Understanding the FSCA’s DPI 2024 Directive: A Guide for Accountable Institutions
The Financial Sector Conduct Authority (FSCA) has recently published the Directive to Provide Information (DPI) 2024, as part of its mandate under the Financial Intelligence Centre Act (FIC Act). Released on 27 May 2024, this directive is crucial for all Accountable Institutions supervised by the FSCA to complete and submit. This blog will help you understand who needs to comply, what is required, and how to navigate the submission process effectively.
Who Needs to Comply?
All Accountable Institutions under the supervision of the FSCA must complete the DPI 2024. This specifically includes all Financial Services Providers (FSPs) with the exception of:
FSPs exclusively authorized to render financial services in non-life insurance and/or health service benefits only.
FSPs newly approved for financial advisory and/or intermediary services in crypto assets, known as crypto asset service providers.
Additionally, Collective Investment Scheme Managers must comply, except those conducting business solely as collective investment schemes in participation bonds.
For institutions that failed to submit the previously issued DPI by 31 May 2021, this is the final opportunity to comply.
Submission Process and Timeline
The DPI 2024 must be completed and submitted online via the FSCA's FAIS and CIS e-portals. The submission window is from 27 May 2024 to 31 July 2024. Here’s how you can access and complete the DPI 2024:
1. Accessing the Portal:
Use your existing login credentials for the FAIS e-portal. If your institution has never used the FAIS e-portal, the key individual must first register.
Only Sole Proprietors, Key Individuals, and FAIS compliance officers can register for login credentials on the FAIS online e-portal.
2. Completing the DPI 2024:
Login credentials for FAIS compliance officers cannot be used to access the DPI 2024, as credentials cannot be shared.
It is important that senior management, especially key individuals, collaborate with their Anti-Money Laundering Compliance Officer (AMLCO) to ensure the DPI is accurately completed.
Key Points to Remember
Responsibilities and Roles: The responsibility to complete the DPI 2024 lies with the management of the accountable institution, specifically the key individuals AML Compliance Officers.
Honesty and Accuracy: Institutions must be honest and truthful in their responses. Misrepresentation can lead to administrative penalties and will be scrutinized by the FSCA.
Required Information: Institutions will need their Risk Management and Compliance Programmes (RMCP’s) and their ORG ID number from the Financial Intelligence Centre for completing the DPI.
GoAML Registration: Institutions not yet registered with the FIC on the GoAML system should do so promptly and not use this as a reason for delay in completing the DPI 2024.
Questionnaire Details
The DPI 2024 focuses on various compliance aspects, including:
Risk-based approach and management
Customer due diligence
Training programs
Record keeping
Reporting and registration
Screening processes
The questions are formatted to allow responses of "Yes", "No", and "Not applicable". No statistical information or supporting documents need to be uploaded.
Final Thoughts
The FSCA’s DPI 2024 is a critical compliance requirement for Accountable Institutions. Proper preparation and understanding of the submission process are essential to meet the deadline and avoid penalties. Ensure that your institution's RMCP is up-to-date and readily available. If you have any uncertainties, seek assistance from your AML Compliance Officer to navigate the process smoothly.
Remember, compliance is not just a legal obligation but a cornerstone of building trust and integrity in the financial sector. Act now to ensure your institution meets the FSCA’s requirements and continues to operate within the regulatory framework.
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