FIC Issues Draft PCC 122 on Special Purpose Vehicles

Posted 20 March 2026 Written by Acts Online
Category Regulatory Compliance

Brought to you by SA Accounting Academy: The Financial Intelligence Centre (FIC) has released Draft Public Compliance Communication 122 (Draft PCC 122) for public comment, specifically addressing the regulatory status and obligations of Special Purpose Vehicles (SPVs).

In terms of the Financial Intelligence Centre Act, No. 38 of 2001 (the FIC Act), the FIC has issued Draft PCC 122 to clarify the applicability of regulatory requirements to SPVs. Under Item 11 of Schedule 1 of the FIC Act, certain SPVs are classified as accountable institutions, requiring them to implement robust anti-money laundering, counter-terrorist financing, and counter-proliferation financing (AML, CTF, and CPF) measures.

The draft communication identifies specific threats and vulnerabilities inherent in SPV structures. It provides a framework for these entities to assess money laundering, terrorist financing, and proliferation financing (ML, TF, and PF) risks within their direct or indirect client engagements. Key areas covered in the draft include:

  • Guidance on the classification of SPVs as accountable institutions under Item 11 of Schedule 1;
  • Identification of ML, TF, and PF risk indicators relevant to SPV operations;
  • Clarification of the Risk-Based Approach (RBA) required for client due diligence; and
  • Reporting obligations and compliance monitoring frameworks.

Click here to download Draft PCC 122: On Special Purpose Vehicles.

What this means for you, your business, or your clients

  • For yourself: You must determine if any SPVs you manage or advise meet the criteria of an accountable institution under Schedule 1 to ensure you are meeting your personal professional obligations regarding the reporting of suspicious activities.
  • For your business: Your firm must review its Risk Management and Compliance Programme (RMCP) to ensure it incorporates the specific risk indicators and vulnerabilities for SPVs as outlined in Draft PCC 122.
  • For your clients: Clients utilizing SPV structures for financing or asset holding must be advised that they may now be required to register with the FIC and comply with full FICA verification and reporting protocols.

Originally published at https://accountingacademy.co.za/news/read/fic-draft-pcc-122-spvs

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