The Financial Crimes Commission (FCC) has recently issued new guidelines for Legal Persons under section 52(2) of the Financial Crimes Commission Act 2023 (FCCA). These guidelines aim to help organisations establish and implement adequate procedures to prevent financial crimes such as corruption, money laundering, fraud and the financing of drug-related activities under Part III of the Act.
These guidelines apply to: A Legal Person, which is defined under section 2 of the FCCA as “any entity, including a private entity, other than a natural person” (the “Legal Person”).
The guidelines are designed to complement existing legal and regulatory obligations. They adopt a principle-based approach, allowing each organisation to tailor its compliance framework according to its size, nature and level of risk. Five Guiding Principles The FCC framework is built around five key principles that promote good governance and ethical conduct:
Leadership Commitment: Senior management must set the tone from the top by fostering a culture of integrity and compliance.
Risk Assessment: Organisations should regularly assess and manage potential financial crime risks.
Control Measures: Establish internal controls, including due diligence, reporting channels, and beneficial ownership transparency.
Monitoring & Review: Continuously review and evaluate the effectiveness of procedures, addressing any gaps or weaknesses.
Training & Awareness: Provide ongoing staff training and ensure clear communication of compliance policies.
Gifts and Hospitality
The FCC also encourages organisations to adopt a Gifts, Hospitality & Promotional Expenditure (GHPE) Policy. Such a policy should ensure that all gifts or hospitality are reasonable, transparent and properly documented and that they cannot be perceived as attempts to influence decisions or gain undue advantage.
Our Commitment at CKLB At CKLB International Management Ltd, we fully support the principles set out by the FCC and remain committed to maintaining the highest standards of integrity, transparency, and ethical conduct. We continuously review and strengthen our internal controls, compliance procedures, and staff awareness programmes to ensure that our operations reflect our strong culture of good governance and accountability.
