Are You FIC-Registered? What Every Accountant Must Know Now
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You registered a company for a client last year. Simple admin task? Maybe not. That single service could make your practice an accountable institution under the Financial Intelligence Centre Act (FIC Act), with legal compliance duties many accountants still do not fully understand.
If your practice assists clients with company or trust structures, this is something you need to check now.
Do You Need to Register with the FIC?
Not every accountant must register with the FIC. But if your practice provides certain trust or company-related services, you may qualify as a Trust and Company Service Provider (TCSP) under Item 2 of Schedule 1 of the FIC Act. If you do, registration is compulsory.
If you provide the following services, YES, you are a TCSP:
Registering companies with CIPC on behalf of clients
Registering or administering trusts with the Master of the High Court
Acting as a nominee shareholder or arranging nominee structures for clients
A nominee is someone who officially holds shares or ownership on behalf of another person.
The following services alone DO NOT NORMALLY require FIC registration:
Bookkeeping
Compiling financial statements
Tax return submissions
Payroll services
General accounting or advisory work that does not involve managing or controlling client entities.
The FIC clarified this position in Public Compliance Communication 6A (PCC 6A) for TCSPs explaining when accountants cross into TCSP activity.
What Happens Once You Are Registered?
Once registered as an accountable institution, your compliance duties become ongoing legal obligations.
Your RMCP Is the Foundation
Every accountable institution must have a written Risk Management and Compliance Programme (RMCP) following Guidance Note 7A . Your RMCP explains how your practice:
▶️Identifies money laundering risks
▶️Assesses client risk
▶️Verifies clients
▶️Monitors suspicious activity
▶️Handles reporting obligations.
Importantly, PCC 53 makes it clear that an RMCP is not compliant if it simply sits in a file untouched. It must actually be implemented, communicated to staff, and reviewed regularly. CIBA provides RMCP templates for both incorporated practices and sole practitioners.
Know Your Client Properly
For every TCSP client, you must complete proper client onboarding before providing services. This includes:
✅Verifying identity documents
✅Identifying beneficial owners
✅Checking the Targeted Financial Sanctions list
✅Screening politically exposed persons (PEPs)
✅Risk-rating the client
Importantly, these requirements only apply to TCSP clients, not ordinary bookkeeping or tax clients. PCC 6A specifically confirms this distinction. You can use CIBA’s Client onboarding form to document the considerations. Do not forget to collect evidence with the procedures, i.e. copies of documents, proof of verifications etc.
Reporting to the FIC
Registered accountable institutions may need to file reports through the FIC’s goAML platform. These include:
💵Cash Threshold Reports (CTR)
Required for cash transactions of R50 000 or more.
Reports must generally be submitted as soon as possible, but no later than two business days after becoming aware of the transaction.
🤔Suspicious Transaction Reports (STR)
Required where you suspect money laundering, terrorist financing, tax crimes, or proceeds of unlawful activity.
There is no minimum amount. Even cancelled or attempted transactions may trigger reporting obligations.
STRs must be submitted as soon as possible, and no later than 15 days after the suspicion arose.
🕵️Terrorist Property Reports (TPR)
Required where property or assets may be linked to terrorist activity or sanctioned persons.All reporting is done electronically through goAML.
Directive 11 of 2026: The Deadline Many Practices Are Missing
This is currently the biggest compliance issue affecting TCSPs. Directive 11 of 2026 requires all Item 2 institutions (TCSPs) to submit a Risk and Compliance Return (RCR) to the FIC by 30 June 2026.
The reporting period covers 3 years: 1 April 2023 to 31 March 2026.
The questionnaire asks how your practice manages money laundering, terrorist financing, and proliferation financing risks.
The submission window opened on 4 May 2026 and submissions by TSCPs must be made by 30 June 2026.
The RCR is not an exam and there is no “pass or fail.” However, failing to submit it may result in administrative sanctions under the FIC Act.
Before completing the RCR, make sure you have:
Your FIC ORG ID
Your signed RMCP
AML training records
Your reporting history (CTR, STR and TPR submissions)
Client records for all TCSP clients.
Registered by Mistake? Fix It Now
Many accounting practices registered early before the FIC clarified the TCSP rules in PCC 6A.
If your practice only performs normal accounting, bookkeeping, payroll, or tax work, you may not need to remain registered.
Currently, goAML does not have a simple deregistration button.
The practical options are:
Update your services on goAML to reflect your actual activities
Submit a compliance query to the FIC requesting confirmation of your registration status
Keep the FIC’s written response on file for compliance purposes.
Remaining incorrectly registered can create unnecessary reporting and compliance obligations — including the Directive 11 RCR submission requirement.
Practical Checklist Before 30 June 2026
Confirm whether your services qualify as TCSP activities
Ensure your goAML registration is correct
Update or implement your RMCP
Properly onboard all TCSP clients
Prepare your client records and reporting history
Submit your Directive 11 RCR before 30 June 2026
If you do not provide TCSP services, address your registration position with the FIC before the reporting deadline closes.
Watch the space for more CIBA guidance and templates coming soon.
