Registering with the FIC on goAML
How a South African accountable institution registers with the FIC on goAML, what the FIC's guidance covers, and the records to keep.
By Achekam · · 4 min read · For Accountants & audit firms in South Africa
The partners have read the FIC's guidance on trust and company service providers and reached an uncomfortable conclusion: the firm's company secretarial and trust work makes it an accountable institution. The next question comes from the most junior partner, who has been given the job. "So how do we actually register?"
The answer is shorter than many firms expect, but it has conditions. Registration is electronic, it costs nothing, and the FIC's own guidance sets out what the registration involves. What takes time is the preparation: deciding who registers, gathering the details, and keeping proper records of what was done.
Registration happens on goAML
The Financial Intelligence Centre says accountable institutions must complete and submit their registration with the FIC electronically, within the prescribed period, using its online registration and reporting system, goAML.
The same system is used later for reporting, so registration is also the firm's first encounter with the tool it will use to file any cash threshold, suspicious transaction or terrorist property reports. Treat it that way: the person who registers should understand that the profile they create is the one the firm will report from.
The FIC answers the registration question directly on its how do I register with the FIC page, which explains the electronic route through goAML and points to the guidance that governs it.
It is free, and the guidance is specific
The FIC says registration is free. Any third party offering to "register you with the FIC" for a fee is selling a service, not a requirement, and the firm can do it itself.
The FIC refers accountable institutions to Guidance Note 7 and Public Compliance Communication 5C for the registration requirements. Read both before starting. They set out what information the FIC expects and how particular situations are handled, and they will answer most of the questions that otherwise stall a registration halfway through.
A practical preparation list, to be checked against the guidance:
- The legal entity registering, exactly as it appears in its own registration documents.
- The item in the Act under which the firm is an accountable institution, with the reasoning recorded.
- The people who will hold roles on the profile, including the person responsible for compliance.
- Contact details that will still work when staff change.
- The firm's internal note of who completed the registration and when.
Paper registration only in exceptional cases
According to the FIC, a manual, paper-based registration is allowed only in exceptional circumstances. A firm should not plan on it. If something genuinely prevents electronic registration, record what it was and how the firm dealt with it, because the exception is narrow and the FIC may ask.
The more common obstacle is internal rather than technical: nobody has been given the job, or the person given it lacks the details. Settle both before anyone logs in. A registration started by a junior who then has to stop and chase partners for information tends to be abandoned half-finished, and a half-finished profile helps nobody.
Reading the amended Act
The registration duty sits in the Financial Intelligence Centre Act 38 of 2001, which the government's page describes as establishing the Financial Intelligence Centre and imposing duties on institutions and other persons who might be used for money laundering.
The Act has been amended since 2001, and the government's page itself points readers to SAFLII for the consolidated amended Act, updated to 4 January 2023, rather than the original text attached to the page. Anyone in the firm who needs to read the provisions behind registration should use that consolidated version. Reading the 2001 text alone risks missing changes that affect what the firm must do.
Whether the firm needs to register at all depends on the services it provides; that question is worked through in when an accounting firm is an accountable institution.
Keeping the records, and connecting them to client acceptance
Registration is a one-off event, but the evidence of it is needed for years. Keep the confirmation the FIC provides, the internal note of who registered and under which item, and copies of the guidance version that was followed. These are firm-level compliance records and belong with the compliance officer's files, wherever the firm keeps them, with access limited to the people who need it.
Achekam's Document Centre is organised as a folder per client and per lead, where staff upload files and folders, keep versions, tag them, archive and restore them with a reason, and search. That structure suits the client side of the firm's FIC obligations: the identity documents and due diligence evidence for each client can be filed in that client's folder and tagged consistently, so they can be found when a client is reviewed.
Registration also changes how the firm should treat client acceptance. In Achekam, a firm can record a client acceptance review after a conflict check against its own clients and contacts, and only a signed-in partner can approve it. Two limits matter for an accountable institution:
- Due diligence is a confirmation, not a check. Customer due diligence in the review is a tick-box confirmation by the preparer. Achekam runs no automatic FICA, CIPC or sanctions check.
- The evidence lives elsewhere. The acceptance review records the decision; the due diligence documents themselves should be filed in the client's folder and referred to in the review.
Once registered, the firm's reporting duties begin. They are explained in cash threshold and suspicious transaction reports.
Download Guidance Note 7 and PCC 5C, assemble the preparation list above, and decide who will complete the goAML registration. Set a date for it, and a second date for a partner to confirm the confirmation is on file.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
