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New FICA obligation: Specified accountable institutions to submit risk and compliance returns

The Financial Intelligence Centre (FIC) has published two directives – Directive 6 of 2023 and Directive 7 of 2023 – which require specified accountable institutions to submit risk and compliance returns to the FIC on an annual basis. The return must contain information regarding the accountable institution’s understanding of money laundering (ML), terrorist financing (TF) and proliferation financing (PF) risks, as well as its assessment of compliance with obligations in terms of the FIC Act.

Directive 6 applies to:

  • Legal practitioners
  • Trust and company service providers
  • Estate agents
  • The gambling sector

The reporting period for this risk and compliance return is from 1 April 2022 to 31 March 2023, both dates inclusive.

The deadline for submission to the FIC is 17:00 on 31 May 2023.

If an accountant is deemed to be an accountable institution, they must comply with Directive 6.

Directive 7 applies to:

  • Credit providers
  • The South African Postbank Limited
  • High-value goods dealers
  • The South African Mint Company
  • Crypto asset service providers

The reporting period for this risk and compliance return is from 1 January 2023 to 30 June 2023, both dates inclusive.

The deadline for submission to the FIC is 17:00 on 31 July 2023.

The risk and compliance return for specified accountable institutions:

  • is compulsory, and non-submission of the return will be considered as non-compliance and may result in an administrative sanction;
  • requires all questions to be answered;
  • is an online return, and answers must be populated and submitted online; and
  • requires that all questions be answered based on the accountable institution’s understanding of ML, TF and PF risks and the risk-based controls that are currently in place.


Do you need help to complete your risk and compliance return?

Masthead has been helping businesses implement and comply with FICA requirements since 2004. We can provide you with hands-on assistance, work through the return with you, give insight into the questions, and guide you in completing your return.

Contact us here for more information and assistance, or get in touch with your nearest Masthead Regional Office.

Our FICA services

Masthead offers a wide range of FICA compliance services to all types of accountable institutions. These include FICA training for your employees, assistance with implementing FICA requirements in your business, and support services when preparing for a FIC inspection.

Online FICA training programmes

Accountable institutions are required to provide regular, ongoing FICA and Risk Management and Compliance Programme (RMCP) training to current and new employees according to the FIC Act. In addition, these entities must be able to prove that training has taken place and ascertain their employees’ level of understand of the Act.

Masthead’s online FICA training programmes can help you meet these requirements as they will give your employees a comprehensive, up-to-date understanding of the FIC Act.

Requirements and Impact of FICA on Accountable Institutions Webinar

This webinar will give you and your employees greater insight into the FIC Act as amended, relevant anti-money laundering legislation, the Financial Action Task Force and its purpose, and more.

Click here to read more and register for the webinar.

FICA online courses

Our FICA online courses are tailor-made to meet the training needs of different accountable institutions. These online training programmes give employees the flexibility to learn about FIC Act requirements at their own pace.

After working through each module, employees will complete an interactive quiz to assess their level of understanding as they progress through the course.

Read more and register for our FICA online courses here.

RMCP implementation services

Do you require assistance and training that is hands-on and specific to your business? We understand that businesses have unique needs because they differ in size, structure and service offerings. Masthead can help different types of accountable institutions customise and implement their FICA RMCPs. Our team of experienced professionals will guide and assist you in ensuring that your RMCP works for your business.

Contact us here or call your nearest Masthead Regional Office for more information or to arrange onsite training.

What a client had to say about our implementation service:

“We did not know where to start with developing and implementing our customised RMCP. I am thrilled that Masthead stepped in and managed the whole process. The implementation was done meticulously, and I am now confident that my RMCP complies and my staff are properly trained. Getting Masthead to help us was the best decision.” Nico Zandberg I Engelsman Magabane Inc.

Masthead also has a webinar that will guide you through all the elements that need to be included in your FICA RMCP and help you to develop and implement a programme that is customised to your business and its risks.

Read more and register for the webinar here.

Support when preparing for a FIC Inspection

Masthead can help you prepare for FIC inspections and provide onsite support during these inspections.

The typical areas that will be covered and that accountable institutions will need to demonstrate adherence to include: your FIC registration, your governance of anti-money laundering and terrorist financing, your training relating to anti-money laundering and terrorist financing, the thoroughness and effectiveness of your FICA RMCP, your customer due diligence process, your record-keeping process, your cash threshold process and reporting processes, your process to deal with terrorist property and financial sanctions, suspicious transaction reports, and more.

For more information on how we can assist you with preparation, contact us here.

Would you like to gauge your readiness for a FIC inspection? Attend our FIC inspection webinar and identify any gaps ahead of time. We will take you through the process and prepare you for the typical questions you will face before, during and after a FIC inspection.

Read more and register for the webinar here.



A national supplier of risk management services to independent financial advisors and other licensed financial service providers (FSPs). Established in 2004, we help our clients overcome their risk management challenges so they can grow and thrive in an increasingly regulated industry. Providing professional guidance and practical support, our team of specialists is passionately committed to delivering tangible solutions.

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