50 Years Facilitating Open Account - Trade Finance

FCI Compliance Policy

During its 49th annual meeting in Lima, Peru, FCI members approved almost unanimously with 96,4% of the votes a new Compliance Framework that was presented by the Ad Hoc Compliance Committee and discussed during roundtable sessions.

 

The new internal FCI Compliance framework comprises a general Compliance Charter, a document describing FCI’s core values and an FCI Speak-Up policy. You can find these documents in the library under 'compliance'.

 

Secondly, FCI launched an improved Compliance framework to support the two-factor business. This means that from now on members can centrally upload the Wolfsberg AML questionnaire as well as a specific FCI KYC questionnaire.

 

Currently the FCI Constitution sets a few parameters which must be complied with, in order to be accepted and to remain as Associate/Full Member, such as equity, participation to FCI activities and contribution to surveys. Changes to the procedures can easily be amended for new member applications, but the same cannot be forced upon existing members, unless it is decided to amend the FCI Constitution to include these new requirements.

 

The Committee has revised the Membership application form and procedures and all new applicants will have to complete the new form as well as the Wolfsberg Questionnaire.

 

In the interest of all parties involved, we strongly suggest that also existing Full and Associate members complete the two forms:

  1. FCI - Collection of data for KYC purpose
  2. The Wolfsberg Group Anti-Money Laundering Questionnaire 

 

and forward the same to the FCI Secretariat where the documents will be reviewed and uploaded in the FCI Private Net / Members Files, so that they may be available to all correspondents saving each of you the bother of having to circulate such information yourself. 

 

As a non-regulatory body, FCI can only facilitate the KYC/AML procedures for its members, but the final responsibility for due diligence and risk based approach remains of course with the members themselves.