FIC: Guidance on Interpretation of Credit Providers under FICA

Posted 07 April 2026 Written by Acts Online
Category FICA

Brought to you by SA Accounting Academy: The Financial Intelligence Centre (FIC) has published the final Public Compliance Communication 23A (PCC 23A) to provide definitive guidance on the interpretation of credit providers as designated under item 11 of Schedule 1 to the Financial Intelligence Centre Act, No. 38 of 2001 (FICA).

In terms of item 11 of Schedule 1 to FICA, certain credit providers are classified as accountable institutions. PCC 23A clarifies the scope and practical application of this definition, ensuring that entities providing credit understand their registration and compliance obligations. The guidance specifically addresses the criteria that bring a credit provider within the regulatory ambit of the FIC, regardless of whether they are required to register with the National Credit Regulator.

The communication further details the anti-money laundering (AML), counter-terrorist financing (CTF), and counter-proliferation financing (CPF) vulnerabilities inherent in the credit sector. It provides a non-exhaustive list of potential risk indicators that institutions must incorporate into their Risk Management and Compliance Programmes (RMCP) to detect and report suspicious activities.

Consultation and Final Publication

The final version of PCC 23A follows two rounds of public consultation. The FIC has also released a Consultation Feedback Note which addresses the comments and concerns raised by industry stakeholders during the drafting process. This feedback note provides additional context on how the FIC interprets specific scenarios involving credit extension.

Click here to download the PCC 23A: Interpretation of the scope of credit providers.

Access the Web notice regarding PCC 23A and the Consultation Feedback Note.

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

  • For yourself: No direct individual obligations; impact is channelled through the firm’s compliance framework for AML/CTF reporting and client due diligence.
  • For your business: Firms providing any form of credit must review their activities against the criteria in PCC 23A to determine if they are required to register as accountable institutions and implement a FICA-compliant RMCP.
  • For your clients: Clients seeking credit from non-bank lenders may be subject to more rigorous FICA-mandated customer due diligence (CDD) and source of funds verifications as more entities are brought into the regulatory net.

Originally published at https://accountingacademy.co.za/news/read/fic-pcc-23a-re-the-interpretation-of-credit-providers

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