The R100 000 rule
Schedule 1 item 20 (as substituted by GN 2800) lists “a person who carries on the business of dealing in high-value goods” where any transaction reaches R100 000 — replacing the old, lighter Schedule 3 “reporting institution” status that motor and Krugerrand dealers previously held. The change took effect on 19 December 2022; the FIC has campaigned at the motor trade specifically since (its October 2025 outreach to vehicle dealers is explicit about financial-crime risk in the sector), and unregistered dealers are an enforcement target.
Any payment form — not just cash
The most common misreading in the sector is that the rule is about cash. PCC 58 closes it: the R100 000 threshold counts any form of payment — cash, EFT, card or crypto — in a single operation or linked operations. A financed vehicle sale of R350 000 with no banknote in sight still makes the dealership an accountable institution. Cash does matter separately: physical currency exceeding R49 999.99 in a transaction triggers a cash threshold report to the FIC.
Buying a car? Why the dealer FICAs you
If a dealership asks for your ID and source-of-funds information on a R100 000+ purchase, it is discharging the same statutory duties as a bank: identity established and verified per its RMCP, and the transaction’s funding understood. What it may ask for follows the same law-vs-RMCP split as everywhere else in this hub — the documents guide applies to car dealers exactly as it does to banks.
The dealership’s duty stack
A qualifying dealer carries the full accountable-institution stack: registration with the FIC on goAML (within 90 days of qualifying), a documented and implemented RMCP, customer due diligence on qualifying transactions, cash threshold and suspicious transaction reporting, targeted financial sanctions screening, risk and compliance returns and staff training — the institution guide walks through each duty, and the enforcement tracker shows what non-compliance has cost others.
Frequently asked questions
Per PCC 58: a single operation or linked operations totalling R100 000 or more triggers accountable-institution status — splitting an invoice into instalments does not avoid the threshold.
Yes. PCC 58 confirms the threshold counts any payment form — cash, EFT, card, even crypto. (Cash matters separately for the R49 999.99 cash threshold reports.) The FIC’s own FAQ answers the no-cash question the same way: registration still applies.
Schedule 3 (reporting institutions) was abolished in the December 2022 rewrite. Dealers meeting the R100 000 threshold are now full accountable institutions under Schedule 1 item 20, with the complete duty stack.