FIC Issues New Circular: Delisting and Unfreezing Obligations Now in Effect
This article will count 0.25 units (15 minutes) of unverifiable CPD. Remember to log these units under your membership profile.
The Financial Intelligence Centre (FIC) has issued Circular 01 of 2026, alerting all Accountable Institutions (AIs), Reporting Institutions (RIs), and related entities to immediate obligations following recent updates from the United Nations Security Council (UNSC) sanctions lists.
Who is Affected?
If your business or institution previously froze someone’s money or assets because they were listed by the UNSC, you now need to unfreeze those funds if that person or group has been removed from the list. This instruction applies to:
Accountable Institutions (like banks, lawyers, estate agents)
Reporting Institutions
Any person or business that froze assets under anti-terror laws.
What Has Changed?
Entities must now:
Take delisting and unfreezing actions without delay for individuals, organisations, or countries removed from the UN’s designated sanctions lists.
Regularly screen clients and transactions against the updated UNSC lists — not just at onboarding but on an ongoing basis.
Subscribe to UNSC sanctions updates via email (send request to: sc-sanctionslists@un.org) to stay compliant.
The updated list can be accessed here: UNSC 1518 Sanctions Committee (Iraq).
Additional Reporting Requirement
In addition to existing AML reporting obligations, AIs and RIs must now also report suspected terrorist and proliferation financing using one of three dedicated report types:
Sanction Name Match Activity Report (SNMA)
Terrorist and Proliferation Financing Activity Report (TFPA)
Terrorist and Proliferation Financing Transaction Report (TPFT)
These reports can be submitted electronically via the FIC’s goAML portal or manually to helpdesk@fic.na.
Why It Matters
Failure to act in line with this circular is a breach of Section 63 of the FIA and could result in penalties or enforcement action. More importantly, failure to delist or unfreeze assets in a timely manner risks undermining South Africa’s financial integrity and compliance reputation.
Stay informed and compliant. If your institution handles asset freezes or sanctions checks, this update affects you directly.
