FICA Compliance for Motor Dealerships South Africa | Team BLEX
19 August 2026
Three FICA changes landed this year. Is your RMCP still current?
A new submission deadline, a replaced guidance note, and a filing-window correction most dealerships have never heard about — here's what changed, and what it means for you.
A new deadline just landed: Directive 12 of 2026.
On 4 September 2026, the Financial Intelligence Centre issued Directive 12 of 2026, in final form after consultation. It requires specified accountable institutions — including every Item 20 High-Value Goods Dealer, which is what your dealership is classified as — to submit a copy of their Risk Management and Compliance Programme (RMCP) directly to the Centre via goAML.
This is separate from the RCR obligation under Directive 11. It means the FIC will, for the first time, actually see your dealership's RMCP — not just take your word that one exists and is current.
DIRECTIVE 12 . 2026
RMCP submission via goAML, due annually+
Applies to all Item 20 institutions — every motor vehicle dealership.
Guidance Note 7B - and a filing deadline you might have wrong.
Guidance Note 7B took effect on 3 August 2026, "with immediate effect," replacing GN7, GN7A and the Revised GN7A in one go. Two changes matter most for dealerships: proliferation financing now has to be assessed alongside money laundering and terrorist financing risk, and any new product, service, delivery channel or technology needs a risk assessment done before it launches — not after. Simplified Due Diligence also now needs its own documented risk assessment behind it; a customer simply being lower-income or underserved is no longer, on its own, a valid reason to apply it.
Separately, a smaller but common error: many RMCPs still say a Cash Threshold Report must be filed within 2 business days. That changed in 2022 — the filing window is 3 business days, alongside the R49,999.99 threshold. If your RMCP still says 2, it's citing a rule that hasn't applied for years.
01
Directive 12
RMCP submitted to the FIC via goAML. Deadline 31 October, annually.
02
Guidance Note 7B
Effective 3 Aug 2026. New pre-launch risk assessments; tighter SDD justification.
03
CTR filing window
3 business days, not 2 — corrected since 2022, still widely misquoted.
§ 03 WHAT TEAM BLEX IS DOING ABOUT IT
This is exactly the kind of gap an audit is built to catch
Before founding Team BLEX, Lee Flattery spent 15 years in business development, working alongside 15 years as a qualified ISO auditor — building and optimising the kind of compliance programmes that have to hold up under scrutiny, not just look good on paper. That's the standard every RMCP we produce is held to: treated as a living working paper, checked against what's actually in force today, not what was in force when it was written.
Existing Team BLEX clients: your RMCPs are being reviewed against all three changes above as part of your ongoing service — no action needed on your end. If you're not yet a client and the 31 October deadline just made this newly urgent, now's a good time to find out where your dealership actually stands.
Not sure where your dealership stands?
Book a free compliance assessment and find out before the 31 October deadline.
Team BLEX prepares compliance documentation and processes on behalf of client dealerships. Each dealership remains the Accountable Institution under the Financial Intelligence Centre Act 38 of 2001 and retains full statutory responsibility for its own compliance.
SINGLE POINT SOLUTION
To motor dealers for compliance to the Financial Intelligence Centre Act 38 of 2001.
THE FINANCIAL INTELLIGENCE
Plays a vital role in combating money laundering, terrorist financing, and other financial crimes in South Africa.
