A practical RMCP submission control

Before an estate agency closes its RMCP submission task, work through the process in sequence.

1. Confirm the accountable institution

Check that the RMCP is being submitted against the correct legal entity and FIC organisation profile.

This matters particularly where:

• an agency operates more than one entity;

• different branches operate under different companies;

• the brand name differs from the registered legal entity;

• there has been restructuring;

• ownership has changed; or

• the principal is unsure which organisation was originally registered with the FIC.

Do not discover an entity problem at the submission screen.

2. Confirm that the RMCP is the final approved version

The document submitted should be the RMCP that has actually been approved by the appropriate authority within the accountable institution.

Before submission, confirm:

Version → Date → Approval → Approver → Evidence

There should be no uncertainty about which version is final.

A document named:

RMCP final FINAL new corrected 2.pdf

is not a version-control system.

3. Retain the exact submission copy

Once the approved version has been identified, retain the exact PDF used for the submission.

That means the agency should be able to answer:

“Show me the exact RMCP that was submitted to the FIC.”

without recreating it afterwards.

This becomes particularly important when the RMCP is subsequently amended.

4. Log into the correct goAML organisation

Confirm that the authorised user is working within the correct organisation profile.

Where a user has access to more than one entity, this deserves particular attention.

The legal entity, FIC Org ID and Schedule 1 classification should all make sense before proceeding.

5. Upload the approved RMCP

Upload the exact approved document in accordance with the FIC’s submission requirements.

But do not stop here.

The presence of the file is not proof of completed submission.

6. Complete the mandatory comment

This is the step highlighted by the FIC on 9 October 2026.

A comment must be inserted as part of the submission process.

The FIC has confirmed that if the comment is not entered, the submission button will not become active.

For J9Compliance, this is now a hard submission control.

The RMCP should not be regarded as ready for final closeout until this step has been completed.

7. Complete the final submission action

Proceed through the required submission steps until the request has actually been submitted.

Do not interpret:

File uploaded

as:

Submission completed.

This distinction should be built into the agency’s internal checklist.

8. Look for the FIC acknowledgement

The FIC’s 9 October communication confirms that once the RMCP has been received, the FIC issues an acknowledgement of receipt.

Retain it.

It belongs in the agency’s compliance evidence.

If an acknowledgement is expected but cannot be located, investigate before treating the submission as closed.

9. Record the evidence

The compliance record should capture:

What was submitted?

Which entity submitted it?

Who submitted it?

When was it submitted?

Which version was submitted?

Was the mandatory comment completed?

What evidence proves receipt?

That creates a defensible submission trail.

Do not wait until 31 October to test this process

The 31 October 2026 deadline is a regulatory deadline.

It should not be treated as the agency’s internal production date.

This is particularly important where principals still need to:

• review amendments;

• approve the RMCP;

• resolve entity or FIC registration questions;

• regain goAML access;

• verify authorised users;

• confirm the correct organisation profile; or

• correct deficiencies before submission.

If the RMCP is ready on 16 October, submit it on 16 October.

If it is ready on 21 October, submit it on 21 October.

There is no operational benefit in deliberately accumulating completed submissions for 30 or 31 October.

J9Compliance uses the following Rolling Close Protocol:

REVIEW → FIX → APPROVE → SUBMIT SAME DAY → CAPTURE EVIDENCE → CLOSE

Once a client is genuinely ready, the submission should move to completion.

What if goAML does not work?

Technical problems can happen.

They become much harder to manage when first discovered at the deadline.

Before submission day, agencies should therefore confirm that:

• the correct authorised user can log in;

• the correct organisation is visible;

• the relevant organisation details are accurate;

• the final RMCP is available;

• the user understands the submission route; and

• there is enough time to resolve an unexpected issue.

If a technical problem occurs, preserve evidence.

That may include:

• screenshots;

• error messages;

• dates and times;

• correspondence;

• FIC query references; and

• records of attempted resolution.

Do not rely solely on somebody remembering that “the system wasn’t working”.

Submission does not mean your RMCP is compliant

There is another important distinction.

Successfully submitting an RMCP does not mean that the FIC has approved the adequacy of that RMCP.

The FIC has previously cautioned accountable institutions against equating submission with full compliance.

The RMCP must still accurately describe the institution’s risk-based approach, controls and operating procedures — and those controls must be capable of being implemented and evidenced.

So there are really two different questions:

Question 1:

Did we successfully submit the RMCP?

That is a submission-control question.

Question 2:

Does the RMCP accurately describe a compliant system that our agency actually operates?

That is an operating-compliance question.

Both matter.

RMCP submission close is not necessarily programme close

This distinction is especially important for agencies currently updating their compliance environments.

A successful RMCP submission may close the submission workstream.

It does not automatically mean that every implementation activity is complete.

There may still be work relating to:

• staff training;

• staff acknowledgement;

• customer due diligence procedures;

• beneficial ownership;

• targeted financial sanctions screening;

• risk assessment;

• record keeping;

• reporting procedures;

• registers;

• file controls;

• monitoring;

• testing; and

• corrective action.

These should not disappear because the PDF has been submitted.

Where actions remain outstanding, they should have:

an owner → an action → a due date → evidence → review

That is how a submitted RMCP becomes a living compliance programme.

The principal’s final RMCP submission checklist

Before closing the submission, ask:

PRE-SUBMISSION

☐ Correct legal entity confirmed
☐ Correct FIC Org ID confirmed
☐ Correct Schedule 1 registration confirmed
☐ goAML access tested
☐ Correct authorised user confirmed
☐ Final RMCP completed
☐ RMCP formally approved
☐ Approval evidence retained
☐ Exact approved PDF identified

SUBMISSION

☐ Correct goAML organisation opened
☐ Exact approved RMCP uploaded
☐ Mandatory comment completed
☐ Final submission action completed

EVIDENCE

☐ FIC acknowledgement received
☐ Screenshot/reference retained where applicable
☐ Exact submitted RMCP retained
☐ Submission date recorded
☐ Submitter recorded
☐ Evidence filed in the compliance record

Only then should the agency be comfortable saying:

“Our RMCP has been submitted.”

31 October is not an upload exercise

The objective is not simply to get a PDF onto goAML before midnight.

The objective is to be able to demonstrate:

We reviewed it.

We fixed what needed fixing.

The correct authority approved it.

We submitted the correct version.

We completed the required submission process.

The FIC received it.

We retained the evidence.

And, importantly:

We are implementing what the RMCP says we do.

That is the difference between document compliance and operating compliance.

Need help getting to submission-ready?

If your estate agency is preparing for the 31 October 2026 RMCP submission deadline and you are uncertain about your RMCP, goAML readiness or submission controls, J9Compliance can help identify what still needs to be completed before closeout.

J9Compliance

Protect | Comply | Prosper

This article is intended as general compliance information and should be read together with the applicable FIC Act requirements, Directive 12 and current Financial Intelligence Centre guidance..