FICA Comments on the draft Guidance Note 7A Chapter 4 (RMCP) and draft Public Compliance Communication 114 due 2 May 2022
The Financial Intelligence Centre (FIC) has called for comment by 2 May 2022 on:
Draft Guidance Note 7A (draft GN 7A)
Chapter 4 replaces the earlier GN 7 in respect of the formulation and recordal of the Risk Management and Compliance Programme (RMCP), which has been misapplied in practice reflecting a fragmented and unintegrated representation of the RMCP, which often does not exist in one single comprehensive, readily identifiable and accessible document. Accordingly, the expectation is expressed that there be an Apex RMCP document in terms of section 42 of the FIC Act.
Draft Public Compliance Communication 114 (draft PCC 114) discusses the drafting of an RMCP in detail and is limited to assisting Designated Non-Financial Businesses and Professions (DNFBPs) accountable institutions understand better how to approach the issues of ML and TF risk assessment, identification and management within their businesses.
• Draft Guidance Note 7A on implementing ‘various aspects of the Financial Intelligence Centre Act’ relating to in-house risk management and compliance programmes intended to combat money laundering and terrorist financing; and
the process of developing these programmes.
Please also see previous newsletters covering the changes.