11 March 2025
Dear NADA Members
Members are hereby reminded that all accountable institutions supervised by the Financial Intelligence Centre (FIC) required to submit a copy of their risk management and compliance programme (RMCP) to the FIC, in terms of section 42(4)(a) of the Financial Intelligence Centre Act, 2001 (Act 38 of 2001), by close of business on Wednesday, 12 March 2025.
Please note that that the responsibility to submit the RMCP is that of the owner/s of the accountable institution being a motor vehicle dealership (High Value Goods Dealer). The RMCP must be personalised for each business’s operating model.
The FIC has noted that they will not accept standard templates which are being offered in the marketplace – this is not simply a tick box exercise but a detailed risk analysis and mitigation document.
Members need to EXACTLY follow the FIC instructions on how to save and name their submission documents and then also to upload the latest board-approved RMCP. It is important to note that any approvals obtained post the release of FIC Guidance Note 7A will have to follow the 7A rules (directors fully understand the documents, have received any training and guidance so that they can appreciate the contents of the RMCP, have not delegated responsibility or liability to any other person and can apply the document).
Your RMCP must be submitted electronically using the FIC goAML web platform https://www.fic.gov.za/wp-content/uploads/2025/03/2025.3-GN-RMCP-Letter-Request_250304.pdf
Accountable institutions are urged to peruse their goAML message board on a daily basis, and to respond to the FIC’s request in the manner outlined in the general request.
Kind regards
Gary McCraw
Director: NADA
