The FIC recently published draft Directive 6/2022 together with draft PCC 116 which seek to address the areas of concerns as highlighted in the Financial Action Task Force’s 2019 Mutual Evaluation final report, focusing specifically on the shortcoming that there is no requirement for financial institutions to screen employees.
The draft directive proposes the following main requirements for all accountable institutions to:
- Screen prospective and current employees for competence and integrity using a risk-based approach.
- Scrutinise prospective and current employee information against the Targeted Financial Sanctions (TFS) lists.
- Keep records of how both types of screening above will be conducted as well as the outcomes of such screening.
Draft Directive 6/2022 is supported by draft PCC 116 which offers guidance on how to comply with these requirements. The draft Directive will become effective and enforceable 3 months after the date of publication in the Government Gazette. The three-month period is intended to allow for a transition period during which an accountable institution can develop screening and scrutinising processes or enhance existing processes where necessary, to enable compliance with the Directive 6/2022. The draft PCC 116 advises accountable institutions to commence with screening of its higher risk employee roles as soon as possible, and thereafter focus on lesser risk employee roles.
Interested parties are invited to submit comments using the online comments submission links on the draft Directive 6/2022 and draft PCC 116 on or before 19 August 2022. The FIC intends to conclude the consultation process on these draft publications by publishing the final versions by no later than 31 August 2022.