FIC Guidance

Interpreting Draft FIC Guidance Note 7A and Draft Public Compliance Communication 114

The Financial Intelligence Centre (FIC) has called for comments from accountable and reporting institutions, supervisory bodies and other persons on the draft Guidance Note 7A (draft GN7A) Chapter 4 and draft Public Compliance Communication 114 (draft PCC 114).

This article serves as an interpretive note to both the above documents providing some insight as to the expectation of the FIC based on the current draft documents. Both of these documents will still need to be finalised once comments have been received.

The amendments in Draft GN7A relate only to Chapter 4 regarding the aspect relating to the Risk Management and Compliance Program (RMCP).

It must be noted that PCC 114 is applicable to Designated Non-Financial Businesses and Professions (DNFBP) and not to larger Accountable Institutions (AI’s) having advanced compliance structures. However, the principles contained in the PCC may be applied and expanded upon by larger AI’s.

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