The FIC (Financial Intelligence Centre) recently published three important updates that affect accountable institutions in South Africa. We break down what these updates mean for your business.
Directive 10 – Geographic Particulars
The FIC’s Directive 10 took effect on Friday, 31 July 2026. It requires various accountable institutions to disclose detailed geographic particulars of their business to the FIC on the GoAML platform.
The purpose of this Directive is for the FIC to understand the geographic location of an accountable institution’s head office, branch offices, each subsidiary’s head office, and the branch offices of such subsidiaries, in or outside the Republic of South Africa.
Which accountable institutions must comply?
-
Legal Practitioners
-
Trust & Company Service Providers
-
Estate Agents
-
Licensed Gambling Businesses
-
Credit Providers (excluding Banks)
-
SA Postbank
-
High Value Goods Dealers
-
SA Mint
-
Crypto Asset Service Providers
What is expected from you?
For new accountable institutions, the information must be completed at the time of registering with the FIC. For accountable institutions that are already registered, this must be done within 90 (ninety) days of the publication of the Directive. This date being the 31st of October 2026.
View the FIC’s Directive 10 info sheet for more information.
We would recommend you ensure that GoAML is updated with your geographic particulars and in parallel check that all other recorded information remains accurate.
Guidance Note 7B – Replaces Guidance Note 7A
The FIC Guidance Note 7B was published on 3 August 2026, officially replacing Guidance Note 7, Guidance Note 7A, and Revised Guidance Note 7A with immediate effect.
It sets out the FIC’s expectations for accountable institutions to implement effective measures to manage money laundering, terrorist financing and proliferation risks in line with the FIC Act.
Some updates include: introducing proliferation financing, new expectations around assessing risk for new products and services, and a reminder that low-income clients cannot automatically be treated as lower risk.
Click here to download Guidance Note 7B.
What is expected from you?
Accountable institutions should revisit their Risk Management and Compliance Programmes (RMCPs), business risk assessments, and due diligence procedures to ensure that they reflect the changes introduced.
Draft Directive 12 – RMCP Submission
Draft Directive 12 has been released for public consultation and comment. It aims to enable the FIC to monitor Accountable Institutions' compliance with the annual submission of RMCPs. The comment period closed on 21 August 2026, and no further information has been published at this stage.
As per the Draft, this Directive would apply to:
-
Legal Practitioners
-
Trust & Company Service Providers
-
Estate Agents
-
Licensed Gambling Businesses
-
Credit Providers (excluding Banks)
-
SA Postbank
-
High Value Goods Dealers
-
SA Mint
-
Crypto Asset Service Providers
What is expected from you?
The Directive would require the identified accountable institutions to submit a copy of their RMCP to the Centre via the GoAML platform. Legal practitioners, TCSP’s, Estate Agents and Gambling Businesses must complete this by 30 September. All other identified categories must be submitted by 31 October.
We would recommend ensuring your RMCP is up to date and signed off in preparation for this requirement coming into force.
Click here to view Draft Directive 12
Need Assistance with your RMCP?
nCino KYC has a well experienced team of FICA compliance experts that can work together with you to compile an RMCP document that is tailored to your business. To learn more, reach out to our team.
