FIC Issues Warning to Accountable Institutions to Submit Risk and Compliance Returns

The Financial Intelligence Centre (FIC) has issued a stern warning to accountable institutions, including accountants, regarding non-compliance with the mandatory filing of Risk and Compliance Returns (RCRs). Businesses that fail to comply face financial penalties ranging from R10,000 to R50,000.

What You Need to Know

• Am I an Accountable Institution?

  Accountants and firms providing services as trust and company service providers, estate agents, and crypto asset service providers fall under the scope of FIC Directives 6 and 7.

  For example, accountants who offer company or trust registration services fall under item 2. Trust and Company Service Providers must register with FIC as an accountable institution. If you uncertain whether you should register read our previous article and consult your CIBA FIC Registration and Reporting Guide under your member profile. You can also read more in the Reference Guide for All Accountable Institutions guide of the FIC.

• Submit your RCR to the FIC

  Filing RCRs helps identify money laundering and terrorist financing risks. Non-compliance exposes your business to reputational and financial damage.

  Directive 6 applies to the following accountable institutions:

  • Legal practitioners (item 1)

  • Trust and company service providers (item 2)

  • Estate agents (item 3)

  • Gambling institutions (item 9)

Submit your RCR following Directive 6 here.   

Directive 7 applies to the following items:

• Credit providers (item 11)

• South African Post Bank (item 14)

• High-value goods dealers (item 20)

• South African Mint Company (item 21)

• Crypto asset service providers (item 22).

Submit your RCR following Directive 7 here.   

• Consequences of Non-Compliance

Financial penalties were imposed on 286 businesses between November 2023 and November 2024. Non-compliance leads to harsher penalties over time, with repeat offenders at risk of escalating fines and enforcement action.

• What Are the Deadlines?

While initial deadlines for submission were May and July 2023, the FIC portal remains open for late submissions. Businesses are strongly advised to file their RCRs promptly to avoid additional sanctions.

Take Action Now

To stay compliant, accountants must:

• Establish whether you need to register as an accountable institution.

• Review the risk and compliance requirements under the FIC Act.

• File RCRs immediately if not already submitted.

• Ensure all documentation and processes align with the FIC's directives.

Non-compliance not only risks penalties but also undermines efforts to protect South Africa's financial system from criminal exploitation. Stay informed and proactive to safeguard your practice and reputation.

For more information, read your CIBA guide and visit FIC's website.