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The Government of South Africa released a consultation note regarding draft Directive 12 under the Financial Intelligence Centre Act (FICA). The directive addresses the submission of risk management and compliance programmes by regulated entities operating within South Africa's financial services sector. Directive 12 establishes requirements for financial institutions and other FICA-regulated entities to develop, implement, and submit comprehensive risk management and compliance programmes. These programmes are designed to strengthen the regulatory framework governing anti-money laundering and counter-terrorism financing (AML/CTF) compliance across South Africa's financial system. The directive sets out the standards and procedures that entities must follow when establishing internal controls, governance structures, and compliance mechanisms to identify, assess, and mitigate financial crime risks. The consultation note invites stakeholders—including banks, money transmitters, casino operators, and other regulated financial service providers—to submit comments and feedback on the proposed directive. This engagement process allows industry participants to raise concerns, suggest amendments, and provide input on the practical implementation of the requirements before the directive is finalised. The consultation represents a key step in South Africa's ongoing efforts to strengthen its AML/CTF regime and ensure compliance with international standards established by the Financial Action Task Force (FATF). Stakeholders wishing to participate in the consultation should review the draft directive and submit their responses in accordance with the timelines and procedures outlined in the consultation note. The final directive will incorporate feedback received during this consultation period before coming into effect. REFERENCES: South African Government. "Financial Intelligence Centre Act: Consultation note to draft Directive 12 on the submission of risk management and compliance programmes." Government Gazette. Available at: https://www.gov.za/

On July 31, 2026, South Africa’s Financial Intelligence Centre (FIC) published a consultation on draft Directive 12, which would require specified accountable institutions to submit copies of their risk management and compliance programme (RMCP) documentation to the FIC annually. For financial services and payments firms, the proposal is relevant to non-bank credit providers and cryptoasset service providers. With the exception of the South African Postbank, banks as credit providers are expressly excluded. Under the proposal, affected institutions would have to submit a copy of the documentation describing their RMCP through the FIC’s registration and reporting platform . The submissions would allow the FIC to monitor institutions’ overall compliance with their obligations under the FIC Act. Newly established affected institutions would have to submit their RMCP documentation within 90 days of commencing business. Institutions that update and approve their RMCP after the applicable annual deadline would have to submit the revised documentation within ten business days of approval. The South African Postbank and cryptoasset service providers would have an initial deadline of October 31, 2026. The proposal does not create the underlying obligation to develop and implement an RMCP, which already exists under the Financial Intelligence Centre Act. Instead, it would introduce a recurring submission requirement intended to help the FIC assess compliance with anti-money laundering and counter-terrorist financing obligations. Failure to comply with the final Directive could result in administrative sanctions. Comments are due by August 21, 2026 and can be submitted via the online consultation form .

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South Africa's Financial Intelligence Centre Publishes Consultation Note on Draft Directive 12 for Risk Management Programmes

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South Africa's Financial Intelligence Centre Publishes Consultation on Draft Directive 12 for Risk Management Programmes