It appears that there is still uncertainty about who is required to register with the Financial Intelligence Centre.
PCC05A, which came into effect on 30 March 2016, provides additional clarity on the position of financial advisers that only operate in the short-term and medical schemes fields:
“Item 12: A person who carries on the business of a financial services provider requiring authorisation in terms of the Financial Advisory and Intermediary Services Act, 2002 (Act 37 of 2002), to provide advice and intermediary services in respect of the investment of any financial product (but excluding a short term insurance contract or policy referred to in the Short-term Insurance Act, 1998 (Act 53 of 1998) and a health service benefit provided by a medical scheme as defined in section 1(1) of the Medical Schemes Act, 1998 (Act 131 of 1998).”
5.18.1 Financial services providers that are, in terms of their license conditions under the Financial Advisory and Intermediary Services Act, No 37 of 2002 (FAIS Act), limited to the provision of advice and intermediary services on short-term insurance and medical aid membership only are excluded from the requirement to register with the Centre.
