
FIC revises annual RMCP deadlines in final Directive 12
The affected institutions face October deadlines, while the consultation feedback provides guidance on how the requirement applies in practice.

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

An arrangement intended to cost R10m for 10 months ran for years, absorbed R26.6m in seven months, and included claims work outside its scope.

SCOPA says linking attorneys’ success fees to claim values may create incentives to inflate claims, while billions in legal costs flow through a small group of firms.

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.

The FIC says fewer than 12% of accountable institutions facing the first filing deadline had submitted their returns by the middle of this month.

PCC 60 largely preserves the draft framework but clarifies how newly registered firms must report and confirms that third parties may not submit returns.

The specified accountable institutions have until 30 June or 31 July to complete and submit their RCRs.

Penalties cannot be based on periods before the FIC assumed supervisory authority, and remediation must be fully considered when imposing sanctions.

The draft directive requires certain accountable institutions to submit RCR questionnaires covering information from 2023 to 2026.

The Financial Intelligence Centre issues a stern reminder to designated non-financial entities – particularly legal practitioners and estate agents – to file their overdue risk and compliance returns.

Accountable institutions that did not pay the smaller fine or remediate their non-compliance now face harsher penalties.

The firm of attorneys said its non-compliance was not intentional and was the result of a lack of awareness.

The Financial Intelligence Centre sets out legal practitioners’ obligations under the FIC Act.

Non-compliant accountable institutions are hindering efforts to get South Africa off the grey list, says the Financial Intelligence Centre.