The PRACTICAL focus on:
Principal’s and/ or FIC Compliance Officers' Responsibility and Accountability
· Internal FICA compliance structure. (Organigram)
· Appointmentand effectiveness of a FIC Compliance Officer (FCO)
· Tasks of the FCO
· Money Laundering Reporting Officer (MLRO) vs Admin Officer
Directives
· Applicable to whom?
· Steps of the process to follow directives
· RMCP and other documentation.
GoAML and RMCP company details with the FIC
· Steps of the process
· Documentation
· Online navigation
· Keeping record
· Dashboard
Submitting your RMCP
· Who should compile, update and submit.
· Timeframes for redoing RMCP’s and submitting
· Covered in your most recent RMCP
· Information required for submitting
· Corrections.
· Failing to submit in time.
· Repeating obligation annually.
· Common submitting errors.
· Keeping record.
Directivesguide
· Directive 1 (2013)
o Updating registration details
· Directive 2 (2014)
o The use of login credentials following registration with the FIC.
· Directive 3 (2014)
o Notification of failure to report as required by the FIC.
· Directive 4 (2016)
o New registration and reporting system. – Updating info.
· Directive 5 (2019)
o Use of an automated transaction monitoring system (ATMS).
· Directive 6 (2023)
o Submission of risk and compliance returns.
· Directive 7 (2023) – Not applicable to Estate Agency
o Submission of risk and compliance returns
· Directive 8 (2023)
o Screening and risk rating of employees.
· Directive 9 (2024) – Not applicable to Estate Agency
o “Travel Rule” relating to crypto asset transfers
· Directive 10 (2026)
o On information pertaining to geographic locations
· Directive 11 (2026)
o Risk and compliance returns – (RCR 2026.)
· Directive 12 (2026)
o On the submission of risk management and compliance programmes (RMCP2026).