Last week, the Financial Intelligence Centre (‘the FIC’) gazetted Directive 11 of 2026 (‘the Directive’) following a public consultation process. The Directive, which incorporates appropriate public feedback, came into effect on 1st April 2026 and governs the submission of the 2026 risk and compliance returns.
In essence, the Directive is a key supervisory tool that obliges specified accountable institutions to submit an electronic risk and compliance return (‘RCR’), inclusive of questionnaires, via the FIC’s online platform. To that end, the RCR assesses:
- An institution’s exposure to money laundering, terrorist financing and proliferation financing risks; and
- Implementation of current risk-based controls in compliance with their statutory obligations under the Financial Intelligence Centre Act (‘the FIC Act’).
Crucially, the Directive applies to accountable institutions listed under Schedule 1 to the FIC Act, including estate agents and legal practitioners, but excludes mutual banks and co-operative bank credit providers.
With the submission period opening on 4th May 2026, estate agents, legal practitioners, and others, are required to electronically submit their completed RCRs for the information period of 1st April 2023 to 31st March 2026, both dates inclusive, on or before 31st July 2026. All responses must be accurate, complete, and based on the institution’s actual risk assessment and control environment.
Failure to comply with the Directive renders an institution non-compliant and may result in the imposition of penalties and other administrative sanctions.
To support the effective implementation of the Directive, the FIC simultaneously published Draft Public Compliance Communication 125 of 2026 (‘Draft PCC 125’). While the Directive places a legal obligation on designated accountable institutions to submit an RCR, Draft PCC 125 provides formal guidance on the format, manner of completion, and electronic submission of RCRs – as envisaged by the Directive – to the FIC.
In its draft format, PCC 125 requires specified accountable institutions to, inter alia, utilise the goAML registration and reporting platform for submissions, to obtain an Org ID, and to carefully review all answers pre-submission as retraction/withdrawal is not permitted.
Comments on the content of Draft PCC 125 must be submitted via this link by close of business on Friday, 24th April 2026.
For further information or sound legal guidance on preparing and submitting your RCR, contact our experienced team today.
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