The Financial Intelligence Centre (FIC) has published an information sheet setting out what accountable institutions need to know about submitting their Risk Management and Compliance Programmes (RMCPs) under Directive 12.
The two-page guide does not introduce new requirements. It brings together the key requirements of the directive and provides practical guidance on who must submit an RMCP, when submissions are due and how the documents must be submitted through the FIC’s goAML platform.
Read: FIC revises annual RMCP deadlines in final Directive 12
Directive 12 came into effect on 7 September. It requires specified accountable institutions to submit documentation describing their RMCPs to the FIC each year.
The first submissions are due in October.
Who must submit?
Directive 12 applies to accountable institutions listed under items 1, 2, 3, 9, 11, 14, 20, 21 and 22 of Schedule 1 to the Financial Intelligence Centre Act (FICA).
These include:
- legal practitioners;
- trust and company service providers;
- estate agents;
- gambling institutions;
- specified credit providers;
- the South African Postbank;
- dealers in high-value goods;
- the South African Mint Company; and
- crypto asset service providers (CASPs). Directive 12 on the Submission …
Credit providers that form part of a bank, mutual bank or co-operative bank group are excluded from Directive 12.
The FIC also clarifies the position where an institution operates through branches.
Where branches are not accountable institutions in their own right, only one RMCP submission is required. A branch that is itself a standalone accountable institution must submit its own RMCP.
Where a subsidiary has its own branches outside South Africa, details of each foreign branch must also be provided.
Two deadlines to remember
The FIC has confirmed the first submission deadlines:
RMCP submissions opened on 7 September and must be made within these prescribed periods.
How to submit the RMCP
The information sheet provides a five-step process for submitting an RMCP through goAML.
The approved RMCP must first be saved as a PDF using the prescribed naming convention: YYYYMMDD_RMCP.pdf
The date must be the date on which the RMCP was approved by the board, senior management or the person with the highest authority. The FIC gives 20250304_RMCP.pdf as an example.
The institution must then:
- Log into the goAML registration and reporting platform.
- Click on the profile at the top right and select “My Org Details”.
- Enter “RMCP submission” in the comments section below the organisation’s address. This activates the submission request.
- Select “Upload” under “Attachment” and upload the RMCP PDF.
- Click “Submit Request”, followed by “Continue” to complete the submission.
The step-by-step process gives institutions a practical checklist for completing their first submissions.
What happens if an RMCP is not submitted?
The FIC warns that late submission, failure to submit an RMCP, or failure to update an RMCP within the required period will be regarded as non-compliance with the FIC Act.
This may result in an administrative sanction, including a financial sanction.
For institutions covered by Directive 12, the immediate task is to check which Schedule 1 category applies, confirm the relevant deadline and ensure that the approved RMCP is ready for submission through goAML.
