
FIC provides practical guide to RMCP submissions under Directive 12
The FIC has laid out the practical steps for accountable institutions facing their first RMCP submission deadlines under Directive 12.

The FIC has laid out the practical steps for accountable institutions facing their first RMCP submission deadlines under Directive 12.

The FIC’s new manual explains when institutions should screen clients, how they must assess possible matches, and what follows when sanctioned property is identified.

Draft PCC 126 sets out when dealers fall within FICA’s high-value goods category and explains the resulting registration and compliance obligations.

Higher-risk institutions were found wanting on RMCPs, customer due diligence, registration requirements, and targeted financial sanctions screening.

Demand for financial intelligence remained high as the Centre supported court proceedings, asset-recovery work, and the Madlanga Commission.

CASPs helped the FIC exceed its illicit-flow intelligence target, while only 176 of the 362 registered providers submitted Directive 7 returns.

The Court says confidential information cannot be disclosed simply because it may be relevant to litigation, reinforcing the protections built into FICA.

The sanctions against Capitec, Ninety One Assurance, and Albaraka arose from inspections conducted between 2021 and 2023.

The sanctions cover a range of shortcomings, from deficient RMCPs and customer checks to sanctions screening, registration, and failures to provide information.

The affected institutions face October deadlines, while the consultation feedback provides guidance on how the requirement applies in practice.

Institutions will have to identify and verify owners, assess their honesty and integrity at least every two years, and report beneficial-owner information to regulators.

The Bill would introduce annual reporting and accounting duties and establish a prudent-investor framework, while revising the beneficial-ownership obligations.

The final Guidance Note makes targeted changes, but the regulator’s feedback discloses how it weighed industry concerns and refined key aspects of the guidance.

Many institutions have left registration too late, submitted the wrong documents, or filed branch returns instead of consolidated legal entity returns.

The draft directive will introduce a new recurring compliance obligation, with updated programmes also having to be lodged within 10 business days of approval.

The Centre has refined the directive’s scope and addressed concerns over its legal basis, administrative burden, and practical application.

Less than half of the first group of accountable institutions had submitted their returns by mid-July, while submissions from the second group are low.