The Financial Intelligence Centre
(“FIC”) has released draft Directive
10 for consultation under section 43A(1) of the Financial
Intelligence Centre Act, 2001
(“FICA”), focusing on enhanced
geographic location disclosures at the point of registration by
accountable institutions. The draft was issued by the Acting
Director on 19 December 2025 and is currently open for public
comment.
Under draft Directive 10, accountable institutions would need to
provide, as part of their registration, information on the head
office, branches and subsidiaries located both within and outside
the Republic, to determine geographic locations for group
structures. The FIC clarifies that this is a disclosure requirement
only and does not require branches and subsidiaries to register as
separate accountable institutions where they are not separate legal
entities.
