Mandatory FIU Registration and Ongoing Reporting Duties for Compliance Officers under the AML/CFT Act

Circular No. 3 of 2026 Date: 31st March, 2026 Mandatory FIU Registration and Ongoing Reporting Duties for COs and ACOs under AML/CFT Act and AML/CFT Regulation. The Financial Services Authority (“FSA”) would like to draw the attention of all reporting entities under its regulatory purview to the provisions of section 31 of the Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020 (“AML/CFT Act”), which stipulates that every reporting entity, to which this Act applies, shall register with the Financial Intelligence Unit (“FIU”) within such period and in such manner as may be prescribed by Regulations. Regulation 7(2) of the Anti-Money Laundering and Countering the Financing of Terrorism Regulations, 2020 (“AML/CFT Regulations”) further requires that the registration shall be in an electronic manner and the procedures for registration shall be as per the guidelines issued by the FIU. The guidelines can be accessed through the link provided below: https://seychellesfiu.sc/report-a-suspicious-transaction-or-activity/ In line with Regulation 7(3) of the AML/CFT Regulations, every registration submitted to the FIU should contain the particulars listed below in respect of the reporting entity – • The legal name of the natural person, legal person or legal arrangement • Registration number, license number, or national Identity Number • Full contact details of the reporting entity • Full name and contact details of the compliance officer (“CO”) and the alternative compliance officer (“ACO”); and • Any other particulars, as may be determined by the FIU from time to time Section 31(4) further requires that every registered reporting entity under subsection (1) shall notify the FIU of any changes in the particulars furnished, in writing, within a period of 30 days from the date of such change. In line with the above-mentioned statutory obligations requiring reporting entities to submit the prescribed particulars to the FIU upon registration and to promptly notify the FIU of any subsequent changes, the FSA reminds all reporting entities that this duty remains ongoing and must be strictly observed. The FSA places particular emphasis on this obligation with respect to the details relating to COs and ACOs.

Reporting entities are therefore reminded that any change in the particulars of a CO or ACO, including the appointment of a new CO or ACO or amendments to the details of an existing one, must be reported to the FIU in writing within 30 days of the date of the change so as to ensure full compliance with these legislative obligations. The FSA also takes this opportunity to remind all reporting entities who have not yet registered their COs and ACOs on the GoAML platform, in accordance with Section 31 of the AML/CFT Act and Regulation 7 of the AML/CFT Regulations, to do so without delay. Pursuant to section 31 (5) of the AML/CFT Act, a reporting entity which intentionally fails to register with the FIU as required or fails to report the changes in the particulars provided, commits an offence, and is liable on conviction to a fine not exceeding SCR100,000. Reporting entities are therefore reminded to comply with these requirements to avoid any breach of the law. The FSA counts on the continued cooperation of reporting entities to remain compliant with the requirements of the AML/CFT Act and the AML/CFT Regulations. 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