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The Financial Intelligence Centre (FIC) has published Draft Directive 11 of 2026 for public consultation, proposing that specified accountable institutions submit risk and compliance returns (RCRs) to the Centre.
The draft directive, released on 11 March 2026, is accompanied by a Consultation Note, which includes links to a draft composite RCR questionnaire and to draft sector-specific questionnaires.
Issued in terms of section 43A of the Financial Intelligence Centre Act (FICA), the directive – if finalised – will require affected institutions to submit the RCR electronically. The RCR is intended to collect entity-level information about an accountable institution’s understanding of its money laundering, terrorist financing, and proliferation financing (ML/TF/PF) risks, together with the risk-based controls and compliance measures it has implemented.
According to the consultation note, this information will enable the FIC to: better understand and assess ML/TF/PF risks at an institutional level, conduct informed risk-based supervision and monitoring, and
apply proportionate supervisory responses.
The initiative also supports South Africa’s compliance with Financial Action Task Force standards, particularly Immediate Outcomes 1, 3, and 4. Draft Directive 11 applies to accountable institutions listed in the following items of Schedule 1 to FICA:
Item 1 – Legal practitioners
Item 2 – Trust and company service providers
Item 3 – Estate agents
Item 9 – Gambling institutions
Item 11 – Credit providers (excluding banks, mutual banks, and co-operative banks acting as credit providers) Item 14 – South African Postbank Limited
Item 20 – Dealers in high-value goods
Item 21 – South African Mint Company (limited scope)
Item 22 – Crypto asset service providers (CASPs)
The directive does not apply to any bank, mutual bank, or co-operative bank that carries on the business of a credit provider under Item 11.
Questionnaires
The consultation materials include a composite RCR Questionnaire, together with sector-specific RCR questionnaires. Accountable institutions must answer all questions in the risk and compliance return questionnaire applicable based on their understanding of money laundering, terrorist financing and proliferation financing risks and its implementation of current risk-based controls in compliance with the obligations set out in the Act.
The risk and compliance return covers the specific information reporting periods and must be submitted to the Centre by the due dates, as specified in the Schedule below, as follows:
Accountable institutions falling under items 1, 2, 3, and 9 of Schedule 1 to the FIC Act, must submit the completed questionnaire for the information period of 1 April 2023 to 31 March 2026, both dates inclusive.
Accountable institutions falling under items 11 (excluding bank, mutual bank and co-operative bank credit providers), 14, 20, 21 and 22 of Schedule 1 to the FIC Act, must submit the completed questionnaire for the information period of 1 July 2023 to 31 March 2026, both dates inclusive:
Comments [Link] are invited on draft Directive 11 and the draft RCR to be submitted to the FIC by close of business on Wednesday, 25 March 2026.
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