Circular No. 1 of 2026 - Assessment of ML TF Risks For New Products, Business Practices And Technologies

Circular No. 1 of 2026
Date: 29 th January 2026
Assessment of money laundering and terrorist financing risks prior to introducing a new product, business practice or the use of new or developing technologies for both new and pre-existing products The Financial Services Authority (“FSA”) would like to remind all reporting entities under its regulatory ambit (i.e. persons specified in Part B of the First Schedule and persons listed at serial numbers 7 and 8 of
Part C of the First Schedule of the Anti-Money Laundering and Countering the Financing of Terrorism Act,
2020 (“AML/CFT Act”)), of their obligation to identify, assess, understand and monitor their risks of money laundering and terrorist financing activities and to also take appropriate measures to mitigate the risks identified, as required under Section 32 (1) of the AML/CFT Act.
Section 32(4) of the AML/CFT Act further stipulates that “Prior to the launch of a new product or business
practice or the use of a new or developing technology, the reporting entity shall identify and asses the money laundering and terrorist financing risks that may arise in relation to the development and use of new products or business practices, or new or developing technologies for both new and pre-existing products, and take appropriate measures to manage and mitigate those risks.” All reporting entities shall, before the launch of a new product or business practice or the use of new or developing technologies for both new and pre-existing products —

• Undertake a risk assessment;
• After the initial assessment, implement measures to manage and mitigate all the identified risks;
  and
• Document the outcome of the risk assessment based on experience and emerging evidence.
  All reporting entities shall, in identifying and assessing the risks associated with the new product or business practice or the use of new or developing technology, take into account the following factors — (a) the profile of its customers; (b) the geographic area in which it conducts business;

(c) the product or products that it deals in;
(d) the service or services that it provides or receives; (e) the means by which such products or services are delivered; (f) the transactions that it conducts; (g) customer due diligence carried out by third parties; and (h) the technological developments in identifying such risks. In light of the above, the FSA would like to reiterate that risk assessments undertaken under section 32 (1) and (4) of the AML/CFT Act must be included in the risk assessment report which is to be submitted to the FSA upon request. In the event that there have not been any new products or technologies, this must also be explicitly stated in the risk assessment report. Additional guidance on how to conduct a risk assessment can be found in the Anti-Money Laundering and Countering the Financing of Terrorism Institutional Risk Assessment Guidelines which is available on FSA’s website under the AML/CFT tab. The FSA counts on the usual cooperation of all reporting entities in identifying and assessing money laundering and terrorism financing risks prior to the launch of a new product or business practice or the use of new or developing technologies for both new and pre-existing products in the fight against money laundering and terrorist financing activities in order to safeguard the integrity of Seychelles. Reporting entities may contact the FSA through email at amlcft@fsaseychelles.sc for any clarification or further information regarding the content of this Circular. FINANCIAL SERVICES AUTHORITY