
FIC finalises Guidance Note 7B after industry feedback
The final Guidance Note makes targeted changes, but the regulator’s feedback discloses how it weighed industry concerns and refined key aspects of the guidance.

The final Guidance Note makes targeted changes, but the regulator’s feedback discloses how it weighed industry concerns and refined key aspects of the guidance.

Many institutions have left registration too late, submitted the wrong documents, or filed branch returns instead of consolidated legal entity returns.

The draft directive will introduce a new recurring compliance obligation, with updated programmes also having to be lodged within 10 business days of approval.

The Centre has refined the directive’s scope and addressed concerns over its legal basis, administrative burden, and practical application.

Less than half of the first group of accountable institutions had submitted their returns by mid-July, while submissions from the second group are low.

The FIC says fewer than 12% of accountable institutions facing the first filing deadline had submitted their returns by the middle of this month.

PCC 60 largely preserves the draft framework but clarifies how newly registered firms must report and confirms that third parties may not submit returns.

A proclamation brings into operation a set of dormant provisions that link cross-border cash reporting to criminal penalties and forfeiture powers.

The consultation focuses on four insertions dealing with proliferation financing, client risk categorisation, and the operation of systems and controls.

The specified accountable institutions have until 30 June or 31 July to complete and submit their RCRs.

Attend this practical session on PCC 23A, Directive 11, and the steps needed to submit a complete and defensible return.

Penalties cannot be based on periods before the FIC assumed supervisory authority, and remediation must be fully considered when imposing sanctions.

The FIC publishes draft guidance on implementing Directive 10, including how institutions must capture and submit geographic data across group structures.

The draft directive requires certain accountable institutions to submit RCR questionnaires covering information from 2023 to 2026.

Moonstone Compliance’s analysis identifies recurring shortcomings that FSPs should fix to avoid enforcement action.

The draft PCC reinforces zero-threshold travel rule application, mandatory real-time monitoring, enhanced controls for unhosted wallets, and strict freezing obligations.

SPVs designated as accountable institutions must comply with FICA in full, including independent registration and adherence to RMCP and reporting requirements.