Public Compliance Communications 11

PCC 31A - Guidance on the receipt and acceptance of funds by AIs

currentaccepted1 September 2023

Guidance provided by the Centre is the only form of guidance formally recognised in terms of the FIC Act and the Regulations issued under the FIC Act. (page 2)

This public compliance communication supersedes 1 publication and cross-references 4 linked laws.

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Replaces
AI-assistedConfidence 1.0
PCC31
"This PCC31A replaces PCC31, and comes into effect on date of publication of this PCC31A."
PCC31page 3recorded 10 August 2026
Cross-references
Low confidence
guidance note 7
"3.2 A prospective client is deemed to be a person with whom the accountable institution does not have a business relationship or with whom it is in the process of concluding a single transaction (refer to chapter 2 of guidance note 7 for a further discussion on this matter)."
guidance note 7page 4recorded 10 August 2026

Linked legislation

Cross-references
Low confidence

Document

Page 1

FIC

Financial Intelligence Centre

PUBLIC COMPLIANCE COMMUNICATION

PUBLIC COMPLIANCE COMMUNICATION No 31A (PCC 31A) ON THE RECEIPT AND ACCEPTANCE OF FUNDS BY ACCOUNTABLE INSTITUTIONS PRIOR TO COMPLETION OF THE CUSTOMER DUE DILIGENCE MEASURES REQUIRED IN TERMS OF THE FINANCIAL INTELLIGENCE CENTRE ACT, 2001 (ACT NO. 38 OF 2001)

Page 2

The Financial Intelligence Centre (the Centre) provides the guidance contained in this Public Compliance Communication (PCC) in terms of its statutory function in terms of section 4(c) of the Financial Intelligence Centre Act, 2001 (Act No. 38 of 2001 (the FIC Act) read together with Regulation 28 of the Money Laundering and Terrorist Financing Control Regulations (the Regulations) issued in terms of the FIC Act.

Section 4(c) of the FIC Act empowers the Centre to provide guidance in relation to a number of matters concerning compliance with the obligations of the FIC Act. Guidance provided by the Centre is the only form of guidance formally recognised in terms of the FIC Act and the Regulations issued under the FIC Act. Accordingly, guidance provided by the Centre is authoritative in nature and must be taken into account when interpreting the provisions of the FIC Act or assessing compliance with the obligations it imposes.

4. Receipt of funds and the managing of risk

4.1 An accountable institution incurs increased money laundering and terrorist financing (ML/TF) risk when it receives funds from an unidentified person, who may or may not become a prospective client.

4.2 An accountable institution must take care to mitigate ML/TF risks by, for example, not enabling a prospective client to provide funds to the accountable institution that may have to be returned before the accountable institution has made a decision to on-board the prospective client.

4.3 The Centre's view is that only once a prospective client has been satisfactorily identified and verified, and the accountable institution has then taken a decision to accept the prospective client as a client, can they accept funds from the client in respect of the single transaction or business relationship. Therefore, an accountable institution can only make a decision to on-board a client after the client identification and verification measures have been successfully completed.

4.4 An accountable institution must, within their risk management and compliance programme (RMCP), contain measures to mitigate ML/TF risk. The Centre recommends that the RMCP includes measures to reduce the possibility of the receipt of funds from an unidentified person or entity.

4.5 The receipt of an application from a prospective client to conduct business with an accountable institution should not amount to an agreement and should not be relied upon to request the prospective client to provide funds to the accountable institution before the identity of the client has been established and verified.

PUBLIC COMPLIANCE COMMUNICATION No. 31A (PCC31A) ON THE RECEIPT AND ACCEPTANCE OF FUNDS BY ACCOUNTABLE INSTITUTIONS PRIOR TO COMPLETION OF THE CUSTOMER DUE DILIGENCE MEASURES REQUIRED IN TERMS OF THE FINANCIAL INTELLIGENCE CENTRE ACT,2001 (ACT NO. 38 OF 2001)