FICA Compliance for Estate Agents in South Africa: goAML Registration, RMCP and FIC Reporting (2026)
What South African estate agents must do under FICA: register with the FIC on goAML within 90 days, keep an RMCP, report cash above R49,999.99 within 3 days and suspicious transactions within 15, screen for sanctions and PEPs, and keep records for five years.
Short answer: Estate agents are accountable institutions under the Financial Intelligence Centre Act, 2001 (FICA), and the Financial Intelligence Centre (FIC) supervises them directly. An agency must register with the FIC on goAML within 90 days of starting business, run a documented Risk Management and Compliance Programme (RMCP), identify and verify clients, screen them for sanctions and politically exposed persons, report cash above R49,999.99 within 3 days and suspicious transactions within 15 days, and keep records for at least five years.
This guide is for principals, compliance officers and agents at South African estate agencies. It is a practical guide, not legal advice: check the Act, the Money Laundering and Terrorist Financing Control Regulations and the FIC's guidance.
Why estate agents are covered, and who supervises them
Estate agents appear in Schedule 1 of FICA, the list of accountable institutions. Schedule 2 names supervisory bodies for banks, insurers, money transfer providers and investment firms, but none for estate agents, so the FIC supervises them itself (section 4(g)). An agency's first point of contact on FICA is therefore the FIC, not a sector regulator.
The duties, in order
| Duty | What it means for an agency | Source |
|---|---|---|
| Register | Register with the FIC on its goAML portal, free of charge, within 90 days of starting business; an agency with branches may need to register them separately | Section 43B; goAML portal; Guidance Note 4B |
| RMCP | Document, maintain and implement a Risk Management and Compliance Programme covering how you identify, assess and manage your money-laundering risk | Section 42 |
| Client due diligence | Identify and verify clients, understand the business relationship, verify the beneficial owners of companies, trusts and partnerships, and keep due diligence up to date | Sections 21 to 21E |
| PEPs | Treat foreign and domestic politically exposed persons, prominent influential persons and their families and close associates as the Act requires | Sections 21F to 21H |
| Cash threshold reports | Report cash above R49,999.99 received from, or paid to, a client within 3 days, excluding weekends and public holidays | Section 28; regulation 24(4) |
| Suspicious and unusual transaction reports | Report as soon as possible, and no later than 15 days after becoming aware of the facts, excluding weekends and public holidays | Section 29; regulation 24(3) |
| Terrorist property reports | Report a client or party who matches the targeted financial sanctions list or the UN 1267 list | Section 28A |
| Records | Keep records for at least five years | Section 23 |
Cash in property deals
Most property payments move by EFT, which is not cash under FICA and is never a cash threshold report. The CTR duty bites when an agency itself receives or pays out notes, coins or travellers' cheques above R49,999.99, for example a cash deposit. Cash below the threshold is not added up into a CTR, but a series of cash payments split to avoid a report must be considered for a suspicious transaction report under section 29(1)(b)(iii).
Suspicion in property transactions
The 15 days for a suspicious transaction report run from when the facts that give rise to the suspicion came to light, which the FIC points out is usually before the suspicion is fully formed. For an agency, the record that matters is the date an agent first noticed something, such as an unexplained third party paying the deposit, a buyer indifferent to price, or funds from an unexpected jurisdiction, and what happened next.
Filing on goAML
All four reporting streams, including cash threshold, suspicious and terrorist property reports, are filed on the FIC's goAML portal, goweb.fic.gov.za. A small agency will usually use the online form; the FIC also accepts batch and system-to-system reporting for high volumes. The FIC asks reporters to pre-validate reports, attach supporting documents, monitor each report's status and keep a copy. Our South Africa FIC goAML reporting guide covers the mechanics.
A compliance checklist for agencies
- Registered with the FIC on goAML within 90 days of starting business, with branches registered where required
- A written RMCP that matches how the agency actually works
- Client identification and verification for every buyer and seller, including beneficial owners
- PEP and sanctions screening, with terrorist property reports on a match
- Cash above R49,999.99 reported within 3 days
- Suspicions recorded from the date the facts came to light, and reported within 15 days
- Reports pre-validated, tracked and copied
- Records kept for at least five years
How software helps an agency
An agency does not need a bank's monitoring system, but it does need screening against current sanctions lists and PEP data, a risk rating that follows its RMCP, a case file for each concern, and goAML reports the FIC accepts. Creodata's FICA compliance and AML software in South Africa covers screening, customer risk rating, case management and reporting, and the Starter tier covers screening, risk rating and case basics for smaller institutions. For choosing a system, see our FICA compliance software buyer's guide.
Frequently asked questions
Do estate agents need to register with the FIC?
Yes. Estate agents are accountable institutions under Schedule 1 of FICA and must register with the FIC on its goAML portal within 90 days of starting business. Registration is free.
Who supervises estate agents for FICA?
The FIC. Schedule 2 of FICA names no other supervisory body for estate agents, so the FIC supervises them itself under section 4(g).
Do estate agents need an RMCP?
Yes. Every accountable institution must document, maintain and implement a Risk Management and Compliance Programme under section 42 of FICA.
Is an EFT deposit a cash threshold report?
No. EFTs, wire transfers, bank cheques and drafts are not cash under FICA. A cash threshold report is due only for notes, coins or travellers' cheques above R49,999.99 received from or paid to a client.
See how Creodata's FICA compliance and AML software supports an agency's RMCP: book a demo.
