The FIC has issued a Directive 11 of 2026 which appears to have put a few cats amongst the pigeons! But fear not – Miltons is here to help keep you out of jail. In a nutshell:
- You may recall that a few years ago we were all required to file a return to directives 6 and 7. (Some of you did and some of you didn’t. Those who didn’t were slapped with a fine. Expect a repeat performance if you fail to comply with this one too!) This is pretty much a similar exercise.
- Given it has been a few years and as we have nothing better to do, the FIC seeks to gather some fresh blood!
- Directive 11 was published as a draft a few weeks ago, calling for public input and comment. It was published in its final format on 31 March 2026.
- It requires all accountable institutions that fall under items 1 and 3 of the appropriate Schedule to the Act, (being attorneys and realtors – meaning agencies and not individual agents) to file a reply, by 31 July 2026.
- The returns will only be available on the FIC’s website, as from 4 May 2026.
- The return will require us to provide information pertaining to all transactions for the period 1 April 2023 to 31 March 2026 (both dates inclusive).
- The returns must be completed by 17h00 on 31 July 2026. We will only have access to the returns as of 4 May 2026.
- You may want to also confirm your registration on the FIC’s goAML platform.
- A draft circular has been prepared to assist us on how to complete the returns. We await the final circular but for those of you with a burning desire to get cracking, here is a link to the draft in the meantime: 2026.3-PCC-PCC-125_On-RCR-Submission-in-terms-of-Directive-11_Issue.pdf
- Lastly, here is a link to the DRAFT return. A mere 38 pages! We do suggest you start gathering all the information so long so as not to miss the deadline: Risk-and-compliance-return-2026-Composite-questionnaire-sample.pdf. As soon as we receive a set of the final return that will be issued, we will publish this.
As such, there have NOT been any earth-shattering changes made to FICA lately, and you are not going to jail for non-compliance.
Unless I have missed something – in which case, see you there!