Written by: Liana Burger | Afrikaanse weergawe
If you are an estate agent, credit provider, dealer in high-value goods, or another accountable institution under the Financial Intelligence Centre Act (FICA), there are important changes from the Financial Intelligence Centre (FIC) that may affect how you meet your compliance obligations. Here is what you need to know and how we can help.
What Is an RMCP?
Your Risk Management and Compliance Programme (RMCP) is the document that sets out how your business identifies its clients, manages the risk of money laundering, and reports suspicious transactions. Every accountable institution must have one. It must fit your business, be approved by your directors or senior management, and must be used in practice. A template bought off the shelf is not enough.
What Has Changed?
- Guidance Note 7B, published on 3 August 2026, updates what the FIC expects to see in your RMCP. If your RMCP was drafted before August 2026, it most likely needs to be updated.
- Directive 10 requires you to give the FIC the details of your head office and every branch on goAML (FIC’s registration and reporting portal) by 29 October 2026.
- Directive 12 requires you to submit a copy of your RMCP to the FIC every year. Estate agents and dealers in high-value goods must submit by 31 October 2026. Legal practitioners, trust service providers, and credit providers had to submit by 9 October 2026. If you missed that date, submit as soon as possible.
Why It Matters
The FIC will now see every RMCP every year, so an outdated programme is easy to spot. Fines can reach R10,000,000 (ten million rand) for an individual and R50,000,000 (fifty million rand) for a business.
How We Can Help
We take care of the process from start to finish:
- Reviewing your existing RMCP or drafting a new one.
- Preparing the resolution approving your RMCP.
- Updating your goAML registration.
- Submitting your RMCP to the FIC.
- Training your staff.
Not sure whether your RMCP is up to date? Send it to us, and we will tell you exactly where you stand. We also assist with POPIA compliance and governance for companies, trusts, and body corporates.
Contact Van der Walt & Associates Inc. to arrange a consultation.
While every reasonable effort is taken to ensure the accuracy and soundness of the contents of this publication, neither writers of articles nor the publisher will bear any responsibility for the consequences of any actions based on information or recommendations contained herein. Our material is for informational purposes.