The Financial Intelligence Centre (FIC) has opened consultation on targeted amendments to its guidance on the implementation of the Financial Intelligence Centre Act (FICA), with proposed changes focusing on simplified due diligence, risk assessments involving new products and technologies, and the treatment of proliferation financing risks.
Draft Guidance Note 7B updates Chapter 1 of Revised Guidance Note 7A, which sets out how accountable institutions should apply the risk-based approach required under FICA. The FIC has invited comments on four specific proposed additions to the guidance.
According to the FIC’s Consultation Note of 12 June 2026, the draft guidance seeks to provide further guidance on the application of simplified due diligence (SDD) where clients or transactions present a lower risk of money laundering (ML), terrorist financing (TF), and proliferation financing (PF). It also proposes guidance on the assessment of risks arising from new products, business practices, delivery mechanisms, and technologies, while incorporating references to PF throughout the document.
The first proposed addition, paragraph 7A, inserts a definition of PF into the general principles section of Chapter 1. The draft defines PF as activity that provides property, a financial or other service, or economic support to a non-state actor that may be used in connection with the manufacture, acquisition, possession, development, transport, transfer, or use of nuclear, chemical, or biological weapons and their means of delivery. It also states that PF may include conduct that constitutes an offence under section 49A of FICA.
The second proposed addition, paragraph 37A, deals with risk assessment. It states that accountable institutions should identify and assess the ML, TF, and PF risks posed by the development of new products, new business practices, new delivery mechanisms, and the use of new or developing technologies for new and existing products. The assessment should be reflected in the institution’s risk assessment processes and its Risk Management and Compliance Programme (RMCP).
The third proposed addition, paragraph 40A, addresses client risk classification. It states that under-served or low-income persons should not automatically be regarded as presenting a lower risk of ML, TF, and PF. Before treating a business relationship, single transaction, client, or category of clients as low risk, an accountable institution must conduct a comprehensive risk assessment.
The fourth proposed addition, paragraph 58A, concerns the application of SDD. It states that SDD involves a basic level of identification and verification where a business relationship or single transaction presents a low risk of ML, TF, and PF. However, SDD may not be applied where there is a suspicion of ML, TF, or PF. In such circumstances, the relationship or transaction would automatically present a high risk, requiring the institution to conduct enhanced due diligence and file a report in terms of section 29 of FICA.
The FIC has indicated that comments are sought only on the proposed additions contained in paragraphs 7A, 37A, 40A, and 58A. Written submissions must be made using the FIC’s online consultation form by close of business on 26 June 2026.
