FIC’s Draft Directive 11: From RMCP Documents to Real Accountability
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The Financial Intelligence Centre (FIC) has released Draft Directive 11, and related Consultation Note for accounting practices operating as Trust and Company Service Providers (TCSPs). Draft Directive 11 is based on Section 43A of the Financial Intelligence Act giving FIC the power to:
👉 Instruct accountable institutions to provide information about their risk and compliance
This includes:
Their risk exposure (ML, TF, PF)
Their controls and processes
How effectively those controls are working.
👉 And importantly, this information must be submitted in the format the FIC prescribes (like this questionnaire).
giving this is not just another form — it’s a fundamental shift in how compliance is measured.
The proposed reporting period spans 3 years, from 1 April 2023 to 31 March 2026. The information will have to submitted by 30 April 2026. The questionnaire for TCSPs can be downloaded here.
1️⃣ From policies → to proof
Until now, most practices could rely on having a compliant RMCP document. Directive 11 changes that. Accounting practices will now need to submit detailed risk and compliance data, not just confirm that processes exist. This includes:
Client risk profiles
Transaction behaviour
Beneficial ownership tracking
Ongoing monitoring activities.
👉 The message is clear: “Don’t tell us - show us.”
2️⃣ You must report what actually happened (over 3 years)
Registered Trust and Company Service Providers (TCSPs) will need to report on:
Client types and structures (trusts, companies, partnerships)
Source of funds checks
High-risk client exposure
Suspicious or unusual transactions.
📊 And not just once — but across multiple reporting periods (2023–2026).
👉 If you haven’t been tracking this data, you already have a problem.
3️⃣ Much deeper scrutiny on trusts and company structures
Directive 11 goes directly at the core of what accounting practices do:
Are you verifying ultimate beneficial owners properly?
Do you understand the true purpose of trusts and companies?
Can you explain where funds come from — and why transactions make sense?
👉 Expect far more scrutiny on:
Complex structures
Client instructions that “don’t make sense”
Use of trusts for tax or asset protection.
4️⃣ Real-world risk questions — not theory
This is not a textbook exercise anymore. The new questionnaire asks:
Do clients use unusual structures or funding sources?
Are transactions aligned to economic purpose?
Do clients disengage when asked for information?
👉 This is behavioural compliance — not checkbox compliance.
5️⃣ Compliance systems will matter more than documents
Manual processes and spreadsheets won’t cut it. To comply, TCSPs will need:
Structured client data
Ongoing monitoring logs
Evidence of risk assessments
The ability to extract and report data.
👉 This is a move toward system-based compliance
💬 Bottom line
Directive 11 is forcing a shift:
👉 From RMCP as a document
➡️ To RMCP as a working, measurable system.
