Angela Itzikowitz, Executive: Banking and Finance; Era Gunning, Executive: Banking and Finance; Amelia Warren Associate: Banking and Finance; at ENS
The Financial Intelligence Centre (“FIC”) has released draft Directive 10 for consultation under section 43A(1) of the Financial Intelligence Centre Act, 2001 (“FICA”), focusing on enhanced geographic location disclosures at the point of registration by accountable institutions. The draft was issued by the Acting Director on 19 December 2025 and is currently open for public comment.
Under draft Directive 10, accountable institutions would need to provide, as part of their registration, information on the head office, branches and subsidiaries located both within and outside the Republic, to determine geographic locations for group structures. The FIC clarifies that this is a disclosure requirement only and does not require branches and subsidiaries to register as separate accountable institutions where they are not separate legal entities.
The FIC indicates that collecting geographic location information will assist the FIC and supervisory bodies in understanding group structures and thereby enable more informed, risk‑based supervision in relation to group‑wide compliance. The intent is to support supervisory effectiveness by aligning oversight with the actual footprint and risk profile of accountable institutions’ group operations.
Stakeholders are invited to submit comments using the online consultation comments form provided by the FIC by close of business on Friday, 13 February 2026.
In practical terms, accountable institutions should anticipate gathering accurate location data for their head office and all in‑scope branches and subsidiaries across jurisdictions to meet the contemplated registration disclosure, ensuring consistency with their group structure mapping. Given the FIC’s emphasis on risk‑based, group‑wide supervision, institutions will benefit from aligning internal records and governance with the group structure and geographic footprint that will be disclosed through registration. The FIC’s assurance that the proposal does not impose separate registration for non‑separate legal entities should ease compliance burdens while still enhancing supervisory visibility.
Accountable institutions should review the draft text on the FIC website, assess the completeness of their current group location mapping, and consider submitting comments via the online form before 13 February 2026 to address any operational nuances or sector‑specific considerations.
ENDS
