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Get Compliant from Anywhere, Easy and Fast!

0800 007 269 (Toll Free)
Get Compliant from Anywhere, Easy and Fast!

Table of Contents

  • Business Compliance

FIC Alert: Your Business Might Fall Under Accountable Institution Rules

  • This article is written for educational purposes and does not constitute legal advice.
FIC Alert for South African Businesses, learn more about your obligations

If you’re running a law firm, an estate agency, a consulting or accounting business in South Africa, there’s a good chance you’ve heard of the FIC – or the Financial Intelligence Centre.

Many entrepreneurs don’t realise that their business may be classified as an “accountable institution” under the FIC Act, even if they’ve never registered or submitted a compliance report.

The Financial Intelligence Centre Act, 2001 (FICA) sets out serious obligations for certain businesses, and failing to meet them can lead to administrative sanctions, reputational damage, or even financial penalties.

Team discussing the requirements of an accountable institution in terms of FICA Legisltation in South Africa

What Is the FIC?

The Financial Intelligence Centre (FIC) is South Africa’s financial intelligence unit. Its role is to combat:

  • Money laundering
  • Terrorist financing
  • The expansion or distribution of weapons of mass destruction.


To do this, the FIC collects and analyses financial data from businesses that are most at risk of being used to move illicit funds. These are known as accountable institutions.

What Is the Meaning of “Accountable Institution”?

An accountable institution is a business or professional that the FIC has identified as having a higher risk of being misused for money laundering, terrorist financing or other criminal activities.

These institutions are legally obligated to follow the rules of the FIC Act, including registering with the FIC and implementing an internal Risk Management and Compliance Programme (RMCP).

The full list of accountable institutions appears in Schedule 1 of the FIC Act, which was most recently updated to include even more business types. You can find it here.

You Might Be an Accountable Institution Without Knowing It

Here are some examples of accountable institutions you might not realise fall under FIC compliance:

Legal Practitioners

Attorneys and advocates who:

  • Handle client funds
  • Manage trusts or property transfers
  • Facilitate business transactions

Trust and Company Service Providers

Accountants or consultants who:

  • Help clients register or manage companies
  • Offer trust creation or secretarial services
  • Act as nominee shareholders or directors

Estate Agents

Any estate agency that:

  • Handles the sale or letting of property on behalf of clients
  • Processes large amounts of funds through trust accounts

Consultants

Business consultants who offer corporate structuring or company formation services also fall under this scope if they provide trust or company services.

Why This Matters to Your Business

Right now, many business owners and professionals are unaware of their FICA obligations.

In fact, recent updates from the FIC show that a large portion of accountable institutions in sectors like legal, real estate, and accounting have not yet submitted their mandatory Risk Management and Compliance Programmes (RMCPs).

For example:

  • Only 4% of legal practitioners (695 out of 19046) have complied.
  • Just 6% of estate agents (568 out of 9086) have submitted their RMCPs.
  • Even in the accounting space (trust and company service providers), compliance is as low as 11–13% (250 out of 2082).


Source: https://www.fic.gov.za/2025/03/10/web-notice-urgent-update-adherence-to-call-for-submission-of-rmcps/

If your business falls into one of the categories as highlighted in Schedule 1 of FICA and you haven’t registered with the FIC or submitted your RMCP you’re technically in breach of the FIC Act.

Even if it wasn’t intentional, non-compliance can lead to fines or enforcement action.

The Core Compliance Requirements Under the FIC Act

Once your business is classified as an accountable institution, there are five (5) key responsibilities you need to fulfil under the FIC Act.

Many SME’s which operate as Financial Service Providers acquire the services of an outsourced compliance officer to prevent having to employ a full-time compliance person.

Register with the FIC

All accountable institutions must register on the goAML system — the FIC’s official registration and reporting platform.

Develop and Implement an RMCP

You’re required to create a Risk Management and Compliance Programme (RMCP). This internal document explains how your business:

  • Identifies and assesses money laundering or terrorist financing risks
  • Applies due diligence when onboarding clients
  • Monitors transactions and flags suspicious activity
  • Keeps proper records of client and financial information
Expert tip on FIC Compliance, ensure your RMCP is up to date and relevant

The RMCP must be reviewed annually and approved by your business’s board or top management.

Conduct Customer Due Diligence (CDD)

You must verify your client’s identity and understand the nature of their business relationship with you especially for high-risk clients or large transactions.

You would have seen it when you dealt with your bank where they request your proof of address, ID and want to know if you are politically connected.

Submit Regulatory Reports

Depending on your operations, you may be expected to submit the following to the FIC:

  • Cash Threshold Reports (CTR)
  • Suspicious Transaction Reports (STR)
  • Terrorist Property Reports (TPR)

Train Staff and Maintain Records

You must ensure your employees are trained on FIC requirements and maintain complete records for a minimum of five (5) years.

It is recommended to get professional assistance in this regard from a South African service provider who is authorised to assist with FICA compliance.

What is the RMCP Submission Deadline?

In 2025, the FIC formally requested all accountable institutions to submit their RMCP documentation online via goAML by no later than 12 March 2025. The submission window remains open, but delays or incomplete submissions can result in penalties or compliance inspections.

Expert fica act tip, ensure you submit your RMCP on time

Submitting under the wrong item code is one of the most common reasons for rejection.

Not Sure If You’re an Accountable Institution? Start Here.

If you’re in the legal, property, consulting, or accounting space and aren’t sure whether your business qualifies as an accountable institution, here’s what to do next:

  1. Check Schedule 1 of the FIC Act
    Visit the FIC’s website or use their official reference guide to see if your business falls under a listed category such as:
    • Item 1: Legal practitioners
    • Item 2: Trust or company service providers (often accountants or consultants)
    • Item 3: Estate agents
  2. Determine if You’ve Registered with FIC
    If not, you’ll need to register your business via the goAML platform and appoint a compliance officer.
  3. Prepare and Submit Your RMCP
    Drafting your Risk Management and Compliance Programme is mandatory. You can find templates and guidance directly from the FIC’s resource library.

Compliance Is About More Than Avoiding Fines — It’s About Building Credibility

South Africa’s regulatory landscape is tightening — and fast. New requirements like the FIC Act compliance for Accountable Institutions is part of a broader national push to combat financial crime, improve transparency, and align with international standards.

Whether you’re an estate agent, accountant, consultant, or legal advisor, FIC compliance is just one aspect of responsible business. Real credibility comes from consistently meeting all regulatory requirements — from Beneficial Ownership to tax and industry-specific obligations. It’s how you earn trust, unlock bigger opportunities, and grow with confidence.

If you’re looking to:

  • Start a new business in a compliant, fast, and stress-free way
  • Get your business admin sorted out so you can focus on growth
  • Avoid missing deadlines or facing penalties

Let us take care of your compliance, so you can take care of your clients.

Contact us today!

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