The Financial Intelligence Centre (FIC) has published a document to guide designated non-financial businesses and professions (DNFBPs) in developing and implementing their risk management and compliance programmes (RMCPs).
Public Compliance Communication (PCC) 53 does not apply to financial institutions, or DNFBPs that fall within group structures, or DNFBPs that have advanced compliance or complex structures, the FIC said in a statement on 30 August.
It incorporates, where the FIC deemed appropriate, the comments received in response to draft PCC 114, which was issued on 1 April.
The FIC said it does not prescribe what an advanced or complex structure may be. Where the RMCP template as set out in PCC 53 is too simplistic and will not achieve the level of compliance required of an accountable institution, the accountable institution must develop a suitable RMCP.
“Although the principles can be equally applied, the proposed template is only intended for smaller DNFBPs,” the FIC said.
PCC 53 provides DNFBP accountable institutions with detailed guidance on how to understand and document their money laundering and terrorist financing risks. It provides the factors that would demonstrate effective risk identification, assessment, mitigation, management and monitoring.
“The manner in which this is incorporated into an accountable institution’s RMCP remains within the framework of their risk-based approach, and as such is not prescriptive, nor results in the implementation of a rules-based approach,” the FIC said.
As a result of comments on draft PCC 114, the term “apex” has been removed from PCC 53.
The FIC said “apex RMCP” was intended to describe an accountable institution’s highest-level RMCP document, approved by the person exercising the highest level of authority in the accountable institution, and providing an overview of the RMCP.
Click here to download PCC 53.
