1. Legal practitioners
2. Business and trust service providers who assist clients to set up a business or manage trusts
3. Estate agents
4. Participants in South Africa’s financial markets
5. Casinos and businesses that engage in licensed gambling activities
6. Foreign exchange and credit providers dealing in currency transactions and lending
7. Financial services providers, including advisors and intermediaries
8. Businesses dealing in high-value goods and luxury items, particularly those making transactions of R100,000 or more
9. Crypto exchange providers
10. Participants in clearing systems and electronic systems, whether it’s processing credit card transactions, electronic transfers, or any kind of online payment

To download the comprehensive list click here.

The FIC conducts targeted audits, investigates suspicious transaction reports, responds to whistleblower reports, and performs sector-wide compliance reviews. They also monitor public records and can investigate based on client complaints or regulatory referrals.

Yes, if you handle client funds in trust accounts, facilitate property transactions, or deal with high-value matters, you're legally classified as an Accountable Institution under the FIC Act. Many successful firms discover this obligation only when facing penalties or audits.

The FIC has significantly increased enforcement activities. Recent penalties include R7.7 million against Kunene Ramapala Inc. (a law firm) and R3 million against Ninety One Fund Managers. The regulatory environment has shifted from warnings to substantial financial penalties.

Non-compliance with the Financial Intelligence Centre Act (FIC Act) can lead to significant administrative sanctions, including:

• Financial Penalties: Fines up to R10 million for individuals and R50 million for legal entities.

• Cautions and Reprimands: Formal warnings not to repeat the conduct that led to non-compliance.

• Directives for Remedial Action: Orders to take specific steps to address compliance deficiencies.

• Restriction or Suspension of Business Activities: Limiting or halting certain operations until compliance is achieved.

The FIC and other supervisory bodies assess the nature, seriousness, and extent of non-compliance when determining appropriate sanctions. They also consider any mitigating factors and may refer matters for criminal investigation if warranted.

To avoid these consequences, it's crucial for accountable institutions to implement and maintain effective compliance measures, conduct regular self-assessments, and address any identified gaps promptly.

Yes. Directors, partners, and senior executives can face personal liability for compliance failures. The FIC can pursue individuals who were responsible for ensuring compliance but failed to implement adequate measures.

Key requirements include: registering with the FIC, developing a Risk Management and Compliance Programme (RMCP), conducting customer due diligence, verifying beneficial ownership, screening clients against sanctions lists, filing regulatory reports, and providing staff training.

Templates or DIY checklists may seem convenient, but the FIC Act requires compliance measures to be risk-based and specific to your business. A “one-size-fits-all” approach often leaves gaps that regulators can penalize. Your RMCP and processes must reflect your actual services, clients, and risks.

Your RMCP should be reviewed atleast annually and updated whenever there are significant changes to your business, regulatory requirements, or risk environment. The FIC expects your programme to evolve with your business and the regulatory landscape.

While possible, compliance requires specialized knowledge of FIC requirements, risk assessment methodologies, and regulatory reporting. Most firms find that expert guidance ensures proper implementation while freeing up staff to focus on revenue-generating activities.

Partial compliance can be worse than no compliance, as it suggests awareness of obligations but failure to meet them. The FIC expects complete, properly implemented programmes. Half-measures won't protect you during an audit.

Properly implemented compliance actually strengthens client relationships by demonstrating professionalism and protecting both parties from financial crime risks. Banks and corporate clients increasingly prefer working with compliant institutions.

Frame it as protecting both your firm and your clients from financial crime risks. Most affluent clients appreciate working with institutions that take regulatory compliance seriously, as it reflects operational sophistication and reduces their own reputational risks.

A proper compliance assessment can be completed within days. The 2-minute self-audit provides immediate insights into potential gaps, while a comprehensive assessment typically takes 1-2 weeks depending on your firm's complexity.

Gaps are common and fixable. The key is addressing them promptly and systematically. With proper guidance, most firms can achieve full compliance within 4-8 weeks, depending on the extent of gaps and complexity of operations.