FIC: Draft Directive 10 – Geographic locations of Accountable Institutions

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FIC: Draft Directive 10 – Geographic locations of Accountable Institutions

• 09 January 2026
• Money Laundering
• South African Accounting Academy

Summary:
The Financial Intelligence Centre (FIC) has issued Draft Directive 10 relating to the information pertaining to geographic locations of Accountable Institutions, which must be provided upon registration, or updated (if already registered).

Article:

This draft Directive requires accountable institutions, as part of the registration process, to provide information regarding the head office, branches and subsidiaries in and outside the Republic to determine the geographic location for group structures. 

The purpose of this Directive is to specify, in accordance with section 43B(2) of the Act, the particulars concerning an accountable institution’s head office, branches, subsidiaries and branches of subsidiaries in the Republic or outside the Republic that must accompany its registration in terms of section 43B(2) of the Act. 

This Directive applies to every accountable institution referred to in Schedule 1 of the Act (including TCSPs as item 2). 

Accountable institutions that are registered with the Centre on the date of commencement of this Directive must update their registration by providing the particulars mentioned in paragraph 5.1 within 90 days of the date of commencement of the Directive. Accountable institutions must update the particulars provided under paragraph 5.1 within 90 days after such a change. 

An accountable institution that fails to comply with a provision of this Directive is noncompliant and is subject to an administrative sanction in accordance with section 45C of the FIC Act. 

This directive will take effect on the date of publication in the Gazette. 

Deadline for comments is Friday, 13 February 2026.

Other related documents can be downloaded at:

• Consultation Note: https://www.fic.gov.za/wp-content/uploads/2025/12/Consultation-note-Draft-Directive-10.pdf 
• Website Notice: https://www.fic.gov.za/wp-content/uploads/2025/12/Web-notice-Draft-Directive-10-information-pertaining-to-geographic-locations.pdf 
• Latest list of Accountable Institutions (updated in 2022): https://www.gov.za/sites/default/files/gcis_document/202211/47596gon2800.pdf 

Click here to download the 5-page Draft Directive document:

https://www.fic.gov.za/wp-content/uploads/2025/12/Draft-Directive-10-Information-pertaining-to-geographic-locations.pdf 

Relevance to Auditors, Independent Reviewers & Accountants:

• FICA is yet another piece of legislation that your clients must comply with, and which you must assess compliance with.  If they don’t comply with the relevant laws and regulations, you have certain reporting obligations in terms of NOCLAR (NOn-Compliance with Laws And Regulations) – this could include reporting to management, qualifying your audit opinion, reporting a Reportable Irregularity, etc.
• Auditors, Independent Reviewers and Accountants should be aware of the latest publications and guidance issued by regulators, such as the FIC – to enable their assessment of accountable institutions’ compliance with FICA.
• When advising clients or performing this function on their behalf, practitioners should be aware of the finer details and specific guidance on failure to report to FIC.
• As an accountable, you also need to comply with FICA in your workplace.

Relevance to Your clients:

• An entity (company or close corporation) has a duty to comply with the FICA, and accountable institutions should fulfil their reporting obligations, otherwise non-compliance could lead to financial sanctions.
• Relevant Accountable Institutions (companies and CCs) should be aware of the latest publications and guidance issued by regulators, such as the FIC.

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