Who Needs to Act?

This notice applies only to the following accountable institutions:

✔ Legal Practitioners

✔ Trust & Company Service Providers (including Accountants)

✔ Estate Agents

✔ Credit Providers

✔ SA Postbank

✔ High-Value Goods Dealers

✔ SA Mint Company (RF) (Pty) Ltd

✔ Crypto Asset Service Providers

RMCP Submission on GoAML

The Financial Intelligence Centre (FIC) issued a general request on 4 March 2025 for the above-listed accountable institutions to submit their Risk Management and Compliance Programme (RMCP) in accordance with section 42(4)(a) of FICA.

Deadline: Close of business today, 12 March 2025.

Low RMCP Submission Rates (as of 10 March 2025):

The submission rate has been quite low as of yesterday. This is quite foreseeable as a deadline of 7 days is not going to optimize for high response rates. It will be interesting to see how the FIC handles this ill-advised approach. We envision system crashes and outages as the day wears on. Their call centers are overloaded with calls (some say they waited for more than an hour) and it is a general mess.

I am all for getting off the greylist but there are better ways of approaching this. Be that as it may, we are here to assist you and help you cut red tape as much as we can!

See below the table of response rates:

Sector	Registered Institutions	RMCPs Submitted	Submission Rate
Legal Practitioners (Attorneys & Advocates)	19,046	695	4%
Trust & Company Service Providers (Accountants)	759	100	13%
Estate Agents	9,086	568	6%
Credit Providers	2,039	251	12%
SA Postbank	1	0	0%
High-Value Goods Dealers	5,152	578	11%
SA Mint Company (RF) (Pty) Ltd	1	0	0%
Crypto Asset Service Providers	263	39	15%

GoAML Access: Ensure Your Credentials Are Up to Date

Apparently the FIC has received numerous inquiries about GoAML access and requested Accountable Institutions to ensure the following:

✔ Verify that login credentials are valid.

✔ Ensure the Org ID is correct.

✔ Update passwords and user details if needed.

The FIC is actively monitoring compliance and warned that failure to submit your RMCP or maintain GoAML access may result in financial sanctions.

While an extension is plausible (due to the overload on the GoAML platform and industry/regulatory revolt), it is best not to rely on this—submit as soon as you can if you have not done so already.

URGENT: Final Reminder of RMCP Submission to FIC before COB Today