FIC reports: cash threshold and suspicious transactions
The reports a South African accountable institution files with the FIC on goAML: cash threshold, suspicious transaction and terrorist property.
By Achekam · · 5 min read · For Accountants & audit firms in South Africa
A client arrives at the firm's office with an envelope of banknotes to settle a year of outstanding fees. Another client, whose company the firm administers, suddenly routes large payments through a newly formed entity with no obvious business. A third is a trust whose new beneficiary shares a name with someone on a sanctions list.
For an accounting practice that is an accountable institution under the Financial Intelligence Centre Act, each of these moments may carry a reporting duty. The reports are different, the triggers are different, and the firm needs to know which is which before the situation arises, not while the client is still in reception.
Three kinds of report
The FIC sets out the reporting obligations of accountable institutions on its reporting obligations page, with references to the guidance note behind each report. In summary:
| Report | What triggers it | FIC guidance referred to |
|---|---|---|
| Cash threshold report (CTR) | Cash received or paid out exceeding R49 999.99 | Guidance Note 5C |
| Suspicious transaction report (STR) | A completed transaction that is unusual or arouses suspicion of money laundering or terrorist financing | Guidance Note 4B |
| Suspicious activity report (SAR) | The same suspicion where the transaction was not completed | Guidance Note 4B |
| Terrorist property report (TPR) | A party to a transaction matches the targeted financial sanctions list or the UN Security Council Resolution 1267 list | Guidance Note 6A |
The guidance notes set out the detail for each report, including the time limits. Read them, rather than relying on summaries, before writing the firm's procedures.
Cash threshold reports
The FIC says accountable institutions must file cash threshold reports on cash received or paid out exceeding R49 999.99. It notes that the threshold was recently increased by an amendment to the FIC Act, and refers to Guidance Note 5C. Use the amount as stated by the FIC at the time of writing, and check the guidance note for how it applies.
The threshold is mechanical: it does not depend on suspicion. A client who pays a legitimate fee in cash above the threshold still triggers the report. For most accounting practices, the simplest control is a policy on accepting cash, so that the firm knows every time cash is received and can decide whether a report is due.
Suspicious transaction and activity reports
The second category depends on judgement. The FIC says accountable institutions must report transactions that are unusual or arouse suspicion of money laundering or terrorist financing. Where the transaction was completed, the report is a suspicious transaction report. Where it was not, it is a suspicious activity report. Guidance Note 4B is the reference.
For an accounting practice, suspicion often arises from what staff see while doing ordinary work: a company secretarial instruction that makes no commercial sense, a trust distribution to an unexpected party, a structure that seems designed to hide who owns what. The firm's procedure should make it easy for any staff member to raise a concern with the person responsible for reporting, and it should say clearly who decides whether a report is filed.
Write down, for every concern raised, what was seen, who raised it, what the responsible person decided, and why. A decision not to report is still a decision that should be recorded.
Terrorist property reports
The third category turns on a match against lists. According to the FIC, a terrorist property report must be filed where a party to a transaction matches the targeted financial sanctions list or the UN Security Council Resolution 1267 list, with Guidance Note 6A as the reference.
This report depends entirely on the firm knowing who the parties to a transaction are and checking them against the lists. That makes screening a prerequisite, and it is a gap for firms that assume their systems do it. How to screen is covered in screening clients against sanctions lists.
Filing through goAML
The FIC's online registration and reporting system is goAML. Accountable institutions register on it electronically, and the same system is the route for reports. A firm that has not yet registered cannot report through it, which is one more reason to complete registration promptly once the firm concludes it is an accountable institution. Registration is explained in registering with the FIC on goAML.
Make sure more than one person in the firm can access goAML. A reporting duty does not wait for the compliance officer to return from leave.
Recording acceptance decisions in Achekam
Reports are often linked to decisions about whether to keep acting for a client. 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. That gives the firm a dated, partner-approved record of each acceptance and continuance decision.
Two limits need to be understood clearly. Customer due diligence in the review is a tick-box confirmation by the preparer, and Achekam runs no automatic FICA, CIPC or sanctions check. And Achekam does not screen prospects or clients against sanctions or PEP lists: the screening row on a prospect's profile always reads NOT RUN, and a person's PEP or sanctions status is only what staff record.
So Achekam records the decision; it does not detect the trigger. The firm's own procedures must catch cash above the threshold, suspicious activity and sanctions matches, and the acceptance review should note when any of them affected the decision.
A short reporting procedure
Every accountable institution needs one, and it can fit on a page:
- Cash. State whether the firm accepts cash and how cash received is recorded and checked against the threshold.
- Concerns. Name the person who receives concerns and how staff raise them.
- Screening. Say when parties are checked against the sanctions lists and how the result is recorded.
- Decisions. Record every decision to report or not to report, with reasons.
- Filing. Name who files on goAML and who covers in their absence.
- Guidance. List the guidance notes the procedure follows: 5C, 4B and 6A.
Write the one-page procedure this month, using the FIC's guidance notes as the source for each step, and walk every staff member who deals with clients' money or structures through it.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
