Directive 6 & Directive 7 serve to inform certain Accountable Institutions that they must submit information regarding their understanding of money laundering (ML), terrorist financing (TF) and proliferation financing (PF) risks and their assessment of compliance with obligations in terms of the FIC Act to the FIC through a risk and compliance return.

The information obtained from the risk and compliance return will assist the FIC in forming an understanding of the levels of risk awareness and compliance of the responding Accountable Institution with the FIC Act and in identifying the ML, TF and PF risks facing different Accountable Institution sectors.

The completion of the risk and compliance return is compulsory for all identified accountable institutions specified in Directive 6 & 7.
Non-submission of the risk and compliance return will be considered non-compliance and may result in an administrative sanction, in accordance with section 62E read with section 43A(3) of the FIC Act.

Directive 6 & 7 requirements are effectively identical, but apply different reporting periods and deadlines to different institutions

Who does this apply to?

Under Directive 6

FIC Schedule 1 Item 1: Attorneys, Advocates
FIC Schedule 1 Item 2: Trust & Company Service Providers
FIC Schedule 1 Item 3: An Estate Agent
FIC Schedule 1 Item 9: Firms licences under the National Gambling Board

Under Directive 7

FIC Schedule 1 Item 11: Credit Providers
FIC Schedule 1 Item 14: SA Postbank
FIC Schedule 1 Item 20: High Value Goods Dealers
FIC Schedule 1 Item 21: SA Mint
FIC Schedule 1 Item 22: Virtual Asset Service Providers

What must be done?

For institutions under Directive 6: Complete the online risk and compliance return covering the reporting period from 1 April 2022 to 31 March 2023, both dates inclusive.

For institutions under Directive 7: Complete the online risk and compliance return covering the reporting period from 1 January 2023 to 30 June 2023, both dates inclusive.

When must this be done?

For institutions under Directive 6: The risk and compliance return must be submitted to the FIC no later than 17:00 on Wednesday, 31 May 2023.

For institutions under Directive 7: The risk and compliance return must be submitted to the FIC no later than 17:00 on Monday, 31 July 2023.