INTERNATIONAL & OFFSHORE BANKING MASTERS PROGRAM

(NQF Level 9)

The Institute of Advanced Studies (Pty) Ltd

in association with

The Da Vinci Institute

for Technology Management (Pty) Ltd

offer a

Masters Program on

INTERNATIONAL & OFFSHORE BANKING International and Offshore Banking: Masters Program

INTERNATIONAL AND OFFSHORE BANKING PROGRAM SYNOPSIS

Offshore Banking and Private Banking

A considerable volume of international banking takes place offshore, and many of the world’s major banks have banking and trust company operations in one or more International Offshore Financial Centers (IOFCs).

Most IOFC jurisdictions have enacted legislative provisions and set up administrative authorities whose function is to control banking and trust company activities.

Banking services offered in the tax IOFCs are of different types:

- The commercial banks offer full commercial and retail facilities to both residents and non-residents of the jurisdictions where they are located. These banks usually provide an extremely wide range of services through their network of branches, their ability to move funds swiftly, and their expertise in handling international transactions.

- Representative offices in IOFC jurisdictions offer a more limited range of services than do the commercial banks; however, they do normally handle currency transactions, deposits, and the issue of letters of credit. Representative offices of banks located elsewhere are usually licensed as non-resident banks.

- Non-resident banks are licensed to serve only those clients who reside outside the tax haven jurisdiction or to transact business of a non-local character. The precise terminology and the limitations may vary according to the jurisdiction in question.

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Switzerland is the unquestioned leader of the world’s offshore private banking industry. London, Switzerland’s nearest competitor, manages less than half as much as the combined totals of Zurich, Geneva, and Lugano, Switzerland’s three main private banking centres. Switzerland’s share of the world private banking market is estimated to be in the range of 30-40%. Approximately two-thirds of this amount belongs to private clients, the majority of whom reside outside Switzerland.

Private banking, unlike global investment banking, is one area where Swiss banks have always been market leaders. Now, predictably, private banking activities have become a focus not only of Swiss banks themselves but also of many foreign banks carrying on activities in Switzerland. Private banks are concentrating more on investment advice and portfolio management, and less on trading and investment banking, due to the lower risks and higher returns that can be generated. Private bankers, in the true sense of the term, are entrepreneurs in a privately owned sector, who carry out their business using their own assets, assuming unlimited liability with their entire commercial and private fortunes, and exercising independent powers of decision. The core activity of such private bankers traditionally has been and still is asset management for private clients.

Private banking is not only performed by private bankers. Many former private bankers have converted their partnerships into private or publicly traded corporations in order to have limited liability and to be able to benefit from financing opportunities on the capital markets. In the past few years, the activities of many private banks have been extended to the management of assets for national and international institutional investors. This new class of client is very attractive for the banks because of the accumulated savings and potential market they represent.

Institutional clients tend to be very demanding in respect to the performance of their portfolios, and they benchmark performance on a regular basis. Due to the

Page 3 of 30 International and Offshore Banking: Masters Short Program high volume of business they represent, institutional investors are putting substantial pressure on private banks’ fee structures and forcing them to enhance their technical expertise.

Private banks are also becoming active on the stock exchanges and many of them are also involved in underwriting and placement. In addition to catering to institutional investors, private banks are now establishing investment funds. The investment fund business has attracted new clients to private banks who either wish to invest in very specialised funds or whose assets are not substantial enough to justify the structuring of individualised portfolios.

Offshore banks are generally considered to offer protection against risks of expropriation or corruption in the home jurisdiction. Many offshore banks offer services that may be unavailable in the country of residence, and some offshore banks may provide higher interest rates than banks in the home country.

Panama, which is even smaller that Switzerland, has more than 150 international banks providing offshore services to customers worldwide. Singapore too is one of the world's leading offshore banking centres, associated with high security, stability and reliability. Singapore offshore bank accounts have an excellent image, have passed through strict customer due diligence requirements.

Other jurisdictions engaged in the offshore banking business include: Andorra, Anguilla, Aruba, Austria, Bahamas, Bahrain, Belize, British Virgin Islands, Brunei, Cayman Islands, Cyprus, Denmark, Dubai, Gibraltar, Guernsey, Hong Kong, Ireland, Isle of Man, Jersey, Labuan, Latvia, Liechtenstein, Luxembourg, Macao, Mauritius, Seychelles, Vanuatu.

Captive Banks

The term captive bank is sometimes used to refer to a banking subsidiary set up in an IOFC tax haven or financial centre that operates principally for the benefit of the

Page 4 of 30 International and Offshore Banking: Masters Short Program members of a multinational group and their customers and suppliers. Such captive banks may also operate as merchant banks and offer commercial banking as well as financing services.

Banking Secrecy

In most countries, one of the terms of the relationship between banker and customer is that the banker will keep the customer’s affairs secret. Staff members are normally required to sign a declaration of secrecy concerning the business of the banks. If numbered accounts are used, their purpose is to limit the number of persons who know the identity of the client.

In certain countries, specific legislation makes breaches of bank secrecy subject to criminal law sanctions. However, in all legal systems (including Switzerland), there are specific cases in which the duty of secrecy of a banker is discharged. Furthermore, the current attacks being waged worldwide against money laundering have resulted in significant restrictions and controls on banking secrecy. The level of secrecy in the Swiss banking industry is now not much different than most developed countries. In fact, it is arguable that Swiss “know-your-customer” rules are much stricter than elsewhere.

The Swiss banks have become more responsive to foreign requests to block questionable funds in Swiss banks. Furthermore, the negative publicity that has resulted from the past Swiss tradition of banking secrecy is now turning from an asset into a liability. The exchange of information clause contained in most tax treaties may enable the tax administration of one treaty country to obtain information concerning bank accounts that its residents have in the other country.

In a major new development, the worldwide attack on money laundering is creating very considerable pressure towards more open access to banking information.

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Back-to-Back Loans

Back-to-back loans are matching deposit arrangements. They may be used to solve a financing or exchange control problem. In the case of certain IOFCs with tax treaties, the function of back-to-back loans is to reduce the taxable base subject to withholding taxes on interest payments, by interposing an intermediary subsidiary company between the source of the income and the recipient. For example, an intermediary company located in the Netherlands or the Netherlands Antilles may be interposed to take advantage of a favourable tax treaty. In such cases, the authorities usually require a certain spread or “turn” on the rates to create a small profit that is subject to tax locally.

This type of transaction involves the prospective lender placing funds or securities on deposit with a bank operating in the lender’s own country or elsewhere, while an associate of that bank (or the same bank) operating locally or in that other country lends an equivalent amount to an associate of the lender in another country. It is an arrangement for the avoidance or reduction of withholding tax on interest paid to a recipient in a foreign country and/or of exchange controls on the remittance of funds outside the borrower’s country.

The advantage of using an IOFC as a location for the initial deposit is that the interest received on the bank deposit will be paid free of tax or at a reduced rate. In the country of the back-to-back loan, the loan interest should be designed to be an allowable tax deduction. This structure may be utilised in financing structures for the purchase of property in high tax jurisdictions. It is also used to route money from IOFC jurisdictions to high tax countries, without the use of conduit vehicles using tax treaty structures.

International Tax Planning Services by Offshore Banks

A high percentage of clients and customers of offshore financial institutions require tax advice that may involve international tax planning, double taxation agreements

Page 6 of 30 International and Offshore Banking: Masters Short Program and withholding taxes, offshore financial centres, international taxation of trusts, estates, inheritances and gifts, and international anti-avoidance.

It is both lawful and sensible for an offshore bank to arrange customers’ business and personal affairs in such a way as to attract the lowest possible incidence of tax. The widening scope of tax laws, the complexity of their provisions, and high tax rates make it more necessary than ever for business enterprises and individuals alike to plan their taxable events with considerable care.

For an offshore bank’s customer which is a commercial or industrial enterprise, an unnecessarily increased tax burden represents a business waste that not only reduces its distributable profits but may well make it uncompetitive.

In the case of an individual client of an offshore bank, the net return from personal endeavour and the investment of capital is in most countries so severely reduced by the Revenue that the failure to take advantage of potential tax minimisation benefits may have a considerable effect on his spending power and accumulated wealth. The omission to anticipate death duties and inheritance taxes will frequently cut an unnecessarily deep wedge into his estate.

Offshore tax planning is tax planning in which factors involving more than one country are included in the original database and an offshore element is introduced as an extension of domestic tax planning. The different ways in which two or more systems may be linked offer considerable scope for tax minimisation or deferral, particularly where at least one of the countries is offshore, since offshore does, by its very nature, generally refer to a better tax deal in a foreign country. On the other hand, where a project crosses frontiers, there are far more tax and non-tax factors to be taken into account than in a purely domestic case. It follows that offshore tax planning may often be exceedingly complex.

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Trust Services by Offshore Banks

International and offshore banks perform a major role in the setting up and administration of trusts.

The word “trust” refers to the duty or aggregate accumulation of obligations that rest upon a person described as a trustee. The responsibilities are in relation to property held by it or under its control. The trustee is obliged to administer the trust property in the manner lawfully prescribed by the trust instrument (trust deed or settlement), or in the absence of specific provision, in accordance with equitable principles or statute law. The administration will thus be in such a manner that the consequential benefits and advantages accrue, not to the trustee, but to the beneficiaries.

The English trust is merely a bundle of rights and obligations in equity and is thus not strictly speaking a legal entity. Though the law of trusts varies from system to system, those patterned on the English law of trusts resemble one another closely, differences usually being of statutory origin. In the case of civil law systems where the trust is to be found it is invariably a creature of statute.

The trustees stand in a fiduciary relation and must hold the property or exercise the rights in a fiduciary capacity.

The courts have over the centuries greatly elaborated principles laying down the rights, powers, and duties of trustees. In particular, high standards have always been demanded of trustees in respect of care for the trust estate, careful investment, strict accounting, fair apportionment between income and capital, duty to pay the right beneficiaries, and absence of personal profit or self-interest, and trustees have frequently been held liable to repay to the trust losses caused by lack of care or other breach of trust. Trust property can be recovered from a third party who has obtained it unless he obtained a legal title, for valuable consideration, and without notice that his acquisition was in breach of trust.

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A trustee must accept or disclaim office, and persons may be authorized to appoint new trustees, or the court may do so. A trustee may retire but remains liable for things done while he was a trustee, or may be removed by the court. A trustee must not make use of trust property for his private advantage and must account for profit made out of his trust. As a general rule, in the absence of a provision relating to remuneration, a trustee is not entitled to any remuneration. Also, in many cases, the trustee would not be empowered to acquire trust property, and dealings with beneficiaries may be voidable.

The trustees’ duties are: - to take possession of and preserve the trust property; - to be diligent and prudent in administering the trust property; - to act personally; - to be impartial as between beneficiaries; - to keep accounts; - to give information to the beneficiaries as required; and - to invest the trust funds in the manner permitted by statute.

If in doubt, trustees are entitled to obtain the opinion of the court as to the right course of action, and they may have specific questions determined by the court. The courts now have wide powers to approve arrangements varying or revoking the trusts or enlarging the powers of the trustees.

A breach of trust is any act in contravention or excess of the duties imposed on the trustees by the trust, including neglects, omissions, and dishonesty, and trustees are liable in so far as loss has resulted to the trust estate. They may be relieved from liability by provision in the trust deed, or by the court under statutory power. Beneficiaries can obtain no relief against trustees if they concurred or acquiesced in the breach of trust.

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There is no generally accepted definition of the word “settlement” but it may be defined as any disposition of property, of whatever nature, by any instrument or number of instruments, whereby trusts are constituted for the purpose of regulating the enjoyment of the settled property successively among the persons or classes of persons nominated by the settlor. However, for certain tax purposes the word “settlement” is given a much wider meaning.

The trust services of offshore banks include also the setting up and administration of certain alternative vehicles to the offshore trust.

The demand for offshore and onshore structures to provide legal mechanisms for the defense of family property is colossal. In the past decades, the preferred vehicle has been the so-called asset protection trust. The massive increase in the use of offshore trusts over the past 50 years, often in jurisdictions with either no, or inadequate, trust law, has led to a corresponding explosion in litigation. In recent years there has been a succession of decisions which have raised large question marks over the future use of offshore trusts as assumptions that have been made for years have been overturned.

In the result, difficulties are now being encountered in the use of offshore trusts. In the first instance, the trust has, at its heart, a number of essential fundamentals that clients frequently refuse to accept as part of the trust relationship. For example, there is a fundamental requirement that the trustee should take full legal ownership and control of the assets. Many a client seeking an asset protection vehicle is horrified to find that he loses control of his hard-earned assets to some foreigner in a remote jurisdiction, who could, in strict law, take decisions entirely independently of him.

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Then, devices such as letters of wishes (letters of intent), trustees’ file notes, and special functions of the protector, are coming increasingly under attack as being nothing more than an extension of settlor control. Reporting requirements for settlors of offshore has made life very much more difficult for overseas trustees.

The duties and responsibilities of trustees have always been onerous. In the last few years, a number of important court decisions have considerably increased their exposure. Combining this with the fact that, by definition, the asset protection trust is operating in an area where litigants are trigger happy, overseas trustees are now very concerned at the potential risks, and finding it almost impossible to obtain insurance cover. Where the settlor (or grantor) retains control over the “trust” (whether directly or through a protector) the product may sometimes not constitute a trust as the law of equity understands it. It is in legal terms an agency arrangement, or perhaps a bailment, and entirely different legal rules apply.

There has arisen a need for new forms of vehicles which will be safer and more efficient in their application than the offshore trust, and cheaper to administer than the offshore trust. The most common of these are the following:  Limited liability companies  Companies limited by guarantee  Contractual arrangements, such as an option or an agency  Contractual relationships relating to possession, such as bailment  Offshore variable life insurance policies  The single premium “whole of life” policy  The executive investment bond

Money Laundering

Money laundering is an evolving and ubiquitous activity, which knows no frontiers. It follows that, in order to be effective, any action to combat money laundering

Page 11 of 30 International and Offshore Banking: Masters Short Program must rely on effective cooperation between experts from a wide range of disciplines: legal and judicial, financial and regulatory, and law enforcement.

Combating the scourge of money laundering is a significant challenge to all participants in the financial products and services industries. Criminals are extremely cunning and are always devising new methodologies to launder the proceeds of their crimes.

The main issues of concern include:

 the vulnerabilities of Internet banking;

 the increasing reach of alternative remittance systems;

 the role of company formation agents and their services; and

 international trade-related activities as a cover for money laundering.

Individual compliance and corporate compliance play a critical role against the background of government and multilateral anti-money laundering controls.

International Anti-Money Laundering

Quite aside the plethora of statutes imposing severe sanctions for breaches of compliance, the establishment, implementation and growth of the compliance culture is one of the most critical elements of a successful business. Compliance plays an essential role in any company that is concerned about risk exposure.

The leadership in the world’s battle against money laundering has been entrusted to the Financial Action Task Force on Money Laundering (FATF). The FATF is assisted by a number of trans-national agencies.

The principal of these trans-national agencies, supporting the work of the FATF in its anti-money laundering crusade, include:

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 Asia/Pacific Group on Money Laundering (APG)  Caribbean Financial Action Task Force (CFATF)  Council of Europe; the Commonwealth Secretariat  European Bank for Reconstruction and Development  International Monetary Fund (IMF)  Inter-American Development Bank (IDB)  Interpol  International Organisation of Securities Commissions (IOSCO)  Offshore Group of Banking Supervisors (OGBS)  United Nations  World Bank  World Customs Organisation (WCO).

Criminalization of money laundering is the cornerstone of anti-money laundering policy. It is also the indispensable basis for participation in international judicial co- operation in this area. Hence, failure to criminalize laundering of the proceeds from serious crimes is regarded as a serious obstacle to international co-operation in the international fight against money laundering.

South African Anti-Money Laundering and Financial Compliance Legislation

The wide-reaching range of anti-money laundering provisions derive principally from:

 Banks Act 94 of 1990 and Regulations published thereunder, which oblige banks to establish an independent compliance function as part of their risk management framework  Prevention of Organised Crime Act 121 of 1998 (POCA) and the Regulations published thereunder  Financial Intelligence Centre Act 38 of 2001(FICA) and the Regulations published in R1595 in GG 24176 of 20 December 2002. These regulations are divided into six chapters, namely: Establishment and verification of identity;

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Record keeping; Client profile; Reporting of suspicious and unusual transactions; Internal rules; and Miscellaneous  Electronic Communications and Transactions Act 25 of 2002  Financial Advisory and Investment Services Act 37 of 2002  Terrorism Act (Protection of Constitutional Democracy against Terrorist and Related Activities Act) Act 33 of 2004

Compliance by Banks

The term “compliance”, as its name denotes, refers to the specific area of business practice that deals with the adherence to the laws of the jurisdiction or jurisdictions in which the business operates. Compliance is a necessary consequence of any legislation governing the operation of business and, as such, compliance is by no means a new field. However, in the wake of the recent exponential increase in such legislation around the world, the compliance field is one that has become far broader in its application and far more demanding to all its practitioners.

Quite aside from the plethora of statutes imposing severe sanctions for breaches of compliance, the establishment, implementation and growth of a compliance culture is one of the most critical elements of a successful business. Compliance is inextricably linked with corporate governance, and it is the responsibility of directors of a bank to see to it that the bank is fully compliant with all laws at all times. Again, this is more than just avoiding the consequences of non-compliance – compliance is good business practice in and of itself for a bank to be fully compliant.

The compliance function of a bank or any other business is essentially a particular element of the bank’s normal and overall risk management program.

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International and Offshore Banking Framework

Module Learning Outcomes

After completing this module, participants should be able to advise and assist clients and customers with the following:  Commercial and retail banking facilities  Trust facilities  Currency transactions  Deposits  Letters of credit  Representative offices in IOFC jurisdictions International &  Non-resident banks Offshore Banking  Merchant banks Services  Banking subsidiaries in IOFCs and financial centres  Bear and bull markets  Bid / offer spreads  Bonds  Bottoms-up  Derivatives  Distribution funds  Endowment assurance  Fixed interest  Futures  Gearing

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 Gilt  Hedge  Internet services  Life assurance  Managed currency funds  Money funds  Money markets  Mutual funds  Options  Personal portfolio bonds  Portfolio management services  Price / earnings ratios  Roll-up funds  Sicavs International &  Single premium structures Offshore Banking  Top-down Services  Traded endowment policies (cont)  Ucits  Umbrella funds  Unit linking  Warrants  Zero-coupon bonds

After completing this module, participants should be able to advise and assist clients and customers with the following:  Private banking Private Banking  Offshore branches of private banks  Offshore offices of private banks

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 Private banking in Switzerland and London  Private banking and the new rich  The A – Z of expat finance Private Banking  Explain the concept of virtual banking (cont)

After completing this module, participants should be able to advise and assist clients and customers with the following:  Understand how to adapt and react to new Offshore Banking in developments Transformation  Invent new offshore banking solutions  Explain captive banks  Discuss special purpose vehicles (SPVs)  Describe the various financing services  Consolidation  Shift towards onshore banking

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After completing this module, participants should be able to advise and assist clients and customers with the following:  The relationship between banker and customer  The declaration of secrecy  Numbered accounts  The impact of breaches of bank secrecy and the criminal law  Specific cases where duty of secrecy are discharged Banking Secrecy  The “Know-your-customer” rules  Foreign requests to block questionable funds  Exchange of information clauses in tax treaties  Financial Action Task Force (FATF) and the worldwide attack on money laundering  The pressure towards more open access to banking information  Exchange controls, restrictions and regulations  The Financial Intelligence Centre Act (FICA)  The Prevention of Organised Crime Act (POCA)

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After completing this module, participants should be able to advise and assist clients and customers with the following:  Matching deposit arrangements used in solving financing or exchange control problems  The reduction of the taxable base  Withholding taxes on interest payments  The interposition of intermediary subsidiary company Back-to-Back Loans  The intermediary interposed between source of income and recipient  Favourable tax treaties of Netherlands / Netherlands Antilles  The required spread / turn on interest rates  Domestic tax  Allowable tax deductions  Financing structures  Routing money from IOFC jurisdictions to high tax countries

After completing this module, participants should be able to advise and assist clients and customers with the

Tax Planning following: Services by Offshore  International tax planning Banks  Double taxation agreements and withholding taxes  Offshore financial centers  International taxation of trusts  International taxation of estates, inheritances & gifts  International anti-avoidance  Individual and corporate income taxes

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 Capital gains taxes  Special taxes on dividends, interest, and royalties  Withholding taxes  Capital taxes (e.g., property, patrimony, net worth taxes, etc.) imposed on individuals and companies  Payroll taxes  Company duties  Business taxes, business license & other trade taxes  Stamp duties  Transfer duties  Registration duties  Customs duties and other import and export duties  Sales and use taxes  Turnover taxes on value added

Tax Planning  Capital transfer taxes Services by Offshore  Estate, inheritance & gift taxes Banks  Residence, ordinary residence & domicile (cont)  Citizenship (nationality)  Beneficial ownership  Place of incorporation and location of registered office  Place of management and control  Creation of a trust, the applicable law, residence of the trustees or beneficiaries  Centre of economic interests  Permanent establishment  Effectively connected income  Real or deemed source

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After completing this module, participants should be able to advise and assist clients and customers with the following:  Setting up and administration of offshore trusts  Understanding the responsibilities in relation to trust property  Discussing consequential benefits and advantages accruing to beneficiaries  Considering the responsibilities of trustees standing in a fiduciary relation  Explaining the rights, powers, and duties of trustees  Discussing the high standards demanded of trustees Trust Services by  Caring for the trust funds and the trust estate Offshore Banks  Explaining fair apportionment between income and capital  Discussing absence of personal profit or self-interest  Explaining breach of trust and powers of the courts  Letters of wishes (letters of intent)  Special functions of the protector  Settlement  Limited liability company  Company limited by guarantee  Offshore variable life insurance policy  Single premium “whole of life” policy  Executive investment bond

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After completing this module, participants should be able to understand and navigate the following:  How money laundering works  Anti-money laundering  Money laundering activities  Cash and retail banking services  Money service businesses  Investment banking and securities sector Anti-Money  Insurance and personal investment products Laundering Controls  Trading companies and other business activities and Financial  Non-financial sector services Compliance  Trade in diamonds, gold and other precious metals  Terrorist funding  Lawyers, accountants and other intermediaries  Financial compliance  Compliance as preventive law  Developing solutions to the compliance problem  Unsuccessful compliance measures  Financial Action Task Force on money laundering (FATF)

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JOINT MASTERS DEGREE (NQF Level 9) PROGRAM OF DA VINCI INSTITUTE AND INSTITUTE OF ADVANCED STUDIES

DA VINCI INSTITUTE FOR TECHNOLOGY MANAGEMENT MASTERS PROGRAM

Purpose

The Da Vinci Institute of Technology Management provides a structured International & Offshore Banking program that has credit carrying components and can lead towards a Masters (NQF 9) in the Management of Technology and Innovation (potentially 108 credits). The full Masters program provides for 240 credits at exit Level 9.

A further purpose of this program is to produce leaders who are equipped to initiate socio-economic transformation in South Africa and abroad in these specialist fields. This should contribute towards the development of individuals, organisations and the community, and equip them to deal with challenges related to the management of technology, international tax planning, the management of innovation, the management of people and systems thinking.

Objectives

The Learning Program is specifically designed to enable participants to realize their true potential by:  Developing them to lead multi-discipline teams tasked to facilitate business success and socio-economic transformation

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 Acquiring the competence to lead a system (resources) and to develop technology and innovation related activities to meet their professional and business objectives  Providing personal development opportunities for them to contribute significantly to the development of wealth within the South African economy.

Program Level Descriptors

At the Masters Program Level, Da Vinci provides a structured learning environment within which students develop the capacity to:  Operate in variable and unfamiliar learning contexts, requiring responsibility and initiative  Accurately self-evaluate, identify and address their own learning needs  Interact effectively within a professional as well as within a learning group.

Within this contextual environment, while we expect far more integration, we still require that students translate their theoretical understanding of the specific subject matter into demonstrated application back at the workplace such that they show their ability to:  Integrate a well-rounded and systematic knowledge base in one or more disciplines or fields  Provide detailed knowledge and understanding of specialist areas  Develop a coherent and critical understanding of: o Advanced concepts, principles and theories o Conceptual thinking around the discipline or field o An ability to map new knowledge onto a given body of theory o An acceptance of a multiplicity of “right”, even “possible” answers  Effectively select and apply: o The central methods of enquiry and research in a discipline or field

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o The essential procedures, operations and techniques of a discipline or field, and o A knowledge of at least one other discipline or field’s mode of enquiry  Deal with unfamiliar concrete and abstract problems and issues using evidence-based solutions and theory-driven arguments  Display well-developed information processing: o Information retrieval skills o Critical analysis and synthesis of data o Quantitative and qualitative methodologies o Data presentation skills following prescribed formats o Using IT skills appropriately  Present and communicate both information and their own ideas and opinions in well-structured arguments: o Showing awareness of audience, and o Using academic or professional discourse appropriately.

The Masters Program requires integration, often across functions and very definitely systemically within functions. The theories are applied cross-functionally in the workplace and the integration of the system as a whole becomes important. Processes are designed to meet specific requirements and students work at a fairly high conceptual level before translating theory into action. They work actively through groups and develop solutions rather than solve problems. Problem solving is non-linear, often chaotic and integrates sometimes obscure and abstract theories but solution processes are designed to meet constantly changing needs.

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Access

Appropriate Previous Work Employer Academic Conditions Experience Support Qualifications (years) Diploma MOTI Level 6 5 General or 1 Any other relevant NQF 8 qualification 3 General

Provisional approval on the following conditions:  Demonstrate an understanding at NQF Level 8 (appropriate level descriptors will be used to guide the process).  evidence of relevant publications, presentations or relevant working experience that could be considered for recognition of prior learning at NQF Level None, or not 9* Detailed 2 equivalent to NQF 7  Registration for the Research Workshops Assessment 8 qualification  Acceptance of a Research Proposal  Completion of the first three modules

On successful completion of the above, provisional approval will be converted to full approval.

In the event that a student is unsuccessful in completing the above, such student will be de-registered for the relevant program.

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International and Offshore Banking Competencies – Masters Program

International and Offshore Banking: CREDITS

International & Offshore Banking Services 12

Private Banking 8

Offshore Banking in Transformation 8

Banking Secrecy 8

Back-to-Back Loans 4

International Tax Planning & Offshore Trusts Services 12 Anti-Money Laundering Controls and Financial Compliance 8

Total Credits 60

SYSTEMS AND FOUNDATIONAL COMPETENCIES (30 credits)

(SOS) Self, Other and Social Contexts (10 credits)

(PCD) Problem Solving, Creative Thinking and Decision Making (6 credits) (PWP) Professional Writing and Presentation (2 credits) The PWP assignment is compulsory to pass the PCD component (MSW) Managing the Systems Way (12 credits)

DA VINCI CORE COMPETENCIES (30 credits) (MOP) Management of (MOI) Management of (MOT) Management of People (8 credits + 2 Innovation (10 credits) Technology (10 credits) credits) (MLC) Management and Leadership Competencies Final (2 credits) The MLC assignment is compulsory to pass the MOP component

Total Credits = 60 credits

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DISSERTATION – RESEARCH CURRICULUM CREDITS

Integrated International and Offshore Banking 48

(ELA) Exit Level Integration Assignment. 10

Dissertation 62 Total Credits awarded towards 120 Dissertation

Research Project CREDITS

Integrated International and Offshore Banking Research 48 Project

Total Credits awarded towards Masters Qualification 108

Program Structure

Students who successfully complete the Post Module Assignments and Research Project for the International & Offshore Banking component will receive 108 credits towards a Masters in the Management of Technology and Innovation (MOTI). On successful completion of the program students receive an exit level certificate at a formal graduation ceremony.

Successful candidates may elect to complete the full 240 credit Da Vinci Masters in the Management of Technology and Innovation (MOTI) in the domain and qualification of International & Offshore Banking.

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INSTITUTE OF ADVANCED STUDIES

Strategic Vision and Mission

The vision of the Institute is to create learning and training opportunities globally for accountants, attorneys, tax practitioners, financial planners, bankers, and other professionals, as well as business executives, in the fields of International & Offshore Banking.

By applying the case study method to the structuring of international tax plans (that respect the letter and the spirit of the law), the Institute gives to students an incomparable training by any world standards.

It is the mission of the Institute to maintain its position as the world’s principal educational authority in the field of international tax planning.

The Institute, together with Da Vinci, aim to be renowned for the quality of its courses, teaching, and administration, and to create the world’s benchmark training in this highly specialised field.

Objectives and Goals of the Masters Program

The Masters Program offers training of a world-class nature in the multi-billion dollar industry of international tax planning and offshore financial centers, without the geographical and professional limitations affecting many national professional qualifications.

The Program is specifically designed: • to equip the student to deal with all aspects of international tax planning and offshore structuring

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• to give the student hands-on knowledge of correct procedures in dealing with offshore operations which account for more than half of the world’s international transactions measured in money • to ensure that the student achieves practical, as well as theoretical, mastery over this complex discipline.

Background Information on Executive Programs The Institute of Advanced Studies has been engaged in offering courses on International Taxation and Offshore Banking since 1980, teaching many thousands of professionals and business executives, as well as Revenue officials, throughout the world.

Venues include: Amsterdam • Atlanta • Baltimore • Boston • Brussels • Cape Town • Chicago • Dallas • Denver • Durban • Edinburgh • Frankfurt • Geneva • Hong Kong • Houston • Johannesburg • Kuala Lumpur • Lisbon • London • Los Angeles • Madrid • Manchester • Melbourne • Miami • Milan • Minnesota-St Paul • New Orleans • New York • Oklahoma City • Paris • Perth • Phoenix • Reno • San Francisco • San Diego • Seattle • Singapore • Sydney • Tulsa • Washington • Zurich

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