FIC: Draft Guidance Note 7B – Implementation of various aspects of FICA

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FIC: Draft Guidance Note 7B – Implementation of various aspects of FICA

• 06 July 2026
• Miscellaneous
• South African Accounting Academy

Summary:

The Financial Intelligence Centre (FIC) has issued draft Guidance Note 7B on implementation of various aspects of the Financial Intelligence Centre Act, No. 38 of 2001 (FICA) for consideration by accountable institutions, supervisory bodies and other persons (in terms of 42B of FICA).

Article:

Draft Guidance Note 7B provides technical updates to Chapter 1 of the Revised Guidance Note 7A. Changes have been made to draft GN7B to reference proliferation financing throughout the document, where money laundering and terrorist financing is referred to.

Draft GN 7B further provides an update on the implementation of systems and controls, to clarify the circumstances under which simplified due diligence may not be applied and clarity on risk assessment.

Contents:

• Chapter 1 - Adoption of a risk-based approach (with detailed information on General principles)
• Chapter 2 - Customer Due Diligence measures
• Chapter 3 - Record keeping
• Chapter 4 - Risk Management and Compliance Programme
• Chapter 5 - Implementation of the United Nations Security Council Resolutions relating to the Freezing of Assets

The deadline for comments on paragraphs 7A, 37A, 40A and 58A of draft GN 7B was 26 June 2026.

Guidance Note 7A was issued on 13 February 2025. This Revised Guidance Note 7A dated 1 September 2025 replaces both Guidance Note 7A and Guidance Note 7 from the date of its publication. Refer to our previous Alert dated 4 September 2025

Click here to download the 78-page  document:

https://www.fic.gov.za/wp-content/uploads/2026/06/2026.6-GN-260611-G7_FIC-Guidance-Note-07B.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 be up to date with all communication from FIC to ensure their compliance, 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, as well as submitting other relevant report as required by FICA.
• 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 be up to date with all communication from FIC to ensure their compliance, or face administrative sanctions.

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