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FIC: Urgent notice re RMCP submissions
- 20 March 2025
- Regulatory Compliance and Legislation
- South African Accounting Academy
Summary:
The Financial Intelligence Centre (FIC) has confirmed that the RMCP (Risk Management and Compliance Programme) submission window will remain open after the deadline of 12 March 2025.
Article:
The Financial Intelligence Centre (FIC) is aware that a large number of accountable institutions did not submit their Risk Management and Compliance Programmes (RMCPs) by the previously communicated deadline of 12 March 2024 by close of business.
Due to the large influx of institutions still submitting their RMCPs after the deadline, accountable institutions should note that the RMCP submission window will remain open after the deadline of 12 March 2025.
However, institutions that file their RMCPs after the closing date and time, are non-compliant and such non-compliance may attract a financial sanction.
The FIC reminds all accountable institutions that they must use the correct schedule item number designation for each activity when filing their RMCP.
- For example, legal practitioners must use item 1 when filing the RMCP of their legal practice. Failure to file the RMCP under the correct item number may result in the RMCP being rejected.
Click here to download the Urgent notice:
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.