FIC_Sector Risk Assessment for Crypto Asset Service Providers (CASPs)

FIC_Sector Risk Assessment for Crypto Asset Service Providers (CASPs) logo

Summary:

The Financial Intelligence Centre (FIC) has issued a sector risk assessment (SRA) report for crypto asset service providers (CASPs).

Article:

This sector risk assessment report addresses the money laundering (ML) and terrorist financing (TF) risk factors facing CASPs pertaining to products, services, clients, transactions, delivery channels and geographical areas.

It is envisaged that this sector risk assessment, although based on desktop monitoring assessment and research, would provide valuable insights by promoting greater awareness and understanding of the ML and TF risks to CASPs, as well as by articulating methods to reduce and mitigate these risks. CASPs should use this report to develop and apply such methods in their day-to-day AML/CFT risk management.

The CASPs sector has been included in item 22 of Schedule 1 of the Financial Intelligence Centre Act, 2001 (Act 38 of 2001) since amendments to the Schedules were implemented in December 2022. In addition, CASPs must also register under item 22 of Schedule 1 of the FIC Act where it relates to the activities mentioned in this item, for which the FIC is the designated supervisory body. The FIC and FSCA jointly supervise and enforce compliance with the FIC Act obligations (AML, CFT and CFP) for CASPs in terms of the FIC Act.

The purpose of the sector risk assessment is to assist CASPs in understanding their money laundering and terrorism financing risks and introduce measures that can be adopted by the sector to mitigate and manage such risks.

Click here to download the 36-page Sector Risk Assessment:

https://www.fic.gov.za/wp-content/uploads/2025/04/2025.3-PUB-Sector-risk-assessment-%E2%80%93-Crypto-asset-service-providers-1.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 and guidance that are published by the FIC.
  • As an accountant, you should be aware of the inherent money laundering and terrorist financing risks for CASPs, and how to assess these risks.

Relevance to Your Clients:

  • Relevant entities (specifically accountable institutions) have a duty to comply with the FIC Act, otherwise they could be held liable.
  • Relevant entities should be aware of amendments, regulations and guidance that are published by the FIC.

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