The Financial Intelligence Centre (FIC) on 1 September published Revised Guidance Note 7a, effective September 1, 2025, which replaced both Guidance Note 7 and Guidance Note 7A. While many requirements remain consistent with current guidance, this revised version updates some standardised terminology but is useful to remind us of critical compliance obligations.
Terminology Updates:
Some terms were updated, but the underlying meaning did not change. We recommend updating your RMCP with these changes at the next review cycle.
Reminders around Risk:
The guidance re-emphasizes that Accountable Institutions must:
- Conduct comprehensive entity-wide AML/CFT/CPF risk assessments across their entire structure and include all relevant risk factors such as products, services, technologies, delivery mechanisms.
- Document their risk assessment, risk tolerance and risk appetite levels.
- Regularly review assessments and controls to ensure they remain appropriate and effective.
Reminders around Responsibility:
The guidance reiterates:
- Strict Non-Delegation: Board or person(s) with the highest authority CANNOT delegate Risk Management and Compliance Program (RMCP) approval to committees.
- Personal Liability: Board members and senior management bear personal responsibility for FIC Act compliance and must demonstrate that they have "applied their minds" to RMCP adequacy and approval.
- Enforcement: Non-compliance may result in personal sanctions under Section 61.
While these reminders reinforce existing obligations, we recommend regularly reviewing your current compliance framework. Your RMCP must also be reviewed at least on an annual basis and when regulations, guidance or your business changes to ensure alignment with the latest requirements and that all related processes stay effective.
Contact us for Compliance Assistance
Our compliance team is available to support you in reviewing your current practices and ensuring alignment with these reinforced requirements. Please contact us if you require assistance or have any questions about these updates.
