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FICA Directive 12 Assistance

Specialist support for Directive 12 compliance and RMCP submissions

The Financial Intelligence Centre’s (FIC) Directive 12 introduces a formal requirement for certain accountable institutions to submit their Risk Management and Compliance Programme (RMCP) to the FIC on an annual basis.

Directive 12 places increased emphasis on maintaining an up-to-date RMCP and ensuring that it is submitted within the prescribed timeframes.

Masthead’s compliance specialists can help you understand your obligations, assess whether your RMCP remains fit for purpose and support you in meeting the requirements of Directive 12.

What is FICA Directive 12?

Directive 12 was issued in terms of Section 43A(1) of the FIC Act (FICA) and specifies the manner and timeframe within which certain accountable institutions must submit a copy of their RMCP to the FIC. The purpose of the Directive is to enable the FIC to monitor levels of compliance with FICA.

Who must comply with FICA Directive 12?

Directive 12 applies to accountable institutions registered under the following Schedule 1 items of the FIC Act:

  • Legal practitioners
  • Trust and company service providers
  • Estate agents and property practitioners
  • Gambling institutions
  • Credit providers (excluding banks, mutual banks and co-operative bank credit providers)
  • The Post Bank
  • High-value goods dealers
  • The South African Mint
  • Crypto Asset Service Providers (CASPs)

FICA Directive 12 submission deadlines

Accountable institutions must submit their approved RMCP to the FIC via the goAML platform according to the deadlines prescribed by Directive 12. The current submission deadlines are as follows:

9 October

  • Legal practitioners (Item 1)
  • Trust and company service providers (Item 2)
  • Gambling institutions (Item 9)
  • Credit providers (Item 11, excluding banks, mutual banks and co-operative bank credit providers)

31 October

  • Estate agents and property practitioners (Item 3)
  • The Post Bank (Item 14)
  • High-value goods dealers (Item 20)
  • The South African Mint (Item 21)
  • Crypto Asset Service Providers (CASPs) (Item 22)

Additional submission requirements

  • New accountable institutions must submit their RMCP within 90 days of commencing business.
  • Updated and approved RMCPs must be submitted to the FIC within 10 days of approval.
  • Separate RMCP submissions are required where an institution is registered under multiple Schedule 1 categories.

Need help determining your submission obligations?

Understanding whether Directive 12 applies to your business, which submission deadline applies to your institution and whether multiple RMCP submissions are required can be challenging.

Masthead’s compliance specialists can help you understand your obligations, review your RMCP and prepare for submission.

What should be submitted?

Accountable institutions should submit the RMCP documentation that has been approved by the board of directors, senior management or the persons holding the highest authority within the institution.

It is important to note that successful submission of an RMCP does not mean the FIC has approved or endorsed the document. Accountable institutions remain responsible for ensuring that their RMCP complies with the requirements of FICA and accurately reflects their business activities and risk profile.

How Masthead can help

Whether you need a new RMCP drafted or an existing RMCP reviewed and updated, Masthead’s compliance specialists can assist. We help accountable institutions develop and maintain RMCPs that are tailored to their specific business activities, products, services and risk profile.

Our compliance specialists can assist with:

  • Drafting bespoke RMCPs for accountable institutions
  • Reviewing existing RMCPs to assess whether they reflect current business activities and risk exposure
  • Identifying areas that require updating or enhancement
  • Updating RMCPs to reflect changes in business activities or risk exposure
  • Preparing for RMCP submissions under Directive 12
  • Providing ongoing support when RMCPs require updating following approval

Why Choose Masthead?

  • FICA expertise: Our compliance specialists have extensive experience assisting accountable institutions with FICA compliance, RMCP development and ongoing regulatory obligations.
  • Bespoke RMCP solutions: We develop and review RMCPs that are tailored to your business activities, products, services and risk profile, rather than relying on generic templates.
  • Practical compliance support: We provide practical guidance on RMCP development, maintenance and submission obligations, helping you understand what is required and how it applies to your business.
  • Support for new and existing accountable institutions: Whether you’re drafting an RMCP for the first time or updating an existing programme, we can help ensure it remains appropriate for your business.
  • Ongoing Compliance Partnership: As your business evolves, we can assist with reviewing and updating your RMCP to ensure it continues to reflect your operations and risk exposure.

 

 

 

 

WHO ARE WE

Established in 2004, Masthead (Pty) Ltd offers nationwide compliance and business support to independent financial advisors, corporate FSPs, credit providers, legal and property practitioners, and others. We help our clients navigate key regulations like FAIS, FICA, POPIA, and the National Credit Act. With a team of experts, we provide practical solutions across compliance, practice management, and business development to help businesses stay compliant and thrive. Masthead (Pty) Ltd is part of the Masthead Group, alongside Masthead Financial Planning (Pty) Ltd – a licensed FSP dedicated to supporting financial advisors with streamlined operational and regulatory solutions.

Why Masthead?

CONTACT US

Phone:

021 686 3588

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