The Financial Intelligence Centre (FIC) calls on estate agents to submit their 2026 risk and compliance returns (RCRs) so that they meet the 31 July deadline.
Estate agents, listed as accountable institutions in terms of item 3 of Schedule 1 to the Financial Intelligence Centre Act (FIC Act), are mandated to submit their 2026 RCR questionnaires electronically.
The 2026 RCR questionnaire gauges estate agents’ understanding of their money laundering, terrorist and proliferation financing (ML, TF and PF) risks. The questionnaire also evaluates accountable institutions’ implementation of risk-based controls in compliance with the obligations set out in the FIC Act.
Submission of risk and compliance return
The 2026 RCRs include information for specific reporting periods and must be submitted electronically to the FIC before Friday, 31 July 2026 at 17:00.
The person registered with the FIC as the estate agency’s compliance officer must follow the steps below to complete the 2026 RCR on behalf of the entity on the submission platform:
- Go to www.fic.gov.za
- Click on the banner on the FIC landing page which states: “File 2026 risk and compliance return today”
- Click the “Download sample questionnaires” button
- Download the questionnaire relevant to your sector and collate all the relevant RCR response information in preparation for submission on the online submission platform
- Click on “Submit here” under “Submit your 2026 risk and compliance return now”
- Log in with your FIC-issued goAML login credentials.
Refer to Public Compliance Communication 60 for further guidance on the format, manner of completion and submission of the 2026 RCR.
Suspicious and unusual transaction and activity reports
As part of their section 29 FIC Act obligations, estate agents are required to file suspicious and unusual transaction and activity reports as well as other regulatory reports to the FIC.
Reports filed in terms of section 29 of the FIC Act include:
- Suspicious and unusual transaction report (STR) – Transactions that are unusual or arouse suspicion relating to proceeds of unlawful activity or money laundering and contravention of prohibition under section 26B of the FIC Act.
- Suspicious and unusual activity report (SAR) – An activity that may be considered suspicious and unusual involving an incomplete, abandoned, aborted, attempted, interrupted or cancelled transaction.
- Terrorist financing transaction report (TFTR) – Where there is a suspicion that a transaction or series of transactions are linked to the financing of terrorism and related activities.
- Terrorist financing activity report (TFAR) – Where an activity is suspected to be linked to the financing of terrorism and related activities, but the suspected activity did not involve a transaction between two or more parties.
Refer to Guidance Note 4B for guidance on reporting of suspicious and unusual transactions and activities to FIC.
Submission of a risk management and compliance programme
Accountable institutions must also develop and maintain a risk management and compliance programme (RMCP) containing the processes they will use to combat ML, TF and PF.
The RMCP is an all-encompassing document which contains the processes and measures in place to mitigate ML, TF and PF risks. Revised Guidance Note 7A provides insight into the approval process that must be followed for the RMCP as well what the business risk assessment entails.
At minimum, the RMCP should contain three parts:
- Part 1 – Identification and assessment of the risks the accountable institution faces in terms of being abused for ML, TF and PF. Various factors such as the product offering of the entity, its client base, geographical location, and related aspects are considered. The FIC has published a sector risk assessment to assist estate agents.
- Part 2 – Mitigation and management of the risks identified in Part 1 through implementation of appropriate controls, depending on the risk appetite of the estate agent or agency.
- Part 3 – Ongoing monitoring of whether the controls implemented are adequate and effective to mitigate the risks identified in Part 1.
The accountable institution’s board of directors, senior management, or the person(s) with the highest authority must approve their RMCP. The RMCP must not be confused with the RCR, as these are separate obligations.
For compliance information and guidance, visit www.fic.gov.za. For queries, the FIC’s compliance contact centre can also be reached on +27 12 641 6000 or log an online compliance query on the FIC website.