FIC issues Directive 10: Mandatory geographic reporting requirements
The Financial Intelligence Centre (FIC) has issued Directive 10 of 2026 (published in Government Gazette No. 55097 on 31 July 2026), establishing mandatory geographic disclosure requirements for designated Accountable Institutions (AI’s) operating across multiple offices, branches, or subsidiary structures. Issued under Section 43A(1) of the Financial Intelligence Centre Act (FIC Act), this directive requires affected institutions to report their complete operational footprint directly on the FIC portal upon registration and maintain accurate geographic records.
Applicable AI’s
Directive 10 applies to multi-location entities listed under the following Schedule 1 items of the FIC Act:
Item 1: Legal Practitioners / Attorneys
Item 2: Trust and Company Service Providers (TCSPs)
Item 3: Estate Agents
Item 9: Gambling Institutions / Casinos
Item 11: Credit Providers (excluding registered banks, mutual banks, and co-operative bank credit providers)
Item 14: South African Postbank Limited
Item 20: High-Value Goods Dealers
Item 21: South African Mint Company
Item 22: Crypto Asset Service Providers (CASPs)
(Note: Schedule 1 Items 8 and 12 are excluded from Directive 10.)
What counts as a branch?
The FIC's consultation feedback clarified what qualifies as a branch to prevent excessive reporting:
Included: Physical premises where Schedule 1 products or services are provided directly, in person, to clients (including third-party agent branches used for in-person client engagements).
Excluded: Back-office processing hubs, tech offices, data centres, ATMs, remote-working setups, and purely virtual platforms.
Virtual businesses: Platforms without physical client branches must disclose their Head Office location.
Required geographic information
For every head office, domestic branch, foreign branch, subsidiary head office, and subsidiary branch, affected entities must disclose:
Entity details: Name of the office/branch, registration number, and licence number (where applicable).
Address: Physical business address for every location inside or outside South Africa.
Compliance personnel: First name, surname, and direct contact particulars of the person carrying out the Section 42A(2)(b) compliance function for that specific location.
Deadlines and submission timelines
Existing registrations: AI’s already registered on the directive's commencement date (31 July 2026) must update their geographic profile on the FIC portal within 90 days (by 29 October 2026)
Ongoing changes: Any opening, relocation, or structural change to a branch or subsidiary must be updated on the portal within 90 days of the change occurring.
Consequences of non-compliance
Failure to submit or update geographic records constitutes administrative non-compliance under Section 43B(2) and exposes the institution to administrative sanctions and monetary penalties under Sections 45C and 61A of the FIC Act.
