Cash Threshold Reports in South Africa: Section 28 of FICA, R49,999.99 and the 3-Day Rule (2026)
Short answer: Under section 28 of the Financial Intelligence Centre Act, 2001 (FICA), an accountable or reporting institution reports to the Financial Intelligence Centre (FIC) every transaction in which it pays to, or receives from, a client more than R49,999.99 in cash. "Cash" means notes, coins and travellers' cheques, not EFTs, wire transfers, bank cheques or drafts. The cash threshold report (CTR) is due as soon as possible and no later than 3 days, excluding Saturdays, Sundays and public holidays, after the institution becomes aware of the transaction, and it is filed on the FIC's goAML portal. For software that detects these transactions and prepares the reports, see goAML reporting software for South Africa.
This guide is for compliance officers and operations teams at South African banks, gambling operators, foreign exchange dealers, estate agencies, dealers, legal practices and other accountable and reporting institutions. It draws on the Act, regulation 24(4) of the Money Laundering and Terrorist Financing Control Regulations and the FIC's Guidance Note 5C. It is a practical guide, not legal advice.
When a CTR is due
The duty arises when a transaction is concluded with a client and cash above R49,999.99 is:
- paid by the institution to the client, to a person acting on the client's behalf, or to a person on whose behalf the client is acting; or
- received by the institution from the client, from a person acting on the client's behalf, or from a person on whose behalf the client is acting.
Cash paid or received in person and through a third party both count. Where a transaction is partly in cash, only the cash portion above the threshold is reported.
What counts as cash
FICA defines cash as coin and paper money of South Africa, or of another country, that is legal tender and customarily used as a medium of exchange, and travellers' cheques. It does not include bearer negotiable instruments, or transfers by bank cheque, bank draft, electronic funds transfer, wire transfer or any other written order that does not involve physical cash. A property deposit paid by EFT is therefore never a CTR.
The 3-day rule
Regulation 24(4) requires the report as soon as possible, and no later than 3 days, excluding Saturdays, Sundays and public holidays, after a person or any employee or officer has become aware of the cash transaction. Guidance Note 5C says that knowledge normally arises when the institution physically receives or pays out the cash, or sees a bank statement or deposit slip showing a cash transaction above the threshold, so it expects institutions to monitor their bank accounts daily. Where a client pays cash into an account held by another accountable institution, both institutions report.
Cash in and cash out are separate reports
CTRs are reported by direction. If a client pays in R50,000 in cash and is paid out R60,000 in cash on the same day, the institution files two reports, one for cash received and one for cash paid.
Foreign currency
Where foreign currency forms part of the cash, convert it to rand at the exchange rate at the time of the transaction. The institution chooses the rate source, so pick one, document it and use it consistently.
Structuring and suspicion
Cash below the threshold is not added up into a CTR. But splitting cash to avoid a report is exactly what section 29(1)(b)(iii) targets, and conducting transactions to avoid a reporting duty is itself an offence (section 64). Guidance Note 5C gives two examples: a casino customer who buys in five times for R20,000 over eight hours, and a client who exchanges R20,000 in cash at three branches of the same foreign exchange dealer on one day. Neither is a CTR, but both call for a decision on a suspicious transaction report. See our section 29 guide.
Filing and quality
CTRs are filed on the FIC's goAML portal, goweb.fic.gov.za, by web form, batch or system-to-system, after registration (see our FIC registration guide). Guidance Note 5C asks institutions to document their CTR process so the time limits are met, to sample their reports regularly against the FIC's requirements, and to pre-validate every report. A section 28 report may never be posted or mailed; a manual form is available only by arrangement with the FIC. An institution may continue with a reported transaction unless the FIC directs otherwise (sections 33 and 34).
Penalties
Failing to report a cash transaction is an offence under section 51, punishable by up to 15 years' imprisonment or a fine of up to R100 million (section 68). The FIC or a supervisory body may also impose administrative sanctions, including financial penalties of up to R10 million for a natural person and R50 million for a legal person (section 45C).
CTR checklist
- Capture cash separately from EFTs and cheques in every system that takes payments.
- Detect cash above R49,999.99, paid or received, including through third parties.
- Report cash received and cash paid as separate CTRs.
- Convert foreign currency at the transaction-time rate from one documented source.
- Check bank statements daily for cash deposits by clients.
- File within 3 working days, pre-validate, and sample your reports.
- Review cash just under the threshold for structuring, and consider an STR.
Frequently asked questions
What is the cash threshold reporting amount in South Africa?
Cash above R49,999.99, paid to or received from a client in a single transaction.
How long do we have to file a cash threshold report?
As soon as possible and no later than 3 days, excluding Saturdays, Sundays and public holidays, after becoming aware of the transaction (regulation 24(4)).
Is an EFT a cash threshold report?
No. EFTs, wire transfers, bank cheques and bank drafts are not cash under FICA.
Do we aggregate small cash transactions into a CTR?
No. Cash below the threshold is not aggregated into a CTR, but transactions split to avoid a report must be considered for a suspicious transaction report under section 29.
Do we report both cash in and cash out?
Yes. Cash received and cash paid are reported separately, so a client who pays in and is paid out more than R49,999.99 on the same day produces two reports.
Cash threshold reporting with Creodata
Creodata's goAML Reporting Platform detects cash paid or received above the threshold and assembles it for filing within the three-day window, so the threshold is never checked by eye in a spreadsheet. It generates schema-valid goAML XML, validates every report against the schema and business rules before submission, and keeps an immutable record of every filing. See goAML reporting software for South Africa, and FICA compliance and AML software in South Africa for the monitoring that catches structuring.
See it on your own report types — request a demo.