FIC Act reporting overview for financial services providers

There are currently three main regulatory reporting obligations financial services providers (FSPs), as accountable institutions, must comply with in terms of the Financial Intelligence Centre Act (FIC Act).

These regulatory reporting obligations include section 29 reports, section 28 cash threshold reports (CTRs) and section 28A terrorist property reports (TPRs).

When section 31 of the FIC Act commences, only certain FSPs that are licensed by the South African Reserve Bank, are envisioned as having to submit international funds transfer reports (IFTRs).

Under section 29 of the FIC Act, the following reports must be submitted to the FIC:

Suspicious and unusual transaction report (STR) – an FSP must file this report where it finds a transaction to be suspicious and unusual and/or where it is suspected that the transaction could be linked to the facilitation of money laundering and/or targeted financial sanctions.

Suspicious and unusual activity report (SAR) – this report must be filed where there is an activity that the FSP finds suspicious and unusual either from a money laundering facilitation, and/or targeted financial sanctions perspective. Examples of what an activity could include would be an incomplete, abandoned, aborted, attempted, interrupted or cancelled transaction.

Terrorist financing transaction report (TFTR) – must be filed where there is a suspicion that a transaction and/or series of transactions are linked to a listed terrorist and/or terrorist financing.

Terrorist financing activity report (TFAR) – must be filed where an FSP has a suspicion that an activity is linked to a listed terrorist and/or terrorist financing.

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