FIC: Revised Guidance Note 7A on various aspects to comply with FICA

FIC: Revised Guidance Note 7A on various aspects to comply with FICA

• 04 September 2025
• Money Laundering
• South African Accounting Academy

Summary:

The Financial Intelligence Centre (FIC) has published the Revised Guidance Note 7A (Revised GN 7A) which offers accountable institutions guidance on compliance with the Financial Intelligence Centre Act 38 of 2001 (FICA).

Article:

Revised GN 7A entirely replaces Guidance Note 7A, which was published on 13 February 2025 as well as Guidance Note 7, which was published on 2 October 2017. The previous Guidance Note 7A replaced Chapter 4 of Guidance Note 7, specifically, about the Risk Management and Compliance Programme (RMCP). Refer to our previous Alert dated 18 February 2025

The FIC Act incorporates a risk-based approach to compliance elements such as customer due diligence (CDD) into the regulatory framework. A risk-based approach requires accountable institutions to understand their exposure to money laundering and terrorist financing risks. By understanding and managing their money laundering and terrorist financing risks, accountable institutions not only protect and maintain the integrity of their businesses but also contribute to the integrity of the South African financial system.

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

Revised GN 7A provides technical updates, including bringing it in line with the General Law (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act, 2022 (Act 22 of 2022) and the FIC’s public compliance communication 59 (PCC 59). PCC 59 sets out the latest guidance on beneficial ownership. 

Click here to download the 76-page Guidance Note:

https://www.fic.gov.za/wp-content/uploads/2025/09/Revised-Guidance-Note-7A-%E2%80%93-Implementation-of-various-aspects-of-the-FIC-Act.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.

0 COMMENTS

LEAVE A COMMENT