FICA Compliance requires infrastructure
- Registration with FIC/ goAML
- Appointment of Compliance Officer
- RMCP subject to periodic review
- RCR (deadline still May 2023)
Then, operationally
- Targeted Financial Sanctions list screening (TFS)
- Risk Assessment
- KYC this includes client due diligence
- Ongoing Business Relationships
- Employee screening (Directive 8)
With resultant record keeping and reports