FIC Draft Guidance: Geolocation Registration for Accountable Institutions

Posted 19 March 2026 Written by Acts Online
Category Financial Sector

Brought to you by SA Legal Academy: The Financial Intelligence Centre (FIC) is seeking public comment on draft guidelines regarding the registration of geolocation information for the head offices, subsidiaries, and branches of accountable institutions.

In terms of the Financial Intelligence Centre Act, No. 38 of 2001, the FIC has published a draft compliance communication intended to provide guidance on the registration of geographic location data. This document must be read in conjunction with a draft directive released in December 2025 concerning registration requirements.

The draft communication clarifies that branches and subsidiaries do not constitute separate accountable institutions in addition to the head office of the institution concerned. Once finalised, this guidance will update and replace Compliance Communication 5D, which was issued in October 2023. The primary objectives of the draft include:

  • Clarifying the registration status of branches and subsidiaries within the FIC’s reporting framework;
  • Standardising the submission of geolocation data for multi-site entities; and
  • Ensuring that the head office remains the primary point of registration for the legal entity.

Stakeholders and affected parties are invited to submit their input on the draft guidelines by 27 March 2026.

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

  • For yourself: No direct individual obligations; professional impact is channelled through the firm’s regulatory reporting and registration protocols.
  • For your business: Accountable institutions must prepare to review their current registration data on the FIC system to ensure that all branch and subsidiary geolocation information is correctly linked to the head office profile.
  • For your clients: Clients classified as accountable institutions should be advised to audit their internal branch records to ensure compliance with the consolidated registration requirements once the directive is finalised.

Originally published at https://legalacademy.co.za/news/read/financial-intelligence-input-sought-on-geolocation-information-registration-guidelines

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