FIC Directive 12: Mandatory Annual Submission of RMCPs

Posted 17 September 2026 Written by Acts Online
Category Financial Intelligence Centre Act

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 Directive 12, requiring designated accountable institutions to submit copies of their Risk Management and Compliance Programmes (RMCPs) on an annual basis.

Directive 12 determines the manner and timeframes within which affected accountable institutions must submit documentation describing their RMCPs to the FIC. Submissions must align with the specific due dates set out in Annexure A of the Directive. This oversight mechanism operationalises section 4(c) of FICA, enabling the FIC to monitor levels of supervisory and statutory compliance across identified sectors.

The obligation applies to accountable institutions categorized under the following items in Schedule 1 to FICA:

  • Item 1 (Legal practitioners)
  • Item 2 (Trust and company service providers)
  • Item 3 (Estate agents)
  • Item 9 (Financial services providers authorized in terms of the Financial Advisory and Intermediary Services Act)
  • Item 11 (Credit providers, excluding banks, mutual banks, and co-operative bank credit providers)
  • Item 14 (High-value goods dealers)
  • Item 20 (Trust service providers)
  • Item 21 (Payment clearing house system operators)
  • Item 22 (Crypto asset service providers)

Directive 12 carries the full force of law pursuant to section 43A of FICA. Failure to submit an RMCP in accordance with the prescribed timeframes constitutes non-compliance under the Act, exposing defaulting institutions to administrative sanctions and enforcement penalties under section 45C of FICA.

Click here to download FIC Directive 12 on the Submission of Risk Management and Compliance Programmes.

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

  • For yourself: Compliance officers and designated anti-money laundering practitioners must perform an immediate gap analysis on the firm’s documented RMCP to ensure statutory alignment prior to the Annexure A filing deadlines.
  • For your business: Accountable institutions falling within the designated Schedule 1 items must operationalise annual reporting workflows and upload their approved RMCP documents to the FIC’s portal within the specified annual windows.
  • For your clients: Advise clients operating in affected accountable institution sectors (such as legal practices, estate agencies, credit providers, and crypto asset service providers) of their mandatory annual filing duties to prevent administrative sanction proceedings.

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

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