Credit providers · Directive 12 deadline · 9 October 2026
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Directive 12 Deadline · 9 October · For Credit Providers

Capitec’s R5 Million RMCP Penalty. What Would an Inspection Find in Your RMCP?

Capitec’s R28 million FICA penalty included R5 million for RMCP deficiencies. With the Directive 12 RMCP submission deadline approaching on 9 October 2026, non-bank credit providers must submit an approved programme that reflects their lending risks and the controls they actually apply.

Watch the briefing below to understand the key areas your RMCP must address to withstand scrutiny.

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SDS Attorneys
Serfontein & Richards Inc.
BOA Inc.
Renqe Attorneys
Keetse Attorneys
ESN Attorneys
EMG Attorneys Inc.
SF Inc.
Leretha Legal
Solid Block Properties
AL Ramaboea Attorneys
Barnard and Mans
KHR Inc.
L Jikela Attorneys
Light Vision Properties
Mbona Attorneys
Mphahlela Inc.
MS Seconna Attorneys Inc.
Ndlovu Mkhari Attorneys
No Mamabolo Attorneys
R Filander Attorneys
Sharbel-Fahry Inc. Attorneys
T Madyibi
Tshikosi Attorneys
X Nkuna
LRA Inc.
And many more
Why FICA Friendly

Built from real compliance work.

Our RMCP and inspection support experience informs a practical approach to FICA compliance. For credit providers, the programme must be tailored to lending products, borrower relationships and the institution’s actual controls.

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Successful RMCP Review Support

Assisted a law firm through an FIC RMCP review with a successful outcome.

RMCP

Creator of RMCP Developer™

Our RMCP development workflow helps translate FIC Act requirements into documented, practical controls.

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Provinces · RMCP Development

Firm-specific RMCPs developed for clients across all nine provinces.

CISA

Professional Membership

Compliance consultancy led by a Compliance Institute Southern Africa member.

LSSA

FICA Compliance Panelist

National LSSA Conference · Cape Town · April 2026.

SAWLA

FICA Compliance Speaker

Gauteng SAWLA AGM · April 2026.

What is Directive 12?

Submit your approved RMCP by 9 October 2026.

The FIC issued final Directive 12 on 4 September 2026. Item 11 credit providers, excluding bank, mutual bank and co-operative bank credit providers, must submit documentation describing their section 42 RMCP to the FIC by 9 October 2026, and annually thereafter.

Submission does not equal compliance. The FIC can access submitted RMCPs for monitoring, inspections and enforcement.
Who is covered

Item 11 credit providers

The Directive excludes bank, mutual bank and co-operative bank credit providers. Final PCC 23A explains the wider item 11 definition.

The 2026 deadline

9 October 2026

Submit the approved RMCP through the FIC’s goAML platform. Submission is required annually thereafter.

The content standard

Section 42 · GN 7B · PCCs

Address your credit products, client onboarding, risk assessment, monitoring, screening, reporting and records as they operate in practice.

FIC Act enforcement · 11 September 2026

R5 million for deficiencies in Capitec’s RMCP.

The Prudential Authority imposed a R28 million FICA penalty on Capitec. R5 million concerned section 42 RMCP deficiencies; R500,000 of that amount was conditionally suspended.

Capitec branch entrance

How the R28 million penalty breaks down

FindingPenalty
RMCP deficienciesR5 million
Customer due diligenceR10 million
Enhanced due diligenceR5 million
Ongoing due diligenceR5 million
Employee trainingR3 million
Total FICA financial penaltyR28 million

What did the RMCP finding involve?

The Prudential Authority found that Capitec had not obtained management approval for certain screening manuals before using them. It also found gaps in documented and approved terrorist-property reporting processes, and in the RMCP’s policies and controls for terrorist-property reporting and financial sanctions.

What credit providers can take from this
  • Approval before use: Check that the relevant screening manuals and reporting processes have appropriate approval.
  • Complete RMCP controls: Document end-to-end financial-sanctions and terrorist-property reporting processes alongside your lending-specific risks.
  • Proof in practice: Be able to demonstrate due diligence, ongoing monitoring and staff training as they actually operate in your business.

Capitec is a bank and is excluded from the item 11 Directive 12 submission group. This sanction illustrates scrutiny of an RMCP under section 42.

Professional RMCP support

Get professional RMCP development services.

Our consultants develop and review credit provider RMCPs against section 42 and the way each lending business operates.

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01
Your lending model

Reflect your products, borrower relationships, repayment channels and geographic reach.

02
Your risk assessment

Document the money laundering, terrorist financing and proliferation financing risks your business faces.

03
Your section 42 controls

Describe the customer due diligence, screening, monitoring, reporting and record keeping you actually perform.

04
Your submission readiness

Identify gaps in the approved RMCP before it is submitted to the FIC.

Insights

From the compliance front line.

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Inspection InsightsOriginal guide

Five Lessons from a FIC Inspection

Download the original FICA Friendly PDF, based on an inspection involving a law firm. The case study is about legal practice; the broader compliance lessons may be useful to other accountable institutions.

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Professional RMCP support

Speak to a FICA consultant before you submit.

Discuss an RMCP that reflects your lending products, borrower relationships and the controls your business uses in practice.

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