In November 2022 the Government Gazette published changes to Schedules 1, 2 and 3 of the Financial Intelligence Centre Act (FICA). The changes increased the number of institutions and businesses identified as Accountable Institutions who are subject to fulfill all FICA requirements. One of the new categories added as an Accountable Institution is that of High-Value Goods Dealers (HVGDs).
Since the announcement there has been considerable uncertainty among individuals as to whether their business falls within this category. To provide clarity, we have compiled an infographic detailing some of the most important FICA facts you need to know as a HVGD.
1. What is a HVGD as defined by the FIC?
A HVGD is a person (both natural and juristic) that conducts business by dealing with high-value goods and receives payment(s) of R100 000.00 or more. In order to fall within this category, the good(s) should be any single physical item valued at R100 000.00 or more. The FIC’s Public Compliance Communication 58 (PPC 58) clarifies how this definition should be interpreted and applied.
2. What is required of a HVGD?
As per the FIC Act, a HVGD is an Accountable Institution and therefore must comply with all the FICA requirements. The first step is to register on the FIC website, in terms of section 43B of the FIC Act. Read more about the other key FICA requirements here.*
3. What are some examples of items that fall within the HVGD category?
Heavy equipment, machinery, Kruger Rand dealers (the coin can be either gold, platinum or silver), motor vehicles, yachts, vehicle parts, and any precious metals / stones and art over the value of R100 000.00 are all examples of HVG items.
4. What items are excluded from HVGDs?
Excluded from the definition of high-value goods are non-tangible items e.g. shares and trading stock. In other words, the high-value good must be an actual physical item.
5. Is a good still classified as a HVG if it is not purchased “new”?
New and second hand goods of the value of R100 000.00 or more qualify as High Value Goods.
6. What if I only stock just a few items worth
R100 000.00 but most of my inventory are much lower price points?
If any single item in the inventory can be sold for R100 000.00 or more, the business is considered as a HVGD.
7. What happens if an item is valued at R100 000.00, but is paid for in smaller transactions?
Regardless of the payment structure or schedule, whether in a single payment or a series of smaller structured payments, if the sale value of the item equates to R100 000.00 or more, it qualifies as a high value good.
8. What is a common misconception about HVGDs?
A common misconception is that buying multiple items of a lesser value that amount to R100 000.00 or more is considered a high-value goods deal. This is not true.
9. Why are HVGDs listed as Accountable Institutions?
HVGDs are vulnerable to criminals for money laundering and terrorist financing. Research shows that criminals often seek to buy high-value goods, which can easily be converted into cash and used to transfer value, and your business could be prone to such abuse.
On 31 March 2026, the Financial Intelligence Centre (FIC) officially issued Directive 11 of 2026, mandating High-Value Goods Dealers and other Accountable Institutions (AIs) to submit their 2026 Risk and Compliance Return (RCR) electronically by 31 July 2026.
Directive 11 came into effect on 1 April 2026. The questionnaire aims to provide the FIC with an understanding of how Accountable Institutions understand and manage money laundering, terrorist financing, and proliferation financing risks in various sectors within South Africa. They are looking to test your business to see if you understand the risk your business faces, how you measure it, if you know your clients, do you know how to identify something suspicious and if you act – and how.
For a clear breakdown of what Directive 11 requires and answers to the most common questions, take a look at our Directive 11 FAQ guide.
Download our infographic to discover the most important FICA facts about HVGDs.
