Public Compliance Communications 20

PCC 49 - Guidance on ML, TF and PF considerations relating to geographic areas

currentaccepted1 September 2023

This PCC provides guidance on certain ML/TF/PF risk considerations and provides suggested resources that may be consulted in determining the ML/TF/PF risk related to geographic areas. (page 2)

Open PDF Open on FIC website

Relationships in

Cross-references
Low confidence
PCC 49 - Guidance on ML, TF and PF considerations relating to geographic areas
"Readers should refer to PCC49 for further guidance on ML/TF/PF risks regarding geographies."
PCC 49 - Guidance on ML, TF and PF considerations relating to geographic areaspage 10recorded 10 August 2026
Cross-references
Low confidence
PCC 49 - Guidance on ML, TF and PF considerations relating to geographic areas
"Refer to PCC 49 for further guidance on geographic area risks."
PCC 49 - Guidance on ML, TF and PF considerations relating to geographic areaspage 26recorded 10 August 2026

Relationships out

No relationships recorded.

Linked legislation

No relationships recorded.

Document

Page 1

FIC

Financial Intelligence Centre

PUBLIC COMPLIANCE COMMUNICATION

No. 49

GUIDANCE ON MONEY LAUNDERING,

TERRORIST FINANCING RISK AND

PROLIFERATION FINANCING

CONSIDERATIONS RELATING TO

GEOGRAPHIC AREAS

Page 2

Public Compliance Communication 49 guidance on ML/TF/PF risk considerations relating to geographic areas

Page 2 of 10

PCC SUMMARY

An accountable institution relies on different money laundering (ML), terrorist financing (TF) and proliferation financing (PF) indicators to determine the risk that a business relationship and or single transaction may pose to the accountable institution, one of these indicators relates to geographic areas. It is not the geographic area in and of itself that could pose a ML/TF/PF risk, but the features and activities associated with such a geographic area.

1. INTRODUCTION

1.1. There are several indicators that may be indicative of money laundering (ML), terrorist financing (TF) and proliferation financing (PF) risks. As expressed in Guidance Note 7, these indicators, including the client, product or services, delivery channels and geographic areas, can assist in a comprehensive formulation of an understanding of ML/TF/PF risks and the application of an adequate risk-based approach.

1.2. The focus of this PCC is to elaborate on the ML/TF/PF threats and vulnerabilities posed by international geographic areas. The general principles expressed in this PCC should be applied to the application of domestic geographic area risk considerations, where relevant.

1.3. The exclusion of assessing geographic areas, both internationally and domestically, when determining ML/TF/PF risks may result in an incomplete and inadequate risk management process.

1.4. A geographic area risk indicator relates to the ML/TF/PF risks considerations that are associated with a geographic area, where this geographic area is relevant to a single transaction or business relationship with a client. A geographic area indicator can include the geographic area in relation to the client, the product or service and the inflow and outflow of funds such as the source or destination of the funds in relation to the business relationship, or transaction with a client.

1.5. A geographic area is not limited in definition and can include a specific area within the borders of a country, a country, areas of specific interest globally or countries belonging to certain groupings. Geographic areas include international areas and domestic areas i.e. areas within the borders of South Africa.

1.6. A geographic area in and of itself does not present a ML/TF/PF risk, rather the features and activities attached to the geographic area serves as an indication of the potential abuse for ML/TF/PF within that geographic area.

1.7. There may be varying levels of ML/TF/PF risk associated with geographic areas, ranging from a lower to a higher level of ML/TF/PF risk, as determined in the accountable institution's risk framework.

Public Compliance Communication 49 guidance on ML/TF/PF risk considerations relating to geographic areas

Page 3 of 10

2. DETERMINING RISK IN RELATION TO GEOGRAPHIC AREAS

2.1. In order to determine the ML/TF/PF risk associated with a geographic area, an accountable institution would need to review the geographic area against a certain set of features and/or activities. This may result in the accountable institution deeming the risk relating to a geographic area to present either a lower risk, or a higher risk.

Public Compliance Communication 49 guidance on ML/TF/PF risk considerations relating to geographic areas

Page 4 of 10

PCC 49 - Guidance on ML, TF and PF considerations relating to geographic areas

Relationships in

Relationships out

Linked legislation

Document

PUBLIC COMPLIANCE COMMUNICATION

PCC SUMMARY

DISCLAIMER

COPYRIGHT NOTICE

OBJECTIVE

1. INTRODUCTION

2. DETERMINING RISK IN RELATION TO GEOGRAPHIC AREAS

3. AVAILABLE SOURCES OF INFORMATION BY INTERNATIONAL BODIES

Financial Action Task Force (FATF)

Transparency International

The Organisation for of Economic Co-Operation and Development (OECD)

The United Nations Office on Drugs and Crime (UNODC)

Geographic risk indicators

5 COMMUNICATION WITH THE CENTRE