Accountable institutions must ensure they are correctly registered

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Accountable institutions must ensure they are registered with the Financial Intelligence Centre (FIC) under the correct item numbers per Schedule 1 of the Financial Intelligence Centre Act (FICA).

In addition, accountable institutions that are wrongly registered as “Business entities with a reporting obligation” must amend their details to the correct Schedule 1 item.

Section 43B of FICA requires any person or entity listed in Schedule 1 to register with the FIC. Registration must be done within 90 days of the accountable institution commencing business (Regulation 27A of the Money Laundering and Terrorist Financing Control Regulations). Institutions must register via the web portal of the FIC’s registration and reporting platform, goAML.

An accountable institution should note that if its business activities fall under more than one item designation in terms of Schedule 1, it will have to register each business separately under each applicable item, based on its business activity.

Failing to register with the FIC constitutes non-compliance in terms of section 61A of FICA and is subject to administrative sanctions.

Where a person or entity does not fall within any Schedule 1 item and is therefore not an accountable institution, that person or entity may register as a “Business entity with a reporting obligation in terms of section 29 of FICA”, to enable that person or entity to submit a suspicious transactions or activity report to the FIC.

In a Notice published on 7 August, the FIC said certain institutions might be incorrectly registered as business entities with a reporting obligation. These institutions are requested to amend their registration item via the goAML platform.

The Centre said accountable institutions should follow these steps on goAML to amend their registration:

  • Select “MY GOAML” from the menu, then click “My Org Details”.
  • Change the organisation type to the correct accountable institution item.
  • Once amended, click “Submit request”.
  • Click “Continue”.
  • You will receive a reference number called a SHREG number after submitting the request.

The FIC said it will verify the remaining entities registered as “business entities with a reporting obligation” from 31 May.

Where registrations are clearly incorrect in terms of Schedule 1, the FIC might sanction the persons or entities.