The Financial Intelligence Centre (FIC) recently issued Directive 12, introducing a new requirement for certain accountable institutions to submit a copy of their approved Risk Management and Compliance Programme (RMCP) to the FIC via the goAML registration and reporting platform.
The accountable institutions listed below are required to comply with Directive 12 by the applicable annual submission deadline:
The RMCP submitted to the FIC must be the version formally approved by the board of directors, senior management or the persons exercising the highest authority within the organisation.
Where an accountable institution is registered under more than one Schedule 1 item, a separate RMCP must be submitted for each registration category.
In addition to the annual submission requirement, newly established accountable institutions that fall within the scope of Directive 12 must submit their RMCP within 90 days of commencing business. Where an RMCP is amended and subsequently approved, the updated version must be submitted to the FIC within 10 days of approval.
Failure to comply with the requirements of Directive 12 constitutes non-compliance and may result in administrative sanctions.