The Financial Intelligence Centre (FIC) has reinforced the importance of Risk and Compliance Return (RCR) submissions following the expiry of the 2026 reporting deadlines, warning that institutions that failed to submit their returns may face enforcement action, including administrative financial penalties.
The 2026 RCR process was implemented through Directive 11, issued on 31 March 2026. The directive required specified accountable institutions to submit their annual RCRs by either 30 June 2026 or 31 July 2026, depending on the sector in which they operate. The returns form part of the FIC’s risk-based supervision framework and are used to gather information about institutions’ money laundering, terrorist financing and proliferation financing risks, as well as the controls they have implemented to manage those risks.
The first reporting group, which included crypto asset service providers (CASPs), company service providers, non-bank credit providers, trust service providers and casinos, recorded particularly low compliance levels at the initial deadline. By 30 June 2026, only 36.12% of the 5 636 registered institutions in these sectors had submitted their returns. Although late submissions increased this figure to 48.14% by 15 July 2026, more than half of the affected institutions had still not complied by that date.
The second reporting group consisted of legal practitioners, estate agents, non-casino gambling institutions, dealers in precious metals, Krugerrand dealers and dealers in precious stones. As the 31 July deadline approached, submission levels remained low. The FIC reported that only 11.82% of the 40 827 institutions in this group had submitted their returns by 15 July 2026. Legal practitioners, despite representing the largest sector in the group, showed a submission rate of less than 10%, while estate agents and non-casino gambling institutions also recorded relatively low participation levels.
The FIC has emphasised that the purpose of the RCR extends beyond a simple regulatory filing requirement. The information collected assists in assessing institutions’ understanding of their financial crime risks and their preparedness to mitigate those risks through appropriate risk-based controls. The data also enables the FIC to identify sector-wide trends and vulnerabilities, helping to inform its supervisory and enforcement strategies.
Christopher Malan, Executive Manager: Compliance and Prevention at the FIC, highlighted that the completion and submission of RCRs provide important insight into institutions’ risk awareness and their ability to identify and combat money laundering and terrorist financing threats within their businesses. Institutions that do not adequately understand their exposure to these risks may struggle to implement effective control measures.
The FIC made it clear that institutions which failed to submit their RCRs by the prescribed deadlines are regarded as non-compliant. The Centre stated that it may take enforcement action against these institutions including issuing of financial penalties
Institutions that missed the 2026 RCR deadlines should assess their current compliance position and take corrective action where necessary.
The online platform for submission remains open. Institutions are urged to comply to minimise the risk of financial penalties.