Your copy May be the old one

The most useful column in ICPAC's new circular is the one nobody reads: the amendment date.

ICPAC issued Compliance Circular 28/2026 on 10 September 2026 to all members, firms and compliance officers of the Institute, under the subject Update of Guidance Notes and other resources. It contains no new rule. In its own words, ICPAC wishes, through this Circular, to inform all its Members, Firms, and Compliance Officers of the updates to the following Guidelines, Case studies, and Common findings, along with the relevant links for ease of reference. What follows is a numbered table: the guide, its date of issue, its amendment date, and the circular number it was issued under.

That is a shelf list with dates on it, and it is worth an afternoon because our manuals cite guides by name and by original date. The guides table runs to thirty-three titles. Eighteen carry a dated amendment, and a nineteenth says only Annually. Eleven of those amendments fall in 2025 or 2026, five of them in 2026.

Read the five. The Compliance Officers' Handbook, issued 10 September 2024, amended August 2026. The Annual Sanctions Compliance Report guide, issued the same day, amended August 2026. The Terrorist Financing Alert, issued 9 July 2024, amended March 2026. ICPAC's suggested practice guide for Administration Service Providers, issued 8 November 2014, amended March 2026. The Guidance Paper on the Client Risk Based Approach, issued 3 November 2019, amended April 2026. Then last year's: Best practices for AML/CFT Compliance, issued 30 July 2020, amended October 2025, and the Guidance on Transaction Monitoring performed as part of AML/CFT and Sanctions Checks, issued 17 July 2020, amended October 2025.

If your client risk methodology says it follows the 2019 Client Risk Based Approach paper, or your monitoring section points at the 2020 transaction monitoring guidance, or your ASP procedures rest on a practice guide you last pulled in 2014, the circular is telling you those documents have been amended since. It does not tell you what changed in any of them, and neither do I. The listed guides are not in this circular; only their titles and dates are.

The two Directives sit in the same paragraph of the circular: ICPAC would also like to draw Members' attention to the AML/CFT Directive and the Sanctions Directive, both revised in June 2026. Their own amendment records agree. The AML/CFT Directive's table of amendments records a tenth entry dated 30 June 2026, and the Sanctions Directive's front page lists 8 May 2022, 17 July 2024 and 30 June 2026. A manual whose opening paragraph cross-references the AML/CFT Directive by a 2024 date is citing it as it stood before that June 2026 amendment.

Two honest limits. The circular's list of material from other organisations carries its own footnote saying the list is not intended to be exhaustive, so treat it as a pointer rather than a register. And the circular closes by reminding members that a dedicated monitoring and compliance section on the website brings together FAQs, templates, Compliance Briefs and other material, regularly updated, with members encouraged to consult it regularly for anything the circular does not specifically address. Encouraged is the word used, and it is the right one to carry.

The practical job this week is small and unglamorous. Take the amendment column, put it beside your manual's citations, your training slides and your file review checklist, and mark every reference whose date is older than the date ICPAC now prints beside that title. Then go and read the ones you marked.

Not legal advice. Verify against the primary source before acting.

Sources

• PRIMARY.
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