling all the documentation except for the KYC which needs to be handled by SDC team

Client Acceptance Form - A specific Client Acceptance form for the Academy can be found on matrix and needs to be saved in Client folder drive under the client folder.

KYC | All courses with a course fee of Euro 15,000 or above will require a KYC .

AFS | If a client is listed on the CES, an electronic AFS has to be raised by clicking the button on CES system. For threats and safeguards for analysis go to matrisk and get recent client services training SOPS.

Also check tab of 'restrictions'. If it states ' EU non -audit services restrictions apply  or This entity is a downstream and controlled by a PIE audit client' or is a PIE, you need audit committee approval. This could take the shape of a pre-approved catalogue of services, email (copying in other members of the Audit Committee,evidence through AC meeting. This approval needs to be downloaded and attached within the AFS.

If a client is an audit client and not listed on CES, an email is sent to the audit partner (using the email template found on matrix)

LOE | A LoE together with the terms of business is sent in all circumstances and its signed copy saved in the Client folder

NB: Open courses (including e-learns) are exempt from providing for risk management procedures as follows:

Client Acceptance Form - n/a

KYC | All open courses with a course fee of Euro 15k or above will require a KYC (we currently have no courses being offered with such fees)

AFS | N/A based on the fact that training is being offered as a public nature and not client specific . This means there is no risk of a conflict of interest.

LoE | No LoE required

As at 13/9/2019 PwC Network is coming up with the KYC minimum requirements for all the territories. They are setting up the policies and procedures that every Firm needs to follow. The policy is still in the draft form and consultation is taking place. The policy shall be applicable to all PwC Network to all service offerings. However, we discussed that internally with Lucienne as well and we will try to opt for an exemption to carry out due diligence on the customers of PwC Academy and Tech - this is still not confirmed but that would be the goal. 

The initial feedback from the queries raised from the community was with regards to the Offering Definition and explanation and proposed amendments to be implemented by the Network are as follows:

With regards to the sale of apps or reference material-type products through some form of shop/store (e.g. a online sales portal or app store), the sale/purchase transaction is instantaneous, and the firm has little control on who the consumer may be. The relationship with the customer in these circumstances does not have an element of duration and therefore these may be considered to be out of scope for the MRs (KYC Minimum Requirements).

With regards the sale of other online products that do not have any element of service but that have a longer sales/contracting stage than store-type sales, then these may also be considered out of scope for the MRs. However, it is suggested that sanctions screening of the customer should be conducted as a minimum.

All other products and services should be subject to the Proposed KYC MRs.

It is expected that detailed additional guidance will be created to assist with the treatment of specific types of Offerings in line with the definition of a Business Relationship; however, we propose adding the following wording to the Business Relationship definition: 

Proposed  wording: "The sale of apps or reference material-type products through some form of shop/store (e.g. a online sales portal or app store) does not create a relationship with the customer that has any element of duration, and therefore may be considered to be out of scope of these KYC Minimum Requirements."

As mentioned, this requirements are not in place yet, this is still in the consultation form. From the regulatory (EU and Maltese legislation)  perspective, PwC Academy is out of scope when it comes to the KYC Regulation as it does not meet a definition of the subject person, to which such Regulation is applicable to.