The Financial Intelligence Centre (FIC) on 1 September published Revised Guidance Note 7A, which provides accountable institutions with authoritative guidance on implementing key aspects of the Financial Intelligence Centre Act (FICA).
Revised Guidance Note 7A replaces Guidance Note 7A, which was published on 13 February 2025, and Guidance Note 7, which was published on 2 October 2017.
The FIC says the Revised GN 7A provides technical updates, including bringing it in line with the General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act and the Public Compliance Communication 59, which sets out the latest guidance on beneficial ownership.
The most significant changes in the Revised GN 7A include:
Risk Management and Compliance Programme
The Revised GN expands what must be in the Risk Management and Compliance Programme (RMCP) documentation, and the need for board/management oversight. It emphasises that RMCP documentation must describe the RMCP (not merely reference other materials) so the board can meaningfully assess its adequacy.
The Revised GN explicitly warns that inadequate RMCP documentation presented to the FIC or a supervisory body may be regarded as non-compliance and may attract administrative sanctions. It provides more examples of compliance failures.
Treatment of Politically Exposed Persons (PEPs)
GN 7A used the terms “foreign prominent public officials” and “domestic prominent influential persons”, whereas the Revised GN standardises to “foreign politically exposed persons” (FPEPs), “domestic politically exposed persons” (DPEPs), and “prominent influential persons” (PIPs) to distinguish public and private sector risks.
The Revised GN removes the detailed bullet lists of positions (listing roles such as presidents, ministers, judges with website links) and instead refers directly to Schedules 3A (DPEPs), 3B (FPEPs), and 3C (PIPs). The Revised GN notes that Schedule 3C may be delayed, and National Treasury will explore ways to make information available to accountable institutions.
Implementation of resolutions on freezing of assets
The Revised GN repeats the obligation on accountable institutions to freeze property and transactions pursuant to United Nations Security Council resolutions and the notices published by the Minister of Finance and the FIC.
However, the earlier GN tied the inclusion of Targeted Financial Sanctions measures to FATF Recommendation 7, whereas the Revised GN expands the scope to FATF Recommendation 6, covering the suppression of terrorism financing alongside proliferation financing.
