The Financial Intelligence Centre (FIC) has issued a Notice reminding all accountable institutions about their responsibility to register correctly under the Financial Intelligence Centre Act (FIC Act). This reminder is especially important because incorrect registrations can result in penalties, including administrative sanctions.
Why registration matters?
Under Section 43B of the FIC Act, every accountable institution must register with the FIC. This registration is not optional – it is a legal requirement.
- New businesses that fall under the list of accountable institutions in Schedule 1 of the FIC Act must register with the FIC within 90 days of opening.
- If an institution fails to register, or fails to provide the required information, it will be seen as non-compliant and may face sanctions.
The FIC uses this registration process to keep an updated record of accountable institutions. These records support efforts to fight against money laundering, terrorist financing, and other financial crimes.
Who needs to register?
Schedule 1 of the FIC Act lists all accountable institutions that must register. However registration is not limited only to accountable institutions.
If you are not an accountable institution but still need to submit suspicious or unusual transaction reports, you may register as a “Business Entity with a Reporting Obligation”. This categorisation should only be used if you do not fall under Schedule 1. An example of an entity that falls under this categorisation are FSPs that are only authorised for short-term insurance and/or health service benefits. While these FSPs are excluded from the definition of accountable institutions, they still have a reporting obligation amongst other requirements in terms of the FIC Act and therefore must register as a “Business Entity with a Reporting Obligation”.
The list of accountable institutions include, but is not limited to:
- Legal practitioners, attorneys, and advocates
- Trust and company service providers
- Estate agents
- Banks, mutual banks, and co-operative banks
- Life insurers
- Gambling businesses
- Foreign exchange dealers
- Credit providers
- Financial services providers
- Money or value transfer providers
- High-value goods dealers
- Crypto asset service providers
The full list of accountable institutions is available in Schedule 1 of the FIC Act and has also been included in the FIC Notice.
Registering under the correct item numbers
One of the main concerns raised by the FIC is that some accountable institutions are registered incorrectly. Specifically, some have registered as “Business Entities with a Reporting Obligation”, when in fact they qualify as accountable institutions under Schedule 1 of the FIC Act.
Accountable institutions are urged to check that they are registered correctly:
- If your business activities fall under more than one item in Schedule 1, you must register separately for each one. This is known as dual registration.
- If your institution is registered under the wrong item, you must correct it through the FIC’s goAML platform.
How to correct an incorrect registration
If you realise that your institution has registered under the wrong category, you must update your details on the goAML platform. The FIC has provided a step-by-step process:
- Log in to goAML and select “MY GOAML”, then click on “My Org Details”.
- Change your organisation type to the correct accountable institution item.
- Submit the request.
- Click “Continue.”
- Keep the SHREG number you receive as confirmation of the amendment.
The FIC has announced that from 31 May 2025, it has started verifying all entities currently registered as “Business Entities with a Reporting Obligation”. If your registration is incorrect, you risk sanctions.
Masthead can assist you with FICA compliance, preparation for FIC inspections and FICA training
We offer a wide range of services to all Institutions that require FICA compliance, including assistance with registration, FICA training for your employees, hands-on assistance with the implementation of FICA requirements in your business and support services when preparing for a FIC Inspection.
Contact the regional office closest to you or get in touch with us for more information on how Masthead can assist you to be compliant in terms of the FICA requirements.