Why FICA Still Matters in 2025 Link to heading

South Africa’s grey listing by the Financial Action Task Force (FATF) in February 2023 served as a wake-up call. Businesses can no longer afford passive compliance. The Financial Intelligence Centre (FIC) and the Financial Sector Conduct Authority (FSCA) have both increased scrutiny of accountable institutions, with a strong focus on practical implementation of RMCPs (Risk Management and Compliance Programs), beneficial ownership transparency, and customer due diligence (CDD).

FICA is not just a set of rules: it is a proactive risk management framework designed to safeguard South Africa’s financial system from abuse.

1. FICA Essentials – What You Should Know Link to heading

Key obligations under the Financial Intelligence Centre Act, 38 of 2001 (as amended):

1.1 Customer Due Diligence (Section 21) Link to heading

Requires identification and verification of clients, beneficial owners, and related parties.

1.2 Ongoing Due Diligence (Sections 21C–21H) Link to heading

Institutions must monitor transactions continuously for unusual or suspicious patterns.

1.3 Risk-Based Approach (Section 42) Link to heading

Institutions must implement RMCPs aligned to client and product risk levels.

1.4 Record-Keeping (Section 22) Link to heading

All records must be retained for a minimum of five years.

1.5 Reporting Obligations (Section 29) Link to heading

Suspicious or unusual transactions must be reported via a Section 29 report.

2. Pitfalls I Often Encounter Link to heading

In reviewing RMCPs and compliance frameworks, I frequently encounter the following issues:

2.1 Template RMCPs Not Tailored Link to heading

Institutions often adopt generic templates that fail to reflect their actual operations—contravening the risk-based approach required by the FIC.

2.2 Poor Client Risk Classification Link to heading

Inadequate processes for identifying high-risk clients, especially Politically Exposed Persons (PEPs), expose institutions to undue risk.

2.3 No Review Cycle Link to heading

RMCPs are often drafted once and never reassessed, even though Section 42(2)(d) requires them to remain current.

2.4 Lack of Training Link to heading

Many employees are unaware of their duties under Section 29, leaving gaps in suspicious transaction reporting (STRs).

These shortcomings can lead to reputational harm, regulatory penalties, and business risk.

3. RMCPs: From Template to Living Document Link to heading

A robust RMCP should:

  • Be updated regularly to reflect evolving risks, clients, and products.
  • Be communicated clearly across all departments.
  • Be embedded into daily operations—not just a document kept for inspections.
  • Include documented procedures for escalation, reporting, and compliance review.

Institutions that view their RMCP as a strategic asset—not just a legal obligation—build more resilient and trustworthy businesses.

4. Final Thoughts: Culture Over Compliance Link to heading

Compliance is more than avoiding fines. It is about creating a culture of integrity, accountability, and transparency. A well-implemented FICA framework positions your business as future-ready, regulator-aligned, and investor-friendly.

5. Tools & Resources Link to heading

To streamline compliance and empower your team:

5.1 nCino KYC Africa (formerly DocFox Africa) Link to heading

Provides automated onboarding, identity verification, and FICA-ready compliance tools for South African institutions.
https://www.docfox.co.za

5.2 ACAMS – Association of Certified Anti-Money Laundering Specialists Link to heading

Offers global AML certifications, including the CAMS designation. The ACAMS South Africa Chapter provides training, events, and peer resources tailored to local challenges.
https://www.acams.org/en/chapters/south-africa-chapter

6. Call to Action Link to heading

Need help reviewing your RMCP or training your team?

I offer tailored compliance support to South African businesses looking to meet their FICA obligations with clarity and confidence.
📧 [email protected]
🌐 www.peetroodt.co.za

7. References & Further Reading Link to heading