A–C
- Accountable institution
- A business listed in Schedule 1 to the FIC Act — banks, legal practitioners, estate agents, credit providers, crypto asset service providers, high-value goods dealers and others. Only accountable institutions carry FICA’s customer due diligence duties. Who must comply →
- Beneficial owner
- A natural person who, directly or indirectly, ultimately owns a client or exercises effective control of it (FIC Act s 1). Always a human being — companies and trusts are looked through, never beneficial owners themselves. The cascade →
- Business relationship
- An ongoing arrangement between a client and an accountable institution — a bank account, a mandate, an attorney-client engagement. One of the two triggers for customer due diligence.
- Customer due diligence (CDD)
- The FIC Act’s know-your-client duties: establishing and verifying identity (s 21), understanding the relationship’s nature, purpose and source of funds (s 21A), beneficial ownership (s 21B) and keeping information current (ss 21C–21D).
- Controlling ownership interest
- The step-1 test for beneficial ownership. Undefined in the Act — no percentage appears in the statute. The FIC strongly recommends treating 5%+ as a controlling ownership interest (PCC 59 para 2.18). 25% or 5%? →
- Cash threshold report (CTR)
- A report to the FIC of a cash transaction of R49 999.99 or more (s 28; GN R2638 of 2022), filed on goAML. "Cash" means physical currency — not EFTs or card payments.
D–G
- Enhanced due diligence (EDD)
- Deeper-than-standard due diligence for higher-risk clients: more information, stronger corroboration, closer scrutiny. Mandatory for foreign politically exposed persons; risk-triggered for domestic ones.
- Establish and verify
- The Act’s two verbs (s 21(1)). Establishing means collecting identity information — names, date of birth, ID number. Verifying means corroborating it against a reliable, independent source. What verification means →
- Financial Intelligence Centre (FIC)
- The government intelligence unit the Act creates. It receives reports and develops financial intelligence for investigators. It does not prosecute, does not freeze ordinary accounts, and never demands fees from the public.
- FICA
- The Financial Intelligence Centre Act 38 of 2001, South Africa’s anti-money-laundering statute — and, colloquially, the verb for being identified under it ("being FICA’d").
- goAML
- The FIC’s online registration and reporting platform. Accountable institutions register on it (s 43B), receive an Org ID, and file CTRs, STRs and risk and compliance returns through it.
H–P
- High-value goods dealer (HVGD)
- A dealer who receives R100 000 or more for an item — in any payment form, single or linked operations (Schedule 1 item 20; PCC 58). How car dealers, jewellers and art dealers became accountable institutions in December 2022. The R100 000 rule →
- Ongoing due diligence (ODD)
- The duty to keep client information current and to monitor transactions against the expected profile (ss 21C–21D). The legal reason institutions ask established clients for documents again.
- Politically exposed person (PEP / FPEP / DPEP / PIP)
- Persons in prominent public positions, whose profiles raise risk. Foreign PEPs always trigger enhanced due diligence; domestic prominent influential persons do when the relationship is higher-risk (ss 21F–21H; Schedules 3A–3C).
- Public Compliance Communication (PCC)
- The FIC’s topic-specific guidance instruments — e.g. PCC 59 (beneficial ownership), PCC 22A (POPIA), PCC 53 (RMCP), PCC 12A (outsourcing), PCC 58 (high-value goods). Authoritative guidance, not statute. The source library →
Q–Z
- Risk Management and Compliance Programme (RMCP)
- The documented, board-approved rulebook every accountable institution must adopt and implement (s 42). Since 2 October 2017 the RMCP — not the regulations — determines which documents an institution requires. Why there is no document list →
- Reasonable steps
- The verification standard for beneficial owners (s 21B(2)(b)) — measures commensurate with risk, deliberately lighter than the "establish and verify" standard for the client itself. Self-declaration alone is not enough (PCC 59 para 6.3).
- Reliable, independent source
- What verification must compare claimed identity against: documents or electronic data issued or created by reliable and independent third parties (GN 7A para 83) — IDs, passports, and government databases themselves. Client-generated material never qualifies.
- Risk and compliance return (RCR)
- A periodic questionnaire accountable institutions file with the FIC when directed (Directives 6 and 7 of 2023; Directive 11 cycle from 1 April 2026). Non-submission is the most common cause of FIC sanctions.
- Single transaction
- A once-off transaction of R5 000 or more with a client outside a business relationship (s 1; reg 1A) — the second trigger for customer due diligence. Below R5 000 full CDD is not required, but anonymous clients are still prohibited (s 20A).
- Suspicious transaction report (STR)
- A section 29 report to the FIC of a suspicious or unusual transaction, whatever the amount. The reporter’s identity is protected, and tipping off the client is an offence.
- Targeted financial sanctions (TFS)
- The UN Security Council sanctions lists institutions must screen clients against (s 28A), freezing property and reporting on a match. Screening failures featured centrally in recent attorney-firm penalties.
- Trust and company service provider (TCSP)
- A business providing company-formation, company-secretarial or trust services — an accountable institution category since December 2022 that swept in many accounting practices.