LBP Compliance helps South African accountable institutions meet their obligations under the FIC Act, from risk programmes and AML frameworks to FSCA and crypto regulation.
The FIC has proposed that certain accountable institutions submit a copy of their Risk Management and Compliance Programme annually. The draft directive closed for comment on 21 August 2026. The effective date will be confirmed once the directive is formally issued.
Who is affected: legal practitioners, estate agents, credit providers, high-value goods dealers, CASPs and others.
Proposed first submission: 30 September 2026, for legal practitioners, estate agents, credit providers and others (items 1, 2, 3, 9, 11).
High-value goods dealers and crypto asset service providers: proposed first submission 31 October 2026.
Is your RMCP ready to submit? Now is the time to find out.
We help South African accountable institutions across every sector meet their obligations under the FIC Act, from compliance programmes to regulatory licensing.
Risk Management and Compliance Programmes drafted, reviewed, and kept current with the latest FIC directives and guidance notes.
Customer due diligence, screening, transaction monitoring and suspicious-transaction reporting frameworks built for your sector and risk profile.
CASP licensing, FAIS, travel rule and broader regulatory work for crypto asset service providers and financial institutions.
goAML registration, Org ID setup, and support with FIC reporting obligations.
The FIC published Draft Directive 12 on 31 July 2026, proposing that legal practitioners, estate agents, credit providers, high-value goods dealers, crypto asset service providers and others submit a copy of their Risk Management and Compliance Programme to the FIC annually. The draft proposes a 30 September deadline for the first group of institutions, with the effective date to be confirmed after formal issue. Now is the right time to review whether your RMCP is current, complete, and submittable.
We take the work off your desk. The review session is free. You only pay if remediation work follows.
Send us your existing RMCP, or let us know you need one built from scratch. We assess it against section 42 requirements and the FIC guidance notes that apply to your sector.
You receive a clear summary of what is current, what is missing, and what needs updating, matched to your institution's obligations and risk profile.
The findings session is free. If remediation is needed, such as rewriting sections, building a new programme, or AML training, we quote it separately before starting.
Your flagged questions are resolved by people who know the terrain.
Brent Petersen is an admitted attorney, conveyancer, and notary public, and the director of LBP Compliance. He specialises in compliance for Accountable Institutions operating under FICA, advising institutions on the full breadth of their statutory anti-money-laundering and counter-terrorist-financing obligations. Alongside this compliance practice, he remains a practising conveyancer and notary public, advising on and executing property transfers, bonds, notarial deeds, and related instruments, giving him a rare combination of front-line legal practice and specialist regulatory expertise. His ongoing practice keeps him grounded in the realities of legal execution and client service, and complements his compliance work, particularly in matters where property, settlement, and regulated financial flows intersect.
Three decades of international commercial and regulatory operating experience across fintech, crypto and financial services, spanning South Africa and beyond.
Lizette Rudolph is an admitted attorney with seven years' post-qualification legal experience and a focus on regulatory compliance across financial services, fintech, crypto assets, and other regulated sectors. She advises clients on FICA compliance, AML/CTF/CPF frameworks, FSCA obligations, CASP compliance, and RMCP development, taking a practical, risk-based approach. Working with accountable institutions, FSPs, and established organisations, she helps strengthen compliance frameworks, reduce regulatory risk, and manage engagement with the FIC, FSCA, and other authorities, delivering solutions that meet regulatory expectations while supporting operational efficiency and growth.
Andrisa Prins is an admitted attorney and conveyancer of the High Court with over 18 years in the legal profession, specialising in property law and wills and estates. She brings a strong regulatory-compliance background spanning risk management, corporate governance, AML, FICA, POPIA, and statutory compliance, with particular depth in the property sector. Through a practical, solutions-driven approach, she helps businesses navigate a complex regulatory environment while protecting their operations and reputation.
Draft Directive 12 proposes annual RMCP submissions for a defined list of accountable institutions. The draft names legal practitioners (attorneys, advocates, notaries and conveyancers), trust and company service providers, estate agents, gambling institutions, credit providers (excluding banks, mutual banks and co-operative bank providers), high-value goods dealers, crypto asset service providers, Postbank, and the SA Mint. It does not cover all accountable institutions. The final scope will be confirmed once the directive is formally issued.
The draft proposes that legal practitioners, estate agents, credit providers and most others submit annually by 30 September, with the first submission in 2026. High-value goods dealers and crypto asset service providers would have until 31 October. New institutions would have 90 days from the date they become accountable. These are proposed dates only. The effective date will be confirmed once the directive is formally issued, and the FIC has confirmed it will not apply retrospectively.
Section 42 requires an accountable institution to have a Risk Management and Compliance Programme that identifies its money laundering, terrorist financing, and proliferation financing risks, and sets out policies, procedures, and controls to manage them. It must address customer due diligence, record keeping, reporting obligations, employee training, and internal audit. The required depth depends on your sector and risk profile. If you are unsure whether your RMCP meets the standard, that is what our RMCP Readiness Check is designed to establish.
An outdated or inadequate RMCP is a compliance gap that exposes your institution to FIC inspection findings and administrative sanctions. Draft Directive 12 would require you to submit the document to the FIC annually, and submitting an RMCP that does not meet section 42 requirements carries its own risk. An RMCP review identifies what needs updating before you are required to act. We can help you bring it current.
No. The RMCP Readiness Check and the session to discuss our findings are free, with no obligation. If you later ask us to help with broader compliance work, such as updating your RMCP, AML training, or your FICA programme, we will quote that separately and agree it with you in advance.
The Risk and Compliance Return is a self-assessment that the Financial Intelligence Centre requires from accountable institutions under section 43A of the FIC Act. Directive 11 of 2026 made it mandatory for estate agencies, with a submission deadline of 31 July 2026. If your agency holds a FIC Org ID, you were required to submit one per Org ID. The RCR obligation and timing varies by sector. Contact us if you are unsure of your status.
The RCR is submitted electronically through the FIC's goAML platform. The FIC does not accept manual submissions. Our worksheet helps you prepare and finalise your answers so you can transpose them into goAML with confidence. We don't submit on your behalf.
Yes. Completing the worksheet and downloading your answers costs nothing. You only pay if you choose to book a session with our compliance team to resolve questions you've flagged as unsure.
Failure to submit the RCR when required is non-compliance with the FIC Act and may result in administrative sanctions. If you have missed the submission window, we recommend taking advice on your position promptly.
Draft Directive 12 proposes annual submissions for a broad range of accountable institutions. Now is the right time to find out whether your programme is ready to go to the FIC. The review is free.
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