On the 14 of July 2025, the Financial Crimes Commission has issued guidelines on Legal Persons pursuant to section 52 of the FCCA, targeting all legal persons from SMEs to major corporations. These guidelines are intended to guide legal persons in putting up adequate procedures which are reasonably necessary to prevent it or any person acting on its behalf from committing an offence under Part III of the FCCA. Legal persons are required to tailor controls proportional to their size, sector, risk profile and complexity to combat financial crime, corruption, fraud, money‐laundering, and drug financing.
The 5 principles to be considered when implementing measures, procedures and controls are:
1. Commitment at Top level Management – Top level Management must visibly champion ethical, compliant culture
2. Conduct of risk assessment – Regular FCCA-risk assessments, including third‑party and jurisdictional exposure
3. Implementation of control measures – Due diligence, whistle‑blowing, beneficial‑ownership transparency, transaction monitoring and STR protocols
4. Systematic review, monitoring and enforcement – Internal/external audits, compliance checks, sanctions for breaches
5. Training and communication – Multi‑format, entity-wide communication on policies, risks, reporting lines A Gifts, Hospitality & Promotional Expenditure Policy (“GHPE Policy’’) has also been introduced and firms must now document, justify and report such expenditures under freshly mandated GHPE policies
A Gifts, Hospitality & Promotional Expenditure Policy (“GHPE Policy’’) has also been introduced and firms must now document, justify and report such expenditures under freshly mandated GHPE policies.
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