The Financial Intelligence Centre (“FIC”) has issued draft Guidance Note 7B for consultation, marking an important update to the current Revised Guidance Note 7A framework. While draft Guidance Note 7B does not rewrite the risk-based approach under the Financial Intelligence Centre Act, 2001 (FICA”), it refines it in ways that accountable institutions should not ignore. In particular, it integrates proliferation financing more explicitly into the guidance, clarifies aspects of risk assessment and systems and controls, and tightens the position when simplified due diligence may not be appropriate.
At a high level, the most obvious change from Revised Guidance Note 7A is linguistic and conceptual expansion. Revised Guidance Note 7A focused on money laundering and terrorist financing risk. Draft Guidance Note 7B updates that framework so that references throughout Chapter 1 now consistently include proliferation financing, with the guidance speaking in terms of money laundering,
