Case Study Spaza Spend (SS) is a registered Third Party Payment Provider (TPPP) and Authorised Dealers in Foreign Exchange with Limited Authority (ADLA) in South Africa. They facilitate domestic and international money transfers via their proprietary mobile platform. Users of the platform can deposit cash at a network of spaza shops on-boarded by Spaza Spend for this purpose and then transfer the funds utilising the Spaza Spend app. The platform is primarily used for personal remittances by foreign nationals working in South Africa. The deposited funds can also be utilised for bill payments or the purchase of vouchers, airtime or SIM cards. The executives of Spaza Spend recently became aware of allegations in the media of TPPPs facilitating terrorism financing by routing funds to high risk jurisdictions in Africa (included as Annexure A). You have been appointed as a consultant for Spaza Spend to advise them on several matters relating to financial crime risk management. Question 1 The CEO of Spaza Spend is aware of the fact that they, as a registered Accountable Institution in terms of the Financial Intelligence Centre Act (FICA), must apply a "risk-based approach" for purposes of financial crime risk management. However, she does not understand how they should go about performing the required client risk assessments, especially to mitigate the risk of facilitating financial flows relating to terrorism financing. Advise them on how a client risk assessment can be practically performed when a new business relationship is established with a client. Your guidance should include sufficient examples and high risk indicators applicable to their business so that it is easy to understand.