The accountable institutions that must submit a copy of their Risk Management and Compliance Programme (RMCP) to the Financial Intelligence Centre (FIC) can do so after the deadline, but they may be sanctioned.
On 4 March, the FIC published a notice stating that the accountable institutions it supervises will receive a letter instructing them to submit their RMCP by the close of business on Wednesday, 12 March.
In a notice published on its website on 12 March, the FIC said a large number of these accountable institutions were submitting their RMCPs on Wednesday. As a result, the Centre will permit institutions to submit RMCPs after the deadline.
However, institutions that file their RMCPs after the deadline of the close of business on 12 March are regarded non-compliant and such non-compliance may attract a financial sanction, the Centre said.
The following accountable institutions are required to submit their RMCPs:
- Legal practitioners (item 1)
- Trust and company service providers, including accountants (item 2)
- Estate agents (item 3)
- Licensed gambling institutions, including casinos (item 9)
- Credit providers (item 11)
- SA Postbank (item 14)
- High-value goods dealers (item 20)
- SA Mint Company (Pty) Ltd (item 21)
- Crypto asset service providers (item 22)
Note that the request does not apply to financial services providers (item 12), which are supervised by the FSCA. (The Authority also supervises authorised users of an exchange and collective investment scheme managers.)
Accountable institutions must submit their RMCP using the FIC’s goAML web platform. The letter includes instructions on how to do this.
The FIC said accountable institutions must use the correct schedule item number designation for each activity when filing their RMCP. For example, legal practitioners must use item 1 when filing the RMCP of their legal practice. Failure to file the RMCP under the correct item number may result in the RMCP being rejected.
Accessing goAML
The Centre said it continues to receive numerous enquiries on how to access goAML, which is the main channel for registration with the FIC, and for communication and contact with accountable institutions.
Accountable institutions can only access goAML and submit compliance information to the FIC if they have their unique goAML organisational identity (Org ID), as registered on goAML.
The FIC urges all accountable institutions to ensure they have up-to-date and valid user access to goAML, and their unique user and institution log-in credentials to the goAML platform are current.
Several of the enquires received by the FIC relate to resetting passwords, updating user and institution log-in credentials, and registering additional users on goAML. The necessary steps to follow for both are as follows:
Resetting your password on goAML
- Click on “Register | Report” on the FIC website
- Click on “LOGIN” on the goAML landing page
- Select “Forgot Password?”
- Enter your user-name and email address
- Enter authentication code
- Click “Submit”
A message will be sent to your registered email address with a link to reset the password. Click on the link and capture your new password. Your new password must be between five to 10 alphanumeric characters and special characters, of which one alpha character must be in upper case, e.g. Pass1!
Registering additional users on goAML
Existing registrants should not click on “Register as an organisation” because this will create a duplicate registration, which will be rejected by the FIC.
To add users to the goAML system, follow these steps:
Step 1: Click on “Register | Report” on the FIC website.
Step 2: Click “Register as a person”.
Note: You cannot register your entity as a person. Only compliance officers or money laundering reporting officers can be added as additional users.
Step 3: Insert the Org ID and complete the registration form. Add the relevant attachments (that is, a certified copy of your identity document or passport number and a signed authorisation letter) before clicking “submit”.
Note: The authorisation letter must be on your entity’s letterhead and include the details of the additional compliance officer, such as their name, surname, ID or passport number, occupation, and their role to be allocated on the system. Without this authorisation letter, your registration will be rejected.
Step 4: The FIC will confirm the successful registration of the additional user. Only then can the compliance officer update and verify the institution’s details.
Note: Mandatory details as indicated on the goAML system must be provided or updated to ensure successful submission of all reports.
Step 5: The FIC will confirm the successful account registration, and the newly registered compliance officer can file reports.
Help with FICA compliance
Moonstone Compliance offers compliance, consulting, and training options for accountable institutions of all types and sizes to help them meet the requirements of FICA.
Moonstone Compliance provides a wide range of services, from providing documentation to implementing a full compliance framework. You can select a combination of services and have them customised according to your needs.
Click here to read more about Moonstone Compliance’s suite of FICA services or submit an online enquiry.
