The Financial Intelligence Centre (FIC) has published draft Directive 6/2022, which requires accountable institutions to screen prospective employees and current employees for competence and integrity, as well as scrutinise employee information against the targeted financial sanctions (TFS) lists, in order to identify, assess, monitor, mitigate and manage the risk of money laundering, terrorist financing and proliferation financing (employee screening). 

An accountable institution must provide for the manner in which employee screening will be conducted, keep a record of the outcome of such screening and make the manner and outcome of employee screening available to the FIC or the supervisory body which performs regulatory or supervisory functions in respect of that accountable institution. 

The FIC’s draft Public Compliance Communication on Directive 6/2022 (draft PCC 16 of 2022) provides guidance regarding certain requirements of draft Directive 6/2022, including: 

  • The categories of employees which may present higher ML/TF/PF risks (such as senior management); 
  • When screening should be done on prospective employees and current employees; 
  • What factors should be considered when screening an employee for competence and integrity; 
  • When enhanced screening measures may be required (for example, when an employee is a known close associate or immediate family member of a high-risk client); 
  • The screening of all employees (regardless of their level of ML/TF/PF risk) against the TFS lists. 

Draft Directive 6/2022 will become effective and enforceable 3 months from date of publication in the Government Gazette.  

To read draft Directive 6/2022, click here 

To read draft PCC 16 of 2022, click here.  

Commentators are invited to comment on the draft guidance by submitting written comments via the online comments’ submission link here.

Any questions or requests relating to draft PCC 116 of 2022 may be sent to the FIC only at

Submissions will be received until close of business of Friday, 19 August 2022.

Compliance queries may also be submitted via or visiting the Centre’s website and submitting an online compliance query.  


If you would like to find out more about the services that ICS offers please contact us.