All institutions identified as accountable (schedule 1) and reporting (schedule 3) under the Financial Intelligence Centre Act (FIC Act or FICA) are obligated to register their details with the Financial Intelligence Centre (FIC).

According to the 2019/2020 FIC annual report, the largest proportion of registered entities are attorneys (35%), estate agents (24%), and financial advisors/intermediaries (19%).  These sectors were also key in driving the increase of registrations from 42 353 in 2019 to 44 420 in 2020.

Fic registration Increase table

The breakdown of accountable institutions highlights that money laundering and terrorist financing activities extend beyond the traditional idea of banking. As the major banking institutions strengthen their controls, criminals look to other avenues and indirect ways to access the financial system or transfer value – and this drives them towards intermediaries who are often perceived as having lesser awareness or controls in place.

 Described by the Financial Action Task Force (FATF) as ‘gatekeepers’ to the financial system these non-financial entities are vital in the identification of illicit activity as criminals seek to enjoy the proceeds of their crime with a new car or property, or perhaps transfer value into an asset as part of the layering process that can later be sold.

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