| 1. |
VASPs must maintain a system to ensure that accurate reconciliations of the Client Accounts are carried out daily. The reconciliation must include—
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a. |
a full list of individual client credit ledger balances, as recorded by the VASP; |
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b. |
a full list of individual client debit ledger balances, as recorded by the VASP; |
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c. |
a full list of outstanding lodgements; |
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d. |
a full list of Client Account cash book balances; and |
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e. |
formal statements from Third-Party Banks showing account balances as at the date of reconciliation.
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| 2. |
VASPs must—
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a. |
reconcile the individual credit ledger balances, Client Account cash book balances, and the Third-Party Bank Client Account balances; |
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b. |
check that the balance in the Client Accounts as at the close of business on the previous day was at least equal to the aggregate balance of individual credit ledger balances as at the close of business on the previous day; and |
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c. |
ensure that all shortfalls, excess balances and unresolved differences, other than differences arising solely as a result of timing differences between the accounting systems of the Third-Party Bank and the VASP, are investigated and, where applicable, corrective action taken as soon as possible, including where necessary using the VASP’s own funds.
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| 3. |
VASPs must perform the reconciliations in Rule IV.D.2 of this Compliance and Risk Management Rulebook on a daily basis. |
| 4. |
VASPs must ensure that the process of reconciliation does not give rise to a conflict of interest. |
| 5. |
VASPs must notify VARA where there has been a material discrepancy with the reconciliation which has not been rectified.
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