Who we work with

Dealerships have been inside the FICA net for longer than the December 2022 change suggests. Before December 2022 a motor vehicle dealer was a reporting institution under Schedule 3, with cash reporting and registration obligations. In March 2022 the Financial Intelligence Centre published administrative sanctions totalling more than R12 million against Krugerrand and motor vehicle dealers, and the named motor dealers were penalised for failures as ordinary as late registration and cash transactions reported late or not at all. In December 2022 Schedule 3 fell away and dealers moved into Schedule 1 item 20 as full accountable institutions, which added the programme, the risk assessment and the due diligence.

The difficulties are specific to the floor. Due diligence has to happen without stalling a sale. Cash and trade-ins need handling properly. Finance and insurance introduce third parties. And the group compliance officer is often one person covering several sites with the rest of a job to do.

If you are not sure whether your dealership’s programme would survive an inspection, that is what a readiness review is for.

Fine art sold at R100,000 or more brings a gallery or auction house into scope. The sector’s ordinary practices are the compliance problem: buyers who prefer discretion, agents acting for undisclosed principals, consignment arrangements, and cross-border movement of both goods and money.

A programme that ignores how the art market works will not be followed, and a programme that is not followed does not meet the Act’s requirement to implement it. The test is whether the person handling a sale on a Saturday can use it without reading it.

Estate agencies have been accountable institutions for longer than most sectors on this page, and they are among the most inspected. In its 2024/25 financial year the Financial Intelligence Centre conducted 556 compliance inspections, 165 of them of estate agents.

The more useful fact is how they are chosen. The Centre describes its inspections as risk-based, and it reported that most of those 556 were of institutions it rated medium or high risk. What your risk and compliance return said, or did not say, is part of the information it holds about you.

Supervision is shared between the Financial Intelligence Centre and the Property Practitioners Regulatory Authority, and the obligations sit alongside fidelity fund certificate requirements that already take time. The weakness that matters is the gap between the programme on file and what happens when an agent is onboarding a buyer.

Item 20 of Schedule 1 brings in dealers in high-value goods. The Centre’s own guidance illustrates the category with motor vehicles, precious metals and stones, jewellery and watches, Krugerrands and numismatic coins, fine art, aircraft and boats, antiques, luxury retail items, and livestock. That list is illustrative rather than exhaustive.

Two points are easy to miss. The threshold reaches linked payments, not only single invoices. And being an accountable institution is a matter of fact rather than registration: you do not become one when you register, you were one already.

If you are not certain whether you are in scope, that is worth establishing before someone else establishes it for you.

The practice is also built for organisations that are not accountable institutions but have grown faster than their governance: technology and professional services firms, property businesses, non-bank financial services.

The signals are familiar. The board is asking for better information. A funder or major customer wants evidence the business is well run. Or the one person who understood all of this has resigned.