FIC: Draft Directive 12 on the submission of RMCPs

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FIC: Draft Directive 12 on the submission of RMCPs

• 07 August 2026
• Miscellaneous
• South African Accounting Academy

Summary:
The Financial Intelligence Centre (FIC) has issued Draft Directive 12 on the annual submission of the Risk management and compliance programmes (RMCP), for consideration by accountable institutions, supervisory bodies and other persons.

Article:

Draft Directive 12 seeks to mandate accountable institutions listed in item 1, 2, 3, 9, 11 (excluding bank, mutual bank, and co-operative bank credit providers), 14, 20, 21 and 22 of Schedule 1 to the Financial Intelligence Centre Act (FICA) to submit their risk management and compliance programmes to the FIC on an annual basis.

The draft Directive 12 also provides for the manner and timeframes within which specified accountable institutions are required to submit a copy of the documentation describing their risk management and compliance programmes to the FIC in terms of the FIC Act.

Specified accountable institutions should make available a copy of the documentation describing its RMCP available to the centre according to the due dates set out in Annexure A:

 

Section 43 of FICA empowers the FIC to issue legally binding directives to accountable and reporting institutions concerning compliance with anti-money laundering, terrorist financing, and proliferation financing laws.

This directive is issued in terms of section 43A of FICA, which means that the Directive has the full force of law. Non-compliance is treated as a statutory violation. FIC Act to submit their risk management and compliance programmes to the FIC on an annual basis.

This directive is issued in terms of section 43A of FICA, which means that the Directive has the full force of law. 

Non-compliance is treated as a statutory violation.

The deadline for comments is 21 August 2026. 

Commentators are invited to comment on draft Directive 12 by making written comments via the online consultation form only.

For queries, please contact the FIC’s compliance contact centre on 012 641 600, select option 1, or submit a web query by clicking on: https://www.fic.gov.za/compliance-queries-2/. 

Click here to download the 2-page Draft Directive document:

https://www.fic.gov.za/wp-content/uploads/2026/07/Draft-Directive-12-On-the-submission-of-risk-management-and-compliance-programmes.pdf

Relevance to Auditors, Independent Reviewers & Accountants:

• The Financial Intelligence Centre Act (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.
• As an auditor and independent reviewer, you need to consider amendments, regulations, guidance and directives that are gazetted relating to FIC and accountable institutions, to ensure that your clients (or even your own practice) comply with their reporting obligations.
• As an Accountable Institution, you need to submit your RMCP, or face administrative sanctions.

Relevance to Your clients:

• Relevant entities (specifically accountable institutions) have a duty to comply with the FIC Act, otherwise they could be held liable. This includes online submission of their RMCP to FIC.
• Relevant entities should be aware of amendments, regulations, guidance and directives that are gazetted relating to FIC and accountable institutions, to ensure that they comply with their reporting obligations.

• All accountable institutions need to submit their RCR, or face administrative sanctions.

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