Guidance Note 7B: It's More Than an RMCP Update

On 3 August 2026, the Financial Intelligence Centre (FIC) published Guidance Note 7B, replacing Guidance Note 7, Guidance Note 7A and the Revised Guidance Note 7A.

At first glance, many Financial Services Providers (FSPs) may assume that Guidance Note 7B simply requires an update to their Risk Management and Compliance Programme (RMCP). While reviewing and updating documentation is certainly important, the Guidance Note delivers a much broader message.

Guidance Note 7B reinforces the Financial Intelligence Centre's expectations that accountable institutions should implement a practical, risk based approach to Anti Money Laundering, Counter Terrorist Financing and Counter Proliferation Financing. It encourages institutions to move beyond compliance on paper and demonstrate that their compliance framework is actively embedded into their daily operations.

The focus has shifted from documents to implementation

Many accountable institutions have invested considerable time developing RMCPs, FICA Manuals and customer due diligence procedures. Guidance Note 7B makes it clear that these documents should not merely exist to satisfy regulatory requirements. They should accurately reflect how the institution conducts business and how financial crime risks are identified, assessed and managed in practice.

A generic template is unlikely to address the unique risks faced by every institution. Instead, accountable institutions should ensure that their compliance framework is tailored to their specific business activities, products, services, customer base, delivery channels and overall risk profile.

Institutions should also recognise that compliance documentation is not static. As businesses grow, introduce new products or adopt new technologies, their policies and procedures should be reviewed to ensure they continue to reflect current operations and regulatory expectations.

Risk management has become even more important

One of the strongest themes throughout Guidance Note 7B is the application of a genuine risk based approach.

Rather than applying the same level of due diligence to every client, accountable institutions are expected to identify, assess, mitigate and monitor financial crime risks based on their own circumstances. This enables institutions to allocate resources more effectively while ensuring that higher risk clients and activities receive greater scrutiny.

Business risk assessments and customer risk assessments should therefore be reviewed regularly. Institutions should consider whether changes to their client base, services, technology or operating environment have introduced new risks that require additional controls or updated procedures.

Proliferation Financing is now part of the conversation

Guidance Note 7B integrates Proliferation Financing alongside money laundering and terrorist financing throughout the guidance.

This reinforces the expectation that accountable institutions should consider proliferation financing risks when developing and maintaining their compliance framework. Existing policies, procedures and risk assessment methodologies should be reviewed to ensure they appropriately address all three financial crime risks where relevant to the institution.

Documentation alone is not enough

Another important message throughout Guidance Note 7B is that institutions should be able to demonstrate the decisions they make.

It is not enough to simply assign a client risk rating or complete a due diligence checklist. Institutions should maintain sufficient records to show why particular decisions were made and how they applied their risk based approach.

Examples include documenting:

• Why a client received a particular risk rating.

• Why Simplified Customer Due Diligence was considered appropriate.

• Why Enhanced Due Diligence was required.

• When sanctions screening was performed.

• How ongoing due diligence is conducted.

• When senior management approvals were obtained where required.

Maintaining comprehensive records not only supports regulatory compliance but also demonstrates that the institution's RMCP is being implemented consistently and effectively.

Guidance Note 7B presents an opportunity

While many institutions may view Guidance Note 7B as another compliance update, it should also be seen as an opportunity to strengthen existing compliance frameworks.

Reviewing policies, procedures, forms, registers and operational processes together helps ensure consistency throughout the client lifecycle. It also allows accountable institutions to identify potential gaps before they become regulatory findings during a compliance review or inspection.

A proactive review today can reduce future compliance risks and improve the overall effectiveness of an institution's AML, CFT and CPF programme.

Practical implications for FSPs

For many Financial Services Providers, Guidance Note 7B provides a good opportunity to review:

• RMCP.

• FICA Manual.

• Business Risk Assessment.

• Customer Risk Assessment methodology.

• Customer Due Diligence procedures.

• Enhanced Due Diligence procedures.

• Ongoing Due Diligence processes.

• Sanctions screening procedures.

• PEP and PIP procedures.

• Internal forms and registers.

• Staff training material.

The extent of any changes will depend on the nature, size and complexity of the institution, but ensuring that all compliance documents work together as a cohesive framework is essential.

Don't view Guidance Note 7B as another compliance exercise

Guidance Note 7B is not simply about updating wording in an RMCP or revising a policy document.

It encourages accountable institutions to ensure that compliance is practical, evidence based and integrated into everyday business operations. Institutions should be able to demonstrate that their policies are understood by staff, implemented consistently and supported by appropriate records.

A well designed compliance framework not only assists with meeting regulatory obligations but also strengthens an institution's ability to identify, manage and mitigate financial crime risks.

Free Guidance Note 7B Infographic

To help accountable institutions understand the key themes and practical implications of Guidance Note 7B, we have created a complimentary two-page infographic summarising the most important points.

If you would like a copy, simply submit an enquiry through our website with the subject "Guidance Note 7B Infographic", and we will gladly send it to you.

At FSPCOMPLY, we remain committed to helping Financial Services Providers build practical, effective and compliant AML, CFT and CPF frameworks that meet regulatory expectations while supporting their day-to-day operations.

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