Public Compliance Communications 38

Draft PCC 118A - Interpretation of money or value transfer service providers

draftaccepted1 March 2025

Draft PCC 118A – Interpretation of money or value transfer service providers (page 1)

This public compliance communication cross-references 7 linked laws.

Consultation draft - not in force

This item is marked as draft or consultation material. It is kept for lineage and review, but should not be treated as binding guidance unless a final instrument is separately verified.

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Draft PCC 118A - Interpretation of money or value transfer service providers
"The Financial Intelligence Centre (Centre) provides the guidance contained in this draft PCC in terms of its statutory function in terms of section 4 (c) of the FIC Act read together with Regulation 28 of the Money Laundering and Terrorist Financing Control Regulations (Regulations) issued in terms of the FIC Act."
Draft PCC 118A - Interpretation of money or value transfer service providerspage 2recorded 10 August 2026

Relationships out

Read together with
Low confidence
Draft PCC 118A - Interpretation of money or value transfer service providers
"The Financial Intelligence Centre (Centre) provides the guidance contained in this draft PCC in terms of its statutory function in terms of section 4 (c) of the FIC Act read together with Regulation 28 of the Money Laundering and Terrorist Financing Control Regulations (Regulations) issued in terms of the FIC Act."
Draft PCC 118A - Interpretation of money or value transfer service providers

Document

Page 1

FIC

Financial Intelligence Centre

DRAFT PUBLIC COMPLIANCE COMMUNICATION

DRAFT PUBLIC COMPLIANCE COMMUNICATION 118A FOR CONSULTATION

GUIDANCE ON THE INTERPRETATION OF MONEY OR VALUE TRANSFER SERVICE PROVIDERS, IN TERMS OF THE FINANCIAL INTELLIGENCE CENTRE ACT AND THEIR REGISTRATION, REPORTING AND SUPERVISION

31 March 2025

Page 2

PCC REVISION NOTE

Save for new sections in paragraphs 2.7 and 2.22, this public compliance communication (PCC) 118A follows closely the layout and content presented in PCC 118, which was issued for consultation in December 2022.

PCC 118A provides guidance on the registration, reporting and supervision of money value and transfer services (MVTS) providers, under item 19 to Schedule 1 of the Financial Intelligence Centre Act (FIC Act) that engage in cross-border activity and/or domestic business activity.

Linked legislation

Cross-references

Low confidence

Financial Intelligence Centre Act 38 of 2001

"Future reports not submitted under the correct Schedule 1 item on the Centre's registration and reporting platform will be rejected."
Financial Intelligence Centre Act 38 of 2001page 14recorded 10 August 2026

Cross-references

Low confidence

Financial Intelligence Centre Act 38 of 2001 28

"ration and reporting platform will be rejected. Refer to Guidance note 9 2.22 Domestic and cross-border MVTS providers must submit to the Centre cash threshold reports (CTRs) in terms of section 28 of the FIC Act, suspicious and unusual transaction and activity reports (STRs and SARs) in terms of section 29 of the FIC Act and terrorist property reports (TPRs) in terms of section 28A of the FIC Ac"
Financial Intelligence Centre Act 38 of 2001page 14recorded 10 August 2026

Cross-references

Low confidence

Financial Intelligence Centre Act 38 of 2001 28A

"section 28 of the FIC Act, suspicious and unusual transaction and activity reports (STRs and SARs) in terms of section 29 of the FIC Act and terrorist property reports (TPRs) in terms of section 28A of the FIC Act, under the correct cross-border and domestic MVTS item 19 category and not under another Schedule item number on the Centre's registration and reporting platform. 31 March 2025 – Draft"
Financial Intelligence Centre Act 38 of 2001page 14recorded 10 August 2026

Cross-references

Low confidence

Financial Intelligence Centre Act 38 of 2001 29

"roviders must submit to the Centre cash threshold reports (CTRs) in terms of section 28 of the FIC Act, suspicious and unusual transaction and activity reports (STRs and SARs) in terms of section 29 of the FIC Act and terrorist property reports (TPRs) in terms of section 28A of the FIC Act, under the correct cross-border and domestic MVTS item 19 category and not under another Schedule item number"
Financial Intelligence Centre Act 38 of 2001page 14recorded 10 August 2026

Cross-references

Low confidence

Financial Intelligence Centre Act 38 of 2001 31

"2.21 A cross-border MVTS provider must report electronic cross-border transactions by submitting international funds transfer reports (IFTRs) in terms of section 31 of the FIC Act through item 19 accountable institution registration only."
Financial Intelligence Centre Act 38 of 2001page 14recorded 10 August 2026

Cross-references

Low confidence

Financial Intelligence Centre Act 38 of 2001 42B

"5.1 Before issuing guidance to accountable institutions, supervisory bodies and other persons regarding their performance, duties and obligations in terms of the FIC Act or any directive made in terms of the FIC Act, the Centre must in accordance with section 42B of the FIC Act:"
Financial Intelligence Centre Act 38 of 2001page 18recorded 10 August 2026

Cross-references

Low confidence

Money Laundering and Terrorist Financing Control Regulations, 2002

"The Financial Intelligence Centre (Centre) provides the guidance contained in this draft PCC in terms of its statutory function in terms of section 4 (c) of the FIC Act read together with Regulation 28 of the Money Laundering and Terrorist Financing Control Regulations (Regulations) issued in terms of the FIC Act."
Money Laundering and Terrorist Financing Control Regulations, 2002page 2recorded 10 August 2026

DISCLAIMER

The publication of a PCC concerning any particular issue, as with other forms of guidance which the Centre provides, does not relieve the user of the guidance from the responsibility to exercise their own skill and care in relation to the users' legal position. The Centre accepts no liability for any loss suffered as a result of reliance on this publication.

OBJECTIVE

This PCC provides clarity on the interpretation of "a person who carries on the business of a money or value transfer provider" as designated in item 19 of Schedule 1 to the FIC Act.

31 March 2025 – Draft public compliance communication 118A guidance on the definition regarding the money or value transfer service provider in terms of Schedule 1 of the Financial Intelligence Centre Act.

Draft PCC 118A - Interpretation of money or value transfer service providers

Consultation draft - not in force

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Document

DRAFT PUBLIC COMPLIANCE COMMUNICATION

Linked legislation

DISCLAIMER

COPYRIGHT NOTICE

OBJECTIVE

1. INTRODUCTION

Formal cross-border MVTS providers

Informal or alternative cross-border MVTS providers

Other cross-border MVTS providers

Domestic MVTS providers

Consultation notes – Scope of MVTS providers:

Consultation notes – Payment activities:

Exclusions from the MVTS providers designation

Consultation note – MVTS providers exclusions:

Agency in MVTS provider arrangements

Registration considerations for MVTS providers

Client risk indicators

5 CONSULTATION

6 COMMUNICATION WITH THE CENTRE

FATF Glossary to the FATF Recommendations adopted 16 February 2012, and last updated February 2025 (accessible here)

FATF Guidance for 'A Risk-Based Approach for Money or Value Transfer Services' issued February 2016, Paragraph 11 provides as follows: