How to submit a late RMCP on goAML

An RMCP is the written programme that section 42 of the FIC Act requires every accountable institution to keep. It sets out the money-laundering, terrorist-financing and proliferation-financing risks you face and the controls you use against them. The FIC’s drafting guidance for smaller businesses is Public Compliance Communication 53.

Directive 12 (Government Notice 7887 of 2026, Government Gazette 55337, 4 September 2026) tells specified institutions to send the FIC a copy of that documentation every year through goAML, the Centre’s registration and reporting platform. It commenced on 7 September 2026.

Check which Schedule 1 item you are registered under, then read your deadline from Annexure A of the Directive.

Schedule 1 items	Who	Annual deadline
1, 2, 9 and 11	Legal practitioners, trust and company service providers, gambling institutions, and credit providers other than banks, mutual banks and co-operative bank credit providers	9 October
3, 14, 20, 21 and 22	Estate agents, the South African Postbank, high-value goods dealers, the South African Mint Company and crypto asset service providers	31 October

Both 2026 deadlines have passed. If you are in either group and have not submitted, you are filing late. A business in scope that starts trading has 90 days from the day it commences business. If you approve an updated RMCP after your annual window, paragraph 8 of the Directive gives you ten days from that approval to upload it. The FIC’s information sheet says 90 days for updates, but the Directive itself says ten, so plan to ten days.

Paragraph 9 of Directive 12 says an institution that fails to comply is non-compliant and subject to an administrative sanction under section 42(4), read with sections 61(c) and 45C of the FIC Act. When the FIC called for RMCPs in March 2025, it kept the goAML window open after the deadline. Its notice of 12 March 2025 said: “However, institutions that file their RMCPs after today’s closing date and time, are non-compliant and such non-compliance may attract a financial sanction.” An open upload window is not an extension. Submit now, and keep a record of when the programme was approved and when you uploaded it.

Before you start, save the RMCP approved by your board, senior management or the person with the highest authority as a PDF named YYYYMMDD_RMCP.pdf, where the date is the approval date. An RMCP approved on 6 November 2026 becomes 20261106_RMCP.pdf. Confirm that your goAML user login and your organisation’s Org ID work before the day you need them.

1. Sign in to goAML at goweb.fic.gov.za/goAMLWeb_PRD/Home.
2. Click your profile at the top right and choose My Org Details.
3. In the comments field below the organisation’s address, type RMCP submission. Submit Request only becomes active once that comment is there.
4. Under Attachment, click Upload, select your PDF and click Open.
5. Click Submit Request, then Continue.

File under the correct Schedule 1 item. The same notice warned: “Failure to file the RMCP under the correct item number may result in the RMCP being rejected.” If your institution holds more than one item registration, each Org ID needs its own submission.

No. In its consultation feedback on Directive 12, the FIC said a successful upload only confirms that it received a document in the correct format and naming convention. It is not approval of the programme, and it does not change your duties under section 42. Keep your approval record and the goAML confirmation together.

Call the FIC compliance contact centre on 012 641 6000 and fix your credentials before you try again. Do not use Register as an organisation to get around a login problem. The FIC’s 12 March 2025 notice says this “will create a duplicate registration which will be rejected by the FIC.”