In terms of Directive 12 of 2026, which came into effect on 31 July 2026, the following Accountable Institutions referred to in Schedule 1 of the FIC Act:
- Item 1 – A legal practitioner
- Item 2 – A board of executors / trust company
- Item 3 – An estate agent
- Item 9 – Gambling Sector
- Item 11 – A credit provider
are required to submit their Risk Management & Compliance Programme (“RMCP”) on the FIC’s GoAML system by 30 September 2026.
The following Accountable Institutions:
- Item 14 – The Post Bank
- Item 20 – High-Value Goods Dealers
- Item 21 – The South African Mint Company
- Item 22 – Crypto Asset Service Providers
are required to submit their Risk Management & Compliance Programme (“RMCP”) on the FIC’s GoAML system by 31 October 2026.
Affected AIs must ensure that their RMCPs incorporate all the latest Guidance published by the FIC before uploading the approved document.
This will be an annual requirement in future.
As always,
The CTB Team