FIC: Urgent request for accountable institutions to submit their RMCP

FIC: Urgent request for accountable institutions to submit their RMCP

• 13 March 2025
• Regulatory Compliance and Legislation
• South African Accounting Academy

Summary:

The Financial Intelligence Centre (FIC) has requested Accountable Institutions to submit their Risk Management and Compliance Programme (RMCP) online by 12 March 2025. This tight deadline was communicated to compliance officers via the goAML message board, and a request was issued on 4 March 2025.

Article:

Accountable institutions must submit the RMCP electronically using the FIC goAML web platform at https://goweb.fic.gov.za/goAMLWeb_PRD/Home.

Accountable institutions are urged to peruse their goAML message board on a daily basis, and to respond to the FIC’s request in the manner outlined in the general request.

All accountable institutions supervised by the Financial Intelligence Centre (FIC) are advised that a general request will be issued for them to submit a copy of their risk management and compliance programme (RMCP) to the FIC, in terms of section 42(4)(a) of the Financial Intelligence Centre Act, 2001 (Act 38 of 2001), by close of business on Wednesday, 12 March 2025.

The accountable institutions supervised by the FIC, and affected by this RMCP general request are:

• Legal practitioners (item 1),
• trust and company service providers, including accountants (item 2),
• estate agents (item 3,)
• licensed gambling institutions, including casinos (item 9),
• credit providers (item 11),
• the South African Postbank Limited (item 14),
• high-value goods dealers (item 20),
• SA Mint Company (RF) (Pty) Ltd (item 21) and
• crypto asset service providers (item 22).

Steps to submit the RMCP, are set out in the General Notice.

Failure to comply with this request in terms of section 42(4)(a) of the FIC Act, within the requested time period, will constitute non-compliance and may lead to administrative sanctions being imposed, including a financial penalty in terms of section 45C of the FIC Act.

In an urgent update regarding adherence to call for submission of RMCPs, the FIC also advised that the current RMCP submission response rate is poor and is in urgent need of immediate action. The RMCP submission rates as at Monday, 10 March 2025, were provided in a table in the Website Notice at https://www.fic.gov.za/wp-content/uploads/2025/03/2025.3-WN-Update-on-Compliance_Submission-of-RMCP-.pdf. From this it was clear that not all accountable institutions that should be registered with FIC, are duly registered – and thus the compliance rate of submitted RMCPs by accountable institutions is dismal.

Click here to download the request notification:

https://www.fic.gov.za/wp-content/uploads/2025/03/2025.3-GN-RMCP-Letter-Request_250304.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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