FIC Gazettes Directive on RMCP Submissions for Accountable Institutions

Posted 04 September 2026 Written by Acts Online
Category Safety and Security

Brought to you by SA Legal Academy: Under the Financial Intelligence Centre Act, No. 38 of 2001 (FIC Act), the Financial Intelligence Centre (FIC) has issued a final directive prescribing the manner and timeframe within which specified accountable institutions must submit copies of documentation setting out their Risk Management and Compliance Programme (RMCP).

The directive establishes specific annual October cut-off dates by which accountable institutions added or amended under Schedule 1 of the FIC Act must lodge their RMCP documentation with the Centre. The expanded Schedule 1 categories, which took effect in December 2022, include:

  • Legal practitioners;
  • Commercial juristic entities; and
  • Other designated designated financial and non-financial business categories.

The final directive follows the release of a draft version for public comment in July, alongside which the FIC has now published an industry consultation feedback note detailing stakeholder submissions and regulatory responses.

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

  • For yourself: Legal practitioners and designated compliance officers must ensure their personal professional certifications and AML/CFT oversight documentation align directly with the firm’s formalised RMCP.
  • For your business: Accountable institutions listed under amended Schedule 1 must audit, update, and submit their written RMCP documents to the FIC portal ahead of their specified annual October filing deadline to avoid administrative sanctions under section 45C of the FIC Act.
  • For your clients: Commercial juristic entities and institutional clients categorized as accountable institutions must verify their registration status with the FIC and establish internal governance protocols to facilitate timely annual RMCP disclosures.

Originally published at https://legalacademy.co.za/news/read/financial-sector-risk-management-compliance-programme-directive-gazetted

The views expressed herein are those of the author and do not necessarily reflect those of Acts Online. Acts Online accepts no responsibility for the accuracy, completeness or fairness of the article, nor does the information contained herein constitute advice, legal or otherwise.