On 2 May 2017 the Financial Intelligence Centre Amendment Act 1 of 2017 (the “Amendment Act”) was published which Amendment Act has made a number of amendments to the Financial Intelligence Centre Act, 2001 (the “Act”). Certain sections of the Amendment Act became effective on 13 June 2017, certain other sections will become effective on 2 October 2017 and certain other sections will become effective on a date to be proclaimed.

The Financial Intelligence Centre has issued a draft guidance note in respect of the Amendment Act, which is available on the website www.fic.gov.za. Please note that the guidance note is 69 pages. In light of the same while we do seek to deal with some of the important amendments imposed by the Amendment Act this article should not be deemed to constitute legal advice or to be exhaustive in nature.

As of 2 October 2017, every accountable institution (referred to as an “Institution” for the purposes of this article) must develop, document, maintain and implement a Risk Management and Compliance Programme (“RMCP”), in replacement of the internal rules currently required to be formulated and implemented by Institutions. In terms of the RMCP (amongst other requirements):

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