The Financial Intelligence Centre (FIC) has published the finalised versions of Directive 3A and Public Compliance Communication 50A, which address what accountable institutions must do if they fail to submit a report to the FIC or if they submit defective data.
Directive 3A and PCC 50A update Directive 3 and PCC 50, respectively, to include the international funds transfer reporting obligation. They apply to all accountable institutions that are required to file a report with the FIC.
International Funds Transfer Reports (IFTRs) were introduced in 2023 as part of amendments under sections 31 and 56 of the Financial Intelligence Centre Act (FICA), focusing on cross-border electronic funds transfers exceeding a prescribed threshold of R19 999.99. This threshold, set by Regulation 23D, aims to capture transactions likely to be involved in financial crimes.
Directive 3A has been updated to provide for the process to be followed if an accountable institution fails to submit an IFTR or if it submits a defective IFTR. Directive 3A has also been updated to include a reference to proliferation financing, to align with section 3 of FICA.
PCC 50A must be read with Directive 3A because it provides guidance to reporters on measures aimed at preventing, remediating, and mitigating reporting failures, and elaborates on the process to be followed when applicable.
The publication of Directive 3A and PCC 50A follows a consultation process that closed on 21 March 2025.
The obligation to submit IFTRs falls on accountable institutions authorised to conduct cross-border electronic funds transfers. These include:
- Banks, as primary handlers of international transactions.
- Authorised dealers, recognised under the Currency and Exchanges Act for conducting such transactions.
- Financial services providers with a direct reporting dispensation under the Exchange Control Regulations.
IFTRs are required for two types of transactions:
- Outgoing transfers – when money is sent out of South Africa on behalf of or at the instruction of another person, exceeding R19 999.99.
- Incoming transfers – when money is received from outside South Africa under similar conditions, also exceeding the threshold.
The electronic nature of these transactions is key, covering wire transfers, SWIFT payments, and other digital methods, but not physical cash movements, which are addressed separately under other FICA reporting requirements.
