FIC publishes draft directive on employee screening

The Financial Intelligence Centre (FIC) has published a draft directive that requires accountable institutions to screen their employees for competence and integrity, as well as scrutinise employee information against the targeted financial sanctions lists, to combat money laundering, terrorist financing and proliferation financing (ML/TF/PF).

Draft Directive 6/2022 is supported by draft Public Compliance Communication 116, which provides guidance on how accountable institutions can comply with the draft directive.

Draft Directive 6/2022 and draft PCC 116 aim to address the shortcomings highlighted in the Financial Action Task Force’s 2019 Mutual Evaluation final report, which include that there is no requirement for financial institutions to screen employees.

Similar to understanding the ML/TF/PF risks associated with clients, it is equally important for accountable institutions to understand how these ML/TF/PF risks can arise internally through their relationship with their employees, the FIC said.

Accountable institutions must implement risk mitigation and management measures that are commensurate with the level of risk identified.

Click here to download draft Directive 6/2022.

Click here to download draft PCC 116.

The deadline to comment on both draft documents is Friday, 19 August. Comments must be submitted using the relevant online forms only.

Click here to comment on draft Directive 6/2022.

Click here to comment on draft PCC 116.

The FIC said it intends to publish the final versions of both documents by 31 August.

Any questions relating to draft directive and PCC should be emailed to

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