Description

FICA RMCP Template and Annexure Pack

The FICA RMCP Template and Annexure Pack is an editable downloadable compliance document set designed to help accountable institutions prepare, customise and implement a practical Risk Management and Compliance Programme.

This template pack is suitable for businesses that need a structured RMCP framework supported by practical annexures, registers, logs and forms. It helps the accountable institution document its governance structure, FIC registration details, Section 42A compliance responsibility, risk-based approach, customer due diligence process, sanctions screening controls, reporting escalation process, training records and RMCP review process.

What Is Included In This Template Pack?

The pack includes a detailed generic RMCP template together with a supporting annexure pack. The documents include editable placeholders, client notes and practical guidance to help the user customise the content for their own business structure, accountable institution category, products, services, client types, delivery channels and risk exposure.

The main RMCP template covers:

• RMCP approval and governance
• Compliance function oversight
• Section 42A Compliance Officer appointment
• External compliance officer wording, where applicable
• MLRO or reporting responsibility
• FIC registration and goAML profile maintenance
• RMCP review process
• Applicability to directors, staff, representatives and contractors
• Regulatory engagement and supervisory cooperation
• AML, CTF and CPF training requirements
• Escalation of non-compliance with the RMCP or FIC Act
• Background of the accountable institution
• Proliferation financing risk
• Business Risk Assessment summary
• Risk-based approach
• Business-level risk assessment
• Client-level risk assessment
• Business relationship versus single transaction categorisation
• Product, service, geographic, delivery channel and payment method risk considerations

Annexures Included

The annexure pack provides practical tools that can be used to implement and evidence the RMCP in day-to-day operations.

The annexure pack includes:

• Annexure 1: FIC Act and Guidance Note 7A RMCP Mapping Table
• Annexure 2: Section 42A Appointment Letter / Resolution
• Annexure 3: Client Onboarding and FICA Information Form
• Annexure 4: Client FICA Risk Assessment and CDD Checklist
• Annexure 5: Targeted Financial Sanctions Screening Log
• Annexure 6: Internal Suspicious and Unusual Activity Escalation Form
• Annexure 7: Ongoing Due Diligence Review Tracker
• Annexure 8: goAML Registration and Profile Update Log
• Annexure 9: Regulatory Request and DPI Tracking Register
• Annexure 10: AML/CFT/CPF Training Attendance and Assessment Record
• Annexure 11: Recruitment and Employee Screening Checklist
• Annexure 12: RMCP Review and Approval Register
• Annexure 13: Compliance Breach and Remediation Register
• Annexure 14: Rejected goAML Report Remediation Log
• Annexure 15: Targeted Financial Sanctions Update Action Log

Why Accountable Institutions Need an RMCP

An RMCP is a central compliance document for accountable institutions. It explains how the business identifies, assesses, monitors, mitigates and manages money laundering, terrorist financing and proliferation financing risks.

A weak or incomplete RMCP can create serious compliance gaps. Many businesses have a policy document but do not have supporting forms, logs, screening evidence, escalation records, training records or review registers. This template pack helps close that gap by combining the main RMCP with practical implementation annexures.

This template pack helps address common weaknesses such as:

• No documented Section 42A appointment
• Unclear RMCP approval and governance records
• No written client risk assessment process
• No evidence of targeted financial sanctions screening
• No internal form for suspicious or unusual activity escalation
• No ongoing due diligence review tracker
• No goAML profile update register
• No AML training attendance or assessment record
• No breach and remediation register
• No clear record of RMCP review and approval

Who Should Use This Template?

• Accountable institutions under the FIC Act
• Financial services providers
• Registered credit providers
• Businesses updating their FICA compliance file
• Entities preparing for a FIC or FSCA inspection
• Compliance officers assisting clients with RMCP implementation
• Business owners, directors, MLROs and Section 42A Compliance Officers

Editable and Customisable RMCP Template

This is a generic editable template and must be customised before use. The business must insert its entity name, FIC ORG ID, accountable institution category, registration numbers, products, services, client types, systems, staff structure, compliance appointments, reporting responsibilities and actual risk exposure.

The template includes client notes to guide the user while customising the RMCP. These notes should be removed before the final RMCP is approved and signed.

Important Compliance Note

This template pack is a compliance support tool and does not replace legal advice or a full business-specific risk assessment. Each accountable institution remains responsible for ensuring that its final RMCP is accurate, approved, implemented, reviewed and aligned with its actual business activities and FIC Act obligations.