FIC Issues Updated Guidance Note 7A With Major Updates— What You Need to Know

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On 1 September 2025 the Financial Intelligence Centre (FIC) has issued the Revised FIC Guidance Note 7A – September 2025 (PDF), a key update that consolidates and replaces both the original 2017 Guidance Note 7 and the earlier 2025 version of Guidance Note 7A. This updated guide reflects the most current expectations for compliance with the Financial Intelligence Centre Act, 2001 (Act 38 of 2001) (FIC Act) and comes with a number of significant changes that accountants must understand and implement.

🔍 What’s Changed?

• Beneficial Ownership – Clearer Rules

  The revised guide formally integrates Public Compliance Communication 59 (PCC 59), which outlines how accountable institutions must:

  • Identify beneficial owners

  • Verify their identities

  • Maintain accurate and up-to-date ownership records.

This update is especially important for accountants who assist clients in structuring companies, trusts, or partnerships.

• Legal Alignment

The guidance is now fully aligned with the General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act, 2022. This brings consistency between the FIC’s operational guidance and South Africa’s legislative framework.

📌 In Focus: Three Areas with Significant Expansion

• Deeper Risk-Based Approach Guidance

  While the principle of a risk-based approach (RBA) has always been part of the FIC framework, GN 7A provides significantly more depth:

  • Clearer definitions of “inherent risk” and “residual risk”

  • Enhanced breakdown of risk factors—across clients, products, geographic areas, and delivery channels

  • Greater emphasis on how to tailor risk controls to the size, complexity, and activities of your business

  • Holistic risk views that require combining risk indicators rather than evaluating them in isolation

  • Specific attention to continuous reassessment of ML/TF risk in light of new threats, client behaviour, or product changes

This makes it easier for small and large firms alike to develop practical and proportionate risk mitigation measures.

• Customer Due Diligence (CDD) – More Practical Guidance

  The updated guide includes new clarity and structure around CDD obligations:

  • When and how to verify clients’ identities

  • What to do when verification is delayed or not possible

  • Clearer guidance on ongoing due diligence, especially for long-standing client relationships

  • More detailed provisions for non-face-to-face client onboarding, relevant to accountants using digital or remote services

  • This supports better decision-making for practices that need flexibility while ensuring compliance.

• Sanctions Screening and Asset Freezing

  Chapter 5 of the revised note offers detailed instruction on implementing United Nations Security Council sanctions:

  • Mechanisms for screening clients and transactions

  • How to comply with asset freezing directives

  • Allowances for basic living expenses where relevant

  • Guidance on making sanctions lists accessible and ensuring your systems can react promptly to matches.

This update is critical for firms that may deal with foreign clients, cross-border transfers, or politically exposed persons (PEPs).

Key Takeaways for Accountants

• You must update your Risk Management and Compliance Programme (RMCP) to reflect the latest definitions and standards.

• Enhanced risk indicators and client profiling allow you to prioritise your compliance efforts where it matters most.

• If your firm deals with trusts, complex entities, or high-risk clients, the beneficial ownership provisions are non-negotiable.

• Failing to align with the new guidance could result in regulatory scrutiny or enforcement.