FIC Draft Guide on Money or Value Transfer Service (MVTS) Providers
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The Financial Intelligence Centre (FIC) released Draft Public Compliance Communication 118A (PCC 118A) for consultation to clarify who qualifies as a Money or Value Transfer Service (MVTS) provider under the Financial Intelligence Centre Act (FIC Act). This follows amendments to Schedule 1 of the FIC Act (published in Government Gazette 47596), which came into effect on 19 December 2022.
The guidance is now open for public comment until 25 April 2025, and aims to help institutions understand their registration, reporting, and compliance obligations — especially where there’s uncertainty about whether a business falls under Item 19 of the FIC Act.
💼 Who Is Affected?
Money or Value Transfer Service (MVTS) providers are businesses or individuals that assist people send, receive, or move money or value from one person or place to another. This can include formal services like banks and fintech apps, or informal systems like hawala. MVTS providers can operate within South Africa or across borders, and they are required to register with the Financial Intelligence Centre (FIC) and comply with anti-money laundering laws.
If your or your client’s business transfers money or value on behalf of others, whether domestically or across borders, it may qualify as an MVTS provider. This includes:
Banks and authorised dealers in foreign exchange
Hawala-type operators and informal remittance dealers
Cash couriers, cash aggregators, and fintechs
Mobile money or airtime transfer providers
Non-bank payment service providers
New payment method providers.
📋 What the Draft Guidance Covers
Clarifies who fall under an MVTS: The FIC interprets MVTS broadly – covering both formal (banks, fintechs) and informal (hawala, cash agents) services.
Lists who must register as accountable institution: All MVTS providers — domestic or cross-border — must register with the FIC under Item 19 of Schedule 1, even if they already fall under another item.
Outlines reporting responsibilities, i.e. suspicious transactions (STRs), cash threshold reports, international funds transfers and terrorist property reports
Explains who is excluded: Entities that don't deal directly with end-users (e.g., payment clearing houses or system operators) are not considered MVTS providers.
Describes risks and red flags: The FIC provides examples of potential money laundering and terrorist financing warning signs that MVTS providers must monitor.
⚠️ Why It Matters
MVTS providers are seen as high-risk for abuse by criminals due to the ease, speed, and often anonymous nature of transactions. This updated guidance makes it clear that both formal and informal players in the value-transfer space must take their AML/CFT obligations seriously — or risk regulatory action.
📅 What Are The Next Steps?
Review the draft PCC 118A and check if your business activities fall under Item 19
Register with the FIC, if applicable
Strengthen your AML/CFT compliance programme
Submit comments by 25 April 2025 via the FIC’s website submission link.
