The Financial Intelligence Centre (FIC) has published an updated guide on how accountable institutions must register with the Centre. The guide also applies to businesses that are obliged to report suspicious and unusual transactions in terms of the Financial Intelligence Centre Act (FICA).
The new guide, Public Compliance Communication 5D, replaces PCC 5C, which was issued in May 2018. PCC 5D updates the content of PCC 5C to take account of the changes to Schedules 1 and 3 to FICA, which came into effect on 19 December 2022.
PCC 5D details the accountable institutions that must register with the FIC and sets out the process for doing so. For each item in Schedule 1, it describes and provides examples of the registration requirements for entities that have multiple branches or where different entities or organisations operate under the same licence.
An accountable institution that forms part of a group or corporate vehicle must register individually, irrespective of whether it is a separate corporate vehicle or a division that qualifies as an accountable institution by virtue of the business it conducts.
In some cases, an entity can be an accountable institution under more than one category in Schedule 1.
Where a group consists of different entities that are separate corporate vehicles, each entity must register in its own right if it is an accountable institution.
Accountable institutions’ compliance officers are responsible for registering an entity with the FIC. This person is to be appointed in terms of sections 42A(2)(a) and (b), 42A(3), and 42A(4) of FICA.
In a sole proprietorship, the person exercising the highest level of authority may assume the role and functions of compliance officer. This person could be the owner of or the most senior person in the accountable institution.
