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Are you an accountable institution?

This FICA compliance assessment asks eleven questions to find out whether FICA applies to your business, and scores your readiness against the obligations it carries.

This is a quick self-assessment, not an official FICA assessment or audit. It scores only the answers you give, and it is not legal advice. Use it to see where to look first, then confirm your obligations with the Financial Intelligence Centre or a compliance professional.

Your business
Which of these describes your business?

Select every category that applies. Schedule 1 of the Financial Intelligence Centre Act designates certain businesses as accountable institutions; these are the sectors HLBNGA works with most.

Banking
Financial services
Professional services
High-value trade

Schedule 1 lists further categories beyond those shown here. If your sector is not listed, treat the outcome as a starting point and confirm it with the Financial Intelligence Centre.

Do you have a documented Risk Management and Compliance Programme that is current and reviewed?

The RMCP sets out how your business identifies, assesses and manages its money laundering and terrorist financing risk.

Are all new clients identified and verified before you establish a business relationship?

Identification means collecting the information. Verification means confirming it against a reliable, independent source.

For corporate clients, can you identify and verify the ultimate beneficial owners?

The natural persons who ultimately own or control the entity, rather than the registered company itself.

Do you screen every client against targeted financial sanctions lists before onboarding?

Sanctions obligations apply regardless of the risk level you assign to a client.

Do you identify politically exposed persons, including their family members and close associates?

Both domestic and foreign prominent persons, and the people connected to them.

Do you check adverse media and negative news beyond formal watchlists?

Criminal and reputational signals often appear in reporting well before they reach any published list.

Is your existing client base re-screened on an ongoing basis, not only at onboarding?

Client risk is not static, and neither are the lists you screen against.

When a client is assessed as higher risk, do you carry out enhanced due diligence and document the outcome?

Deeper checks on source of funds, ownership and reputation, with the reasoning recorded.

Do you screen third parties, suppliers and agents to the same standard as clients?

Intermediaries and vendors can carry the same exposure as the clients you onboard directly.

Can you retrieve the evidence behind any individual screening decision after the fact?

What was checked, what was found, who decided, and when.

What this FICA compliance assessment measures

The Financial Intelligence Centre Act places a defined set of duties on accountable institutions. This tool works through ten of them, in the order they arise in a client relationship, from establishing who someone is to being able to prove what you checked.

Each answer is scored on whether the control exists, whether it runs consistently, and whether you could evidence it on request. That last part matters: the most common finding in a compliance review is not an absent control, but one that cannot be demonstrated.

Nothing you select is sent anywhere or stored. Your score is calculated in your browser.

How your score is read

  • High exposure0–34

    Most of the core obligations are not yet covered.

  • Material gaps35–59

    Several obligations are partly met or handled manually.

  • Largely in place60–84

    The framework is there, with specific gaps to close.

  • Strong85–100

    Core obligations covered; the work is keeping them current.

Turn the gaps into controls

See how HLBNGA closes them.

Bring your result to a working session and we will map each gap to the screening workflow that covers it.