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Guidelines for Accountants, Trust and Company Servicer Providers, and Other DNFBPs in the RMI

The Banking Commissioner of the Republic of Marshall Islands (RMI) has issued these guidelines to provide clarity on the Anti-Money Laundering (AML) and Countering Financing of Terrorism (CFT) requirements for accountants, trust and company servicer providers, and other Designated Non-Financial Businesses and Professions (DNFBPs).

The RMI has implemented a robust AML/CFT framework to combat money laundering, terrorist financing, and proliferation financing. The framework is based on international standards set by the Financial Action Task Force (FATF) and national laws, including the Banking Act 1987 and the AML Regulations 2002.

Risk-Based Approach

The guidelines emphasize the importance of a risk-based approach in identifying, assessing, and mitigating ML/TF risks. DNFBPs must apply this approach to their business activities and relationships to ensure that they are not used for money laundering or terrorist financing purposes.

Requirements for DNFBPs

DNFBPs must establish effective AML/CFT programs that include:

  • Risk assessment and mitigation measures
  • AML/CFT governance and internal policies
  • Customer due diligence measures
  • Reporting of suspicious transactions
  • Record keeping requirements

Supervision and Monitoring

The Banking Commissioner is responsible for supervising and monitoring the compliance of DNFBPs with the AML Regulations 2002. DNFBPs must cooperate with the Banking Commissioner to ensure that their AML/CFT programs are effective.

Terminology

Throughout these guidelines, “must” refers to a requirement in legislation or regulation, “should” refers to good practice, and “may” refers to an option for meeting obligations.

By following these guidelines, DNFBPs can ensure compliance with the RMI’s AML/CFT requirements and contribute to the integrity of the international financial system.