The Financial Intelligence Centre (FIC) on 1 September published Revised Guidance Note 7a, effective September 1, 2025, which replaced both Guidance Note 7 and Guidance Note 7A. While many requirements remain consistent with current guidance, this revised version updates some standardised terminology but is useful to remind us of critical compliance obligations.
Terminology Updates:
Some terms were updated, but the underlying meaning did not change. We recommend updating your RMCP with these changes at the next review cycle.
Reminders around Risk:
The guidance re-emphasizes that Accountable Institutions must:
- Comprehensive Assessment: Conduct comprehensive entity-wide AML/CFT/CPF risk assessments across their entire structure and include all relevant risk factors such as: products, services, technologies, delivery mechanisms.
- Document Outcomes: Document their risk assessment, risk tolerance and risk appetite levels
- Test effectiveness: Regularly review assessments and controls to ensure they remain appropriate and effective
Reminders around Responsibility:
The guidance reiterates:
- Strict Non-Delegation: Board or person(s) with the highest authority CANNOT delegate Risk Management and Compliance Program (RMCP) approval to committees
- Personal Liability: Board members and senior management bear personal responsibility for FIC Act compliance and must demonstrate they have "applied their minds" to RMCP adequacy and approval
- Enforcement: Non-compliance may result in personal sanctions under Section 61
While these reminders reinforce existing obligations, we recommend regularly reviewing your current compliance framework and RMCP on at least an annual basis and when regulations, guidance or your business changes to ensure alignment with the latest requirements and that your RMCP and processes stay effective. Our compliance team is available to support you in reviewing your current practices and ensuring full alignment with these reinforced requirements. Please contact us if you require assistance or have any questions about these updates.
Contact us for Compliance Assistance
Ensuring you are fully compliant with South Africa’s reporting obligations can be complex. If you're looking for expert support and guidance on your compliance needs, contact us today for our comprehensive compliance services. Our team can help you navigate the reporting process, stay compliant, and mitigate the risks of non compliance.
%20Guidance%20Explained.jpg)
.jpg)