Anti-Money Laundering & FICA Compliance
Some businesses are legally required to know exactly who their clients are, keep an eye on what they do, and tell the Financial Intelligence Centre when something looks wrong. FICA calls them accountable institutions — law firms, estate agents, credit providers and about twenty other kinds of business. If that's you, we build the programme those duties ask for, and build it so your team can actually run it.
What this covers
Knowing who your clients are
Checking that someone is who they say they are, working out who really owns the company behind them, and doing extra checks on the clients that warrant them. FICA calls this customer due diligence. Most firms already do the work — what's usually missing is the paper trail that shows it, so we build the proof in as you go.
Checking names against the lists
The lists of people you can't do business with keep changing, and so do the politically exposed people (PEPs) who warrant a closer look. Screening someone once, on the day you take them on, doesn't discharge the duty. We set up screening that keeps running against current lists, and a record of what was checked and when.
Spotting what doesn't fit
Which patterns actually matter in your sector, and what to do the moment one shows up. That covers the reports FICA asks for — cash over the threshold, and anything that looks suspicious — and the deadline attached to each.
Registration, kept current
You register with the Financial Intelligence Centre through a system called goAML, under a business type that has to be the right one. Then you keep the named people current: your Compliance Officer, your Money Laundering Reporting Officer, your system administrators. Registrations usually go stale after somebody leaves, which is easy to miss and easy to put right.
Ready if someone asks
South Africa left the FATF grey list in October 2025. The next Mutual Evaluation began in 2026 and runs into 2027, and what supervisors want to see has shifted: not whether the document exists, but whether the thing it describes actually happens. Could you show that on Monday?
- Law firms, and anyone who sets up companies or trusts for clients
- Estate agents and property practitioners
- Dealers in high-value goods, precious metals and stones
- Credit providers, crypto platforms and gambling operators
- Anyone else on Schedule 1 to the Financial Intelligence Centre Act — a longer list than most people expect
- A written AML programme built around the risks in your sector
- Client checks your team can follow, with the templates to run them
- Screening and monitoring that leaves a trail you can show
- A clear route for filing cash threshold and suspicious transaction reports
- Staff who know what to look for and who to tell
Questions we get a lot
It's the legal label for a business that FICA applies to. The full list sits in Schedule 1 to the Financial Intelligence Centre Act and runs to about twenty categories: law firms, estate agents, people who set up companies and trusts, dealers in high-value goods, credit providers, crypto platforms and gambling operators, among others. If your business is on that list, the duties apply — however small you are.
No. Coming off the grey list in October 2025 says the country's legal framework is in better shape; it doesn't change a single duty FICA places on your business. The next FATF Mutual Evaluation of South Africa began in 2026 and runs to October 2027, and it looks at how controls work in practice rather than whether the policies are on file.
The Financial Intelligence Centre can impose administrative sanctions, including financial penalties, and has done so against businesses of every size. Penalties under FICA can reach R50 million for serious non-compliance. Findings also carry weight with supervisors, banks and clients.
At least once a year, and again whenever someone changes role or a new obligation comes in. Keep a record while you're at it — an inspection will ask who attended, what was covered and when.
Let’s take a look at where you stand.
A free consultation works out what applies to your business and what you already have in place — before you commit to anything else.