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FATF statements on CULTURE & Challenges for TCSPs risk-based approach [RBA]


In the FATF Guidance on the Risk-Based Approach for Trust and Company Service Providers, there are principles for supervision and specifically include requirements that the supervisor[E.G. JFSC/GFC]:

  1. Requires that a TCSP embeds a robust Corporate Governance, CULTURE And Risk Management Framework,
  2. Consider the type of services the TCSP provides, its size and business model, corporate governance arrangements, THE COMPLIANCE CULTURE within the organisation, financial and accounting information, delivery channels, client profiles, geographic location and countries of operation.


  1. The Guidance highlights that the senior management of TCSPs must foster and promote a CULTURE OF COMPLIANCE as a core business value.
  2. The senior management of TCSPs is responsible for fostering and promoting a CULTURE OF COMPLIANCE as a core business value.
  3. Senior management must create a CULTURE OF COMPLIANCE, ensuring that staff adhere to the firm's policies, procedures, and processes to limit and control risks.
  4. Management should recognise the importance of a CULTURE OF COMPLIANCE across the organisation and ensure sufficient resources are devoted to its implementation appropriate to its size, scale and activities.




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