Public Compliance Communications 48

PCC 60 - Format and manner of completion and submission of the 2026 risk and compliance return

currentunreviewed1 June 2026

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

This public compliance communication cross-references 2 linked laws.

Open PDF Open on FIC website

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Cross-references
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PCC 60 - Format and manner of completion and submission of the 2026 risk and compliance return
"(refer to Regulation 27A of the Money Laundering and"
PCC 60 - Format and manner of completion and submission of the 2026 risk and compliance returnpage 8recorded 10 August 2026

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Cross-references
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Directive 11 - Risk and compliance return 2026
"Refer to example above which deals with registration and commenced business."
Directive 11 - Risk and compliance return 2026page 10recorded 10 August 2026
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Document

Page 1

FIC

Financial

Intelligence Centre

PUBLIC

COMPLIANCE

COMMUNICATION 60

On the format and manner of completion and

submission of the 2026 risk and compliance

return as contemplated by Directive 11 of 2026

by specified accountable institutions

12 June 2026

Page 2

PCC SUMMARY

This Public Compliance Communication provides guidance to the specified accountable institutions, in particular items 1, 2, 3, 9, 11 (excluding banks, mutual banks, and co-operative bank credit providers), 14, 20, 21 and 22 of Schedule 1 of the Financial Intelligence Centre Act, 2001 (Act 38 of 2001) (FIC Act) on the format and manner of completion and submission of the 2026 Risk and Compliance Returns (2026 RCRs) to the Financial Intelligence Centre (Centre) by these specified accountable institutions in order to implement Directive 11 of 2026 (Directive 11), as issued by the Centre.

**The exception: A branch office is structured as a separate legal entity**

2.6. The guidance in paragraph 2.5 above does not apply in circumstances where a branch office or certain branch offices of an accountable institution, are structured as a separate partnership or incorporated legal person or juristic person in their own right, separate from, even though associated to, the specified accountable institution. Such separate partnership, incorporated legal person or juristic partnership, constitutes a unique accountable institution, which should be registered separately with the Centre, and have its own unique Org ID, as an accountable institution.

2.7. The consequence is that such partnership, legal person or juristic person, as a separate accountable institution, should have registered separately as an accountable institution in its own right, due to its legal structure, under a particular business activity as designated in an item under Schedule 1. Such specified accountable institution will also be required to submit a single 2026 RCR to the Centre in respect of all the branch offices falling within its legal structure, as a specified accountable institution for each designated FIC Act Schedule item category it falls within.

2.8. In summation, where several branch offices are structured is a separate juristic entity, from its associate accountable institution, that structure constitutes a

Public compliance communication 60 On the format and manner of completion and submission of the 2026 risk and compliance return as contemplated by Directive 11 of 2026 by specified accountable institutions

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**Example – The legal practitioner that conducts business across more than one FIC Act Schedule 1 item**

The legal practitioner which provides general legal services, which must then register with the Centre as an item 1 designated entity as a legal practitioner under Schedule 1 of the FIC Act (Schedule 1). This is normally its primary registration with the Centre.

The designation of items in Schedule 1 is based on business activity vulnerable to money laundering abuse, and therefore a functional activity approach is enshrined in Schedule 1. An accountable institution that conducts the functional business activity within a designated item must register with the Centre in respect of that business activity.

Accordingly, where the legal practitioner performs legal services in relation to such designated business activity under Schedule 1, that legal practitioner must in addition then register separately with the Centre under that designated item, such as when the legal practitioner provides trust services and company services to their clients. In that scenario, the legal practitioners must register with the Centre as under:

- Item 2 of Schedule 1, as the provider of trust services, as contemplated in Schedule 1 (the second registration); and

- Item 2 of Schedule 1, as the provider of company services as contemplated in Schedule 1 (the third registration).

This means that potentially, this legal practitioner should have three separate and unique registration profiles on the goAML registration and reporting platform of the Centre, which will result in the legal practitioner possessing three distinct and unique goAML Org ID numbers with the Centre.

The consequence is that such legal practitioner for each of the three separate accountable institution registrations it holds, must submit to the Centre three separate 2026 RCRs, one for each of the three designated item profiles under Schedule 1.

2.11. Directive 11 does not apply to a bank, mutual bank, and a co-operative bank that carries on business of a credit provider as contemplated in item 11 of Schedule 1 of the FIC Act.

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PCC 60 - Format and manner of completion and submission of the 2026 risk and compliance return

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Document

PUBLIC

PCC SUMMARY

Linked legislation

THE AUTHORITATIVE NATURE OF GUIDANCE

1. INTRODUCTION

2. GENERAL TERMS AND APPLICATION

The exception: A branch office is structured as a separate legal entity

Example – The legal practitioner that conducts business across more than one FIC Act Schedule 1 item

Manner of preparation

Example – Registered with the FIC or commenced business

3. ADHERENCE TO THE SCHEDULE GOVERNING THE 2026 RCR SUBMISSION

4. METHOD FOR SUBMITTING 2026 RISK AND COMPLIANCE RETURNS

5. COMMUNICATION WITH THE CENTRE

SCHEDULE

PCC 60 - Format and manner of completion and submission of the 2026 risk and compliance return

Relationships in

Relationships out

Document

PUBLIC

**PCC SUMMARY**

Linked legislation

**THE AUTHORITATIVE NATURE OF GUIDANCE**

1. INTRODUCTION

2. GENERAL TERMS AND APPLICATION

**The exception: A branch office is structured as a separate legal entity**

**Example – The legal practitioner that conducts business across more than one FIC Act Schedule 1 item**

Manner of preparation

Example – Registered with the FIC or commenced business

3. ADHERENCE TO THE SCHEDULE GOVERNING THE 2026 RCR SUBMISSION

4. METHOD FOR SUBMITTING 2026 RISK AND COMPLIANCE RETURNS

5. COMMUNICATION WITH THE CENTRE

**SCHEDULE**

PCC SUMMARY

THE AUTHORITATIVE NATURE OF GUIDANCE

The exception: A branch office is structured as a separate legal entity

Example – The legal practitioner that conducts business across more than one FIC Act Schedule 1 item

SCHEDULE