Fickle - The South African FIC corpus, mapped.

Linked legislation

Cross-references
Low confidence
Financial Intelligence Centre Act 38 of 2001 43b
"On registration with the Financial Intelligence Centre in terms of section 43b of the Financial Intelligence Centre Act, 2001 (Act 38 of 2001), read with draft Directive 10 of 2025 on registration of geolocation information of subsidiaries and branches of accountable institutions"
Financial Intelligence Centre Act 38 of 2001page 1recorded 10 August 2026
Cross-references
Low confidence
Financial Intelligence Centre Act 38 of 2001 29
"3.2 These other businesses, other than accountable institutions must complete the registration process when required to submit a report under section 29 of the FIC Act for the first time."
Financial Intelligence Centre Act 38 of 2001page 6recorded 10 August 2026
Cross-references
Low confidence
Financial Intelligence Centre Act 38 of 2001 42A
"5.4 In the event of a sole proprietor, the person exercising the highest level of authority may assume the role and functions of compliance officer in terms of section 42A(3) of the FIC Act."
Financial Intelligence Centre Act 38 of 2001page 9recorded 10 August 2026
Cross-references
Low confidence
Financial Intelligence Centre Act 38 of 2001 45C
"18.1 The Centre or applicable supervisory body may, in terms of section 61A and 45C(1) read with section 45C(3) of the FIC Act, impose an administrative sanction on any accountable institution, or other person to whom the FIC Act applies, for a"
Financial Intelligence Centre Act 38 of 2001page 65recorded 10 August 2026
Cross-references
Low confidence
Financial Intelligence Centre Act 38 of 2001
"Every accountable institution referred to in Schedule 1 must, within the prescribed period and in the prescribed manner, register with the Centre."
Financial Intelligence Centre Act 38 of 2001page 67recorded 10 August 2026
Cross-references
Low confidence
Financial Intelligence Centre Act 38 of 2001 43B
"PCC 5E on registration with the FIC in terms of section 43B of the FIC Act Page 67 of 67"
Financial Intelligence Centre Act 38 of 2001page 67recorded 10 August 2026
Cross-references
Low confidence
Money Laundering and Terrorist Financing Control Regulations, 2002
"1.2 Section 43B of the FIC Act requires all accountable institutions, listed in Schedule 1 of the FIC Act to register with the Centre within the prescribed period and in the prescribed manner provided for in Regulation 27A of the MLTFC Regulations."
Money Laundering and Terrorist Financing Control Regulations, 2002page 5recorded 10 August 2026

Draft PCC 5E on registration with the Centre in terms of section 43B of the FIC Act

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Example 1:

XYZ Bank Ltd, XYZ Bank Broker Division, and XYZ Bank Foreign Exchange Division

It is important to note that, although this is the same institution, it is possible for one institution to conduct the business of different accountable institutions within Schedule 1. Hence, registrations must be done separately. In this scenario, there will be three separate registrations.

A registration would be required for XYZ Bank Ltd (Schedule 1, item 6), XYZ Bank Broker Division (Schedule 1, item 12) and XYZ Bank Foreign Exchange Division (Schedule 1, item 10).

Example 1A:

XYZ Bank Ltd head office, Branch A of XYZ Bank Ltd, and Branch B of XYZ Bank Ltd.

It is important to note that it is the same accountable institution and only one accountable institution registration is made with the FIC. However, it is possible for that accountable institution to have a registered head office, multiple subsidiaries and multiple branches from which it operates.

The compliance officer must register the registered head office as the accountable institution. Thereafter organisation identity (Org ID) numbers must be registered with all the separate geographic location information against each of its various subsidiaries and branches, whether domestic or operating in a foreign jurisdiction. This must be done on the Centre's online reporting platform in accordance with draft Directive 10, as operating of the accountable institution.

4.6 If an accountable institution no longer conducts the business referred to in Schedule 1, it is still required to register with the Centre if it holds a licence or is registered in terms of another Act to conduct such business. The reason for this requirement is that such an accountable institution is legally entitled to conduct the business of an accountable institution. This principle is even applicable to institutions that never conducted the business before but are registered or licensed to do so.

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Draft PCC 5E on registration with the Centre in terms of section 43B of the FIC Act

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Example 2:

An estate agent (refer to PCC 56), registered with the Property Practitioners Regulatory Authority (formerly the Estate Agency Affairs Board), may also conduct business as a financial services provider (FSP) requiring registration with the Financial Sector Conduct Authority. The institution must register with the Centre as an estate agent under item 3, and also as an FSP under item 12, for as long as it is authorised or licensed to conduct such separate business activities.

4.7 If an accountable institution no longer conducts the business referred to in Schedule 1 and no longer holds a licence or registration in terms of another Act, such an accountable institution should notify the Centre in writing of such a deregistration so that the Centre can deregister the profile on its registration and reporting platform. The institution can notify the Centre in writing by submitting a letter on a formal letterhead.

4.8 If an accountable institution sells or otherwise transfers its business or any portion thereof to another entity, it should notify the Centre in writing by submitting a compliance query and providing the details of the new owners, date of sale and provide any relevant supporting documentation.

4.9 The accountable institution must regularly keep current and update its existing registration profile and the details of its authorised users on the Centre's registration and reporting platform.

5. PERSONS RESPONSIBLE FOR REGISTRATION AND REPORTING WITH THE CENTRE

5.1 Accountable institutions' compliance officers must register the entity with the Centre. This person is to be appointed in terms of sections 42A(2)(a) and (b), 42A(3) and 42A(4) of the FIC Act.

5.2 The person assigned with the compliance function is responsible for registering the accountable institution's main or head office registration, including the submission of branch and subsidiary geographic information on the Centre's reporting platform.

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6.3 In a scenario where a branch of an accountable institution, is an accountable institution in its own right, then that branch must register as a separate accountable institution on the Centre's registration and reporting platform.

6.4 In terms of Directive 10, accountable institutions are obliged to provide particulars of every branch and subsidiary that is not a separate accountable institution. These compliance officers can submit information under unique categories on the registration and reporting platform. The accountable institution's risk exposure and types of clients could differ substantially between different geographical areas. The information concerning the accountable institution's branches, subsidiaries and branches of subsidiaries will enhance the quality of the data provided to the Centre by the institution.

6.5 Accountable institutions are not required to register branches and subsidiaries as a separate accountable institution to the head office, nor to regard such registered branches and subsidiaries as accountable institutions.

6.6 This information will assist the Centre and supervisory bodies to understand the group structure of an accountable institution and to accordingly apply risk-based supervision in a more informed manner in relation to group-wide compliance.

Proposed methods of submission of Directive 10 information to the Centre

Accountable institutions are requested to provide their views of the below suggested methods:

**Method 1** – Individual submission (similar to reporting entity registration) of the required particulars per branch, and per subsidiary etc. by the compliance officer, assisted by the compliance function, in terms of a registration category specific for Draft Directive 10. The separate branch profiles can thereafter be linked to the head office, through delegation structures applied on the Centre's reporting platform, by arrangement with the Centre.

**Method 2** – Bulk submission of all branch and subsidiary information for an accountable institution through the attachment of an excel spreadsheet, on the main head office

Draft PCC 5E on registration with the Centre in terms of section 43B of the FIC Act

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Draft PCC 5E on registration with the Centre in terms of section 43B of the FIC Act

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9.3 Item 2: Trust and company service providers (including accountants)

(a) A person who carries on the business of preparing for, or carrying out, transactions for a client, where—

(i) the client is assisted in the planning or execution of—

(aa) The organisation of contributions necessary for the creation, operation, or management of a company, or of an external company or of a foreign company, as defined in the Companies Act, 2008 (Act 71 of 2008);

(bb) The creation, operation or management of a company, or of an external company or of a foreign company, as defined in that Act; or

(cc) the operation or management of a close corporation, as defined in the Close Corporations Act, 1984 (Act 69 of 1984).

(b) A person who carries on the business of—

(i) acting for a client as a nominee as defined in the Companies Act, 2008 (Act 71 of 2008); or

(ii) arranging for another person to act for a client as such a nominee.

(d) A person who carries on the business of preparing for or carrying out transactions (including as a trustee) related to the investment, safe keeping, control or administering of trust property within the meaning of the Trust Property Control Act, 1988 (Act 57 of 1988).

9.3.1

An accountable institution that falls within the scope of item 2 of Schedule 1 must register using its registered name. Branches and/or business units will not be regarded as separate accountable institutions. However, the compliance officer must register information of all the branches of the accountable institution. The nature and clients of a trust and company service provider do not differ substantially between different branches of the same entity.

9.3.2

Where an entity or organisation consists of multiple accountable institutions categorised under different items of Schedule 1 to the FIC Act, separate registrations per Schedule item must occur. During the registration process, the

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9.8A Item 7A: A co-operative bank as defined in the Co-operative Banks Act, 2007 (Act 40 of 2007)

9.8.1A A co-operative bank is required to register per licence in terms of its activity under item 7A of Schedule 1. Where the same licence is used by different entities, the licence holder and all entities using the licence must register separately with the Centre. The business of a co-operative bank is based on the principle of branch business, and a co-operative bank consists of all its branches. All the branches of a co-operative banking group should be in a position to provide advice and administrative services to its clients. The compliance officer must register information of all the branches of the accountable institution.

9.8.2A Where an entity or organisation consists of multiple businesses across several Schedule items (credit provider, foreign exchange agent or company, money or value transfer provider etc.) separate registrations per Schedule item must occur. The main line of business must be selected during the registration process.

Example 13:

An entity's main line of business is that of a co-operative bank, as defined, and has multiple other business offerings. These include that of a money or value transfer provider, collective investment scheme, life insurance business, a financial services provider, and that of the issuing of travellers' cheques.

Mr X is the compliance officer for all six accountable institutions.

Reporting to the Centre follows the registration structure of the accountable institution(s). Multiple MLROs can be added per registration structure i.e. per Schedule item. If the MLRO is registered under the main line of business, he or she can see all registration and reporting information for all the underlying Schedule items. If the MLRO is registered for an underlying Schedule item he or she can only see reporting and registration information of that Schedule item.

Draft PCC 5E on registration with the Centre in terms of section 43B of the FIC Act

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Draft PCC 5E on registration with the Centre in terms of section 43B of the FIC Act

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Example 16: Route, site, and independent site operators

Route Operator A has 27 branches across South Africa. These branches fall within the jurisdiction of nine different licensing authorities. All branches are separate accountable institutions.

Route Operator A must create nine independent registration structures. These structures will be based on the jurisdictions of the nine licensing authorities. Mr Y is the compliance officer of Route Operator A and can register all branches and the head office for Registration Structure 1 as per the diagram (the head office being an accountable institution with a licence issued). He can also fulfil the same role for the other structures that fall within the jurisdictions of the other gambling boards. This means that he can register all 27 accountable institutions if so decided. It is important to note that only Mr Y can register Main Office 1 and Branch 1. That way only Mr Y can have access to the registration and reporting information in Registration Structure 1.

Alternatively, the institution can use more than one person to register the registration structures. This means that registration structures and branches can be registered by different compliance officers (Mr Y, Mr A, Mr B, Mr C, Mr D, Mr E, Mr F, Mr G). Mr Y is responsible for Registration Structure 1. Mr A can register Registration Structure 2 and 3 and Mr B can register Registration Structure 4 etc. In this scenario Mr Y can access registration and reporting information in Registration Structure 1, Mr A can access registration and reporting information in Registration Structure 2 and 3 and Mr B can access registration and reporting information in Registration Structure 4 etc.

It is important to note that reporting to the Centre follows the registration structure of the accountable institution. Multiple MLROs can be added per registration structure i.e. per head office and per branch. If the MLRO is registered at head office level, he or she can see all registration and reporting information for all the underlying branch registrations. If the MLRO is registered at branch level, he or she can only see reporting and registration information of that particular branch.

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9.13.1 Financial services providers that are, in terms of their licence conditions under the Financial Advisory and Intermediary Services Act, 2002 (Act 37 of 2002), (FAIS Act), limited to the provision of advice and intermediary services on non-life insurance policies, reinsurance business, as defined, and medical schemes, are excluded from the requirement to register with the Centre. Public accountants and auditors fall within the category of item 12 of Schedule 1 provided they are licensed in terms of the FAIS Act.

9.13.2 An accountable institution that falls within the scope of item 12 of Schedule 1 must register its institution per licence issued using its registered name.

9.13.3 Where the same licence is used by different entities or organisations, the licence holder and all entities or organisations using the licence must register separately with the Centre. The compliance officer must register information of all the branches of the accountable institution.

Example 19:

An entity with the main business as a financial service provider has three further business offerings. These included services as an authorised user of an exchange, collective investment schemes and life insurance. It therefore operates across multiple FIC Act Schedule items (items 4, 5 and 8). This entity must register its main business and link the three accountable institutions by means of delegation.

Mr X will be the compliance officer for all four accountable institutions.

Reporting to the Centre follows the registration structure of the accountable institution(s). Multiple MLROs can be added per registration structure i.e. per Schedule item. If the MLRO is registered under the main line of business, he or she can see all registration and reporting information for all the underlying FIC Act Schedule items. If the MLRO is registered for an underlying FIC Act Schedule item he or she can only see reporting and registration information of that Schedule item.

PCC 5E on registration with the FIC in terms of section 43B of the FIC Act

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where “crypto asset” means a digital representation of perceived value that can be traded or transferred electronically within a community of users of the internet who consider it as a medium of exchange, unit of account or store of value and use it for payment or investment purposes, but does not include a digital representation of a fiat currency or a security as defined in the Financial Markets Act, 2012 (Act 19 of 2012).

9.22.1 Crypto asset service providers must register per licence issued. The nature of crypto business allows for this accountable institution to be in a position to have a virtual, centralised oversight over their client transactions at all times. It is therefore not required that each individual branch register on its own.

9.22.2 If an entity or organisation consists of multiple businesses across several Schedule items (bank, foreign exchange agent or company, money transfer, or value transfer etc.) separate registrations per Schedule item must occur. The main line of business must be selected during the registration process.

Example 22:

An entity's main line of business is that of a crypto asset service provider, as defined, and has multiple other business offerings. These include that of a money or value transfer provider, collective investment scheme, life insurance business, a financial services provider, and that of the issuing of traveller's cheques.

Mr X is the compliance officer for all six accountable institutions.

PCC 5E on registration with the FIC in terms of section 43B of the FIC Act

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Draft PCC 5E - Registration with the FIC

Consultation draft - not in force

Relationships in

Relationships out

Document

Linked legislation

DRAFT PUBLIC COMPLIANCE COMMUNICATION

PCC SUMMARY

THE AUTHORITATIVE NATURE OF GUIDANCE

DISCLAIMER

COPYRIGHT NOTICE

OBJECTIVE

GENERAL EXPLANATORY NOTE

4. REGISTERING UNDER THE CORRECT NAME OF THE ENTITY

Proposed methods of submission of Directive 10 information to the Centre

Example: Directive 10 Registration

Registration Structure 1

9. REGISTRATION OF ACCOUNTABLE INSTITUTIONS LISTED IN SCHEDULE 1 TO THE FIC ACT

9.1

9.2

Item 1: Legal practitioners

9.2.1

9.2.2

9.3 Item 2: Trust and company service providers (including accountants)

9.3.1

9.3.2

Example 7:

Example 10:

Example 15: Casinos bookmakers and totalisators

Example 16: Route, site, and independent site operators

9.12 Item 11:

9.12.1

10 METHOD OF REGISTRATION

10.1 Web-based registration

11 PROCESSING TIME

12 PERSON RESPONSIBLE FOR REGISTERING AN ACCOUNTABLE INSTITUTION

13 REGISTRATION DETAILS

14 THE REGISTRATION PROCESS

15 FIELDS TO BE COMPLETED

16 REMOVAL FROM THE REGISTER

17 ACCESS TO THE REGISTER

18 FAILURE TO REGISTER WITH THE CENTRE

19 COMMUNICATION WITH THE CENTRE

Glossary

Section 43B of the FIC Act: Registration by accountable institution

Section 45C(1) of the FIC Amendment Act: Responsibility of supervision of accountable institutions

Section 61A of the FIC Amendment Act: Failure to register with the FIC