Draft FIC directive proposes detailed location reporting

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The Financial Intelligence Centre (FIC) has invited comments on Draft Directive 10 of 2025, which sets out proposed requirements for accountable institutions to provide detailed information about their geographic locations when registering with the Centre.

According to the FIC, the purpose of Draft Directive 10 is to specify the particulars that must accompany the registration of an accountable institution in accordance with section 43B(2) of the Financial Intelligence Centre Act. These particulars relate to the location of an institution’s head office, branches, subsidiaries, and branches of subsidiaries, whether located within or outside the Republic of South Africa.

The directive is intended to enable the FIC and supervisory bodies to determine and understand the group structures of accountable institutions, including their geographic footprint. This information is intended to support a more informed application of risk-based supervision, particularly in relation to group-wide compliance.

The FIC has clarified that the information required under the draft directive is not intended to require the separate registration of branches or subsidiaries that are not separate legal entities, nor to classify such branches or subsidiaries as accountable institutions in their own right.

Draft Directive 10 applies to every accountable institution referred to in Schedule 1 of FICA. This includes institutions that operate from a single location, as well as those with multiple branches or subsidiaries, whether domestically or across borders.

The directive introduces definitions for key terms, including “head office”, “branch”, and “subsidiary”, to provide clarity regarding the entities and locations in respect of which information must be disclosed.

Under paragraph 5 of the draft directive, an accountable institution that operates in more than one geographic location would be required, at the time of registration with the FIC, to provide detailed information relating to:

  • Its head office, where applicable;
  • Branches within the Republic of South Africa;
  • Branches outside the Republic;
  • Subsidiaries with head offices in South Africa;
  • Subsidiaries with head offices outside South Africa;
  • Branches of subsidiaries located in South Africa; and
  • Branches of subsidiaries located outside South Africa.

For each of these categories, the draft directive specifies that the following particulars must be provided, where applicable:

  • The name of the head office or branch;
  • The licence number, if applicable;
  • The registration number, if applicable;
  • The business address; and
  • The surname, first name, and contact particulars of a person who may be contacted in relation to the registration of the accountable institution.

Draft Directive 10 further provides that accountable institutions already registered with the FIC on the date the directive comes into force would be required to update their registration details within 90 days of the commencement date.

In addition, institutions would be required to update the information provided under the directive within 90 days of any change to the relevant particulars.

Failure to comply with any provision of Draft Directive 10 would constitute non-compliance. In such cases, an accountable institution may be subject to an administrative sanction in terms of section 45C of FICA.

Comments must be submitted electronically using the designated online consultation form. Questions relating to the consultation process may be directed to the Centre via email at consult@fic.gov.za.

The deadline for the submission of comments is the close of business on Friday, 13 February 2026.

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