The Financial Services Commission of Mauritius continues to raise its standards for licensed investment dealers and advisers. Across capital adequacy, governance, and AML/CFT compliance, the FSC has signalled, through guidance notes, inspection findings, and enforcement actions, that it expects licensees to operate to standards consistent with the best-regulated jurisdictions globally. This briefing summarises the key developments that investment dealer and adviser licensees should be addressing in 2026.
Capital Adequacy: Increased Scrutiny of Risk-Weighted Assets
The FSC has increased its scrutiny of how licensees calculate and report their capital adequacy positions. In particular, inspectors have focused on whether licensees are appropriately risk-weighting off-balance-sheet exposures and whether internal capital adequacy assessment processes reflect the actual risk profile of their operations.
Licensees operating as Investment Dealers (Full Service) or those with underwriting activities should review their capital models against current FSC guidelines and stress-test their capital positions against plausible adverse scenarios. Where capital buffers are thin, proactive communication with the FSC is strongly advisable.
Governance: Board Composition and Independence
The FSC has reiterated its expectation that licensed investment dealers and advisers include at least one genuinely independent director: a director who has no material business relationship with the licensee, its management, or its controlling shareholders. The requirement for independence is substantive, not merely formal: the FSC will look through arrangements where a nominally independent director lacks the expertise or practical independence to exercise meaningful oversight.
Licensees should review their board composition and, where necessary, recruit appropriately qualified independent directors with relevant financial services experience. The FSC has shown willingness to require board changes where it is not satisfied with governance standards.
AML/CFT: Enhanced Due Diligence and Sanctions Screening
The FSC's AML/CFT inspections have consistently identified deficiencies in three areas: enhanced due diligence for politically exposed persons (PEPs), sanctions screening procedures, and transaction monitoring calibration.
PEP due diligence: The FSC expects EDD applied to PEPs as a matter of course, with documented senior management approval for any PEP onboarding. The EDD file should include an assessment of source of wealth and source of funds, a documented risk assessment, and a defined schedule for periodic review.
Sanctions screening: Real-time screening against the major international lists (UN, OFAC, EU, UK) is now a baseline expectation. Licensees that screen only at onboarding, or that use manual processes for ongoing monitoring, should upgrade to automated screening tools.
Transaction monitoring: The FSC has found that many licensees operate monitoring systems with thresholds configured without reference to the actual risk profile of their client base. Licensees should document the rationale for monitoring thresholds and review them at least annually.
Cybersecurity and Technology Risk
The FSC issued a guidance note on cybersecurity expectations for licensed entities. Licensees are expected to have a documented cybersecurity framework including regular vulnerability assessments, incident response plans with defined escalation procedures, and appropriate controls over third-party technology providers. Cybersecurity will feature more prominently in on-site inspections going forward.
Aurevya Wealth's regulatory advisory team supports licensed investment dealers and advisers with pre-inspection readiness assessments, AML/CFT programme reviews, and governance advisory services.