FIC Issues Draft Directive 12 on Annual Submission of RMCPs

Posted 07 August 2026 Written by Acts Online
Category FICA & Anti-Money Laundering

Brought to you by SA Accounting Academy: In terms of section 43A of the Financial Intelligence Centre Act, No. 38 of 2001 (FICA), the Financial Intelligence Centre (FIC) has issued Draft Directive 12, proposing mandatory annual submissions of Risk Management and Compliance Programmes (RMCPs) by specified accountable institutions.

Section 43 of FICA empowers the FIC to issue binding directives to accountable and reporting institutions concerning compliance with anti-money laundering, counter-terrorist financing, and counter-proliferation financing obligations. Issued under section 43A, Directive 12 will carry the full force of law, and non-compliance will be treated as a statutory violation subject to administrative penalties.

The draft directive applies to accountable institutions designated under the following items of Schedule 1 to FICA:

  • Item 1, 2, and 3: Legal practitioners, trust service providers, and estate agents;
  • Item 9: Public accountants and auditors;
  • Item 11: Credit providers (excluding registered banks, mutual banks, and co-operative banks);
  • Item 14: High-value goods dealers;
  • Items 20, 21, and 22: Crypto asset service providers and other designated business entities.

Under the proposed directive, specified accountable institutions must make documentation describing their RMCP available to the FIC annually in accordance with the timeframes and procedures set out in Annexure A of the directive.

Stakeholders and commentators are invited to submit written comments on Draft Directive 12 via the FIC’s online consultation form by 21 August 2026.

Click here to download the FIC Draft Directive 12 Document.

What this means for you, your business, or your clients

  • For yourself: Compliance officers, accountants, and legal professionals must review the draft directive to determine submission timelines and evaluate whether current RMCP documentation meets regulator standards ahead of the 21 August 2026 comment deadline.
  • For your business: Accountable institutions falling within Schedule 1 items 1, 2, 3, 9, 11, 14, 20, 21, or 22 must establish formal internal procedures to ensure their written RMCP is updated and prepared for annual regulatory filing.
  • For your clients: Advise client entities operating as accountable institutions of their upcoming statutory duty to annually file their fully documented RMCP directly with the FIC.

Originally published at https://accountingacademy.co.za/news/read/fic-draft-directive-12-on-the-submission-of-rmcps

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