Registration and the responsible person
The business registered on goAML (section 43B), with an owner or senior manager appointed as the person responsible for compliance (section 42A).
FIC Act Schedule 1 item 20 · R100 000 transactions
FICA Compliance for High-Value Goods Dealers
Jewellers, bullion and gemstone dealers, art and luxury goods sellers who receive R100 000 or more for a transaction are accountable institutions. RCC builds the framework the FIC inspects for.
A R100 000 transaction brings the whole Act with it.
Item 20 of Schedule 1 to the Financial Intelligence Centre Act, added in December 2022, covers a person who carries on the business of dealing in high-value goods in respect of any transaction where the business receives payment in any form to the value of R100 000 or more, whether in a single operation or in linked operations. Jewellers, dealers in precious metals and stones, bullion and coin dealers, art and antique dealers, and sellers of luxury vehicles, watches and similar goods are the businesses the item reaches. The Financial Intelligence Centre supervises the sector directly.
High-value goods are attractive to launderers because they are portable, hold value, can be paid for in cash and resold anywhere. The Act responds by requiring the dealer to know who it is dealing with, to understand where the money comes from and to report what looks wrong. RCC's FICA implementation service writes the Risk Management and Compliance Programme around your goods, your customers and your payment channels, and trains the people at the counter.
What the Act requires of a dealer
The obligations once the item applies
The RMCP
A section 42 programme that assesses risk by customer, goods, payment method and geography, and sets the due diligence, approval and monitoring rules for each band, including when a transaction is treated as linked.
Customer and beneficial-owner due diligence
Identity verified for every transaction at or above R100 000 and for every business relationship; beneficial owners of company and trust customers identified and verified; source of funds on high-risk purchases.
Screening
Customers screened against the targeted financial sanctions lists and assessed for prominent influential person status, with the result on the transaction record.
Reporting
Cash threshold reports for cash of R49 999.99 or more, suspicious and unusual transaction reports within fifteen business days, and terrorist property reports, filed on goAML and logged.
Records and training
Identification and transaction records kept for five years; sales and admin staff trained on the Act and the RMCP with attendance records.
Practical design
A programme that works at the counter
The difference between a compliant dealer and a sanctioned one is usually whether the staff member taking payment knows what to do. RCC's programmes give the counter a one-page procedure: when identification is required, what to collect, when to escalate, and who files the report. We test it in compliance monitoring by sampling transactions against the RMCP, and we repeat the training whenever the thresholds or the programme change.
Common questions
Questions we are asked
Does the item apply if we never take cash?+
Yes. Item 20 is triggered by payment in any form of R100 000 or more for a transaction in high-value goods, not only by cash. Cash brings the additional cash threshold reporting duty at R49 999.99.
What counts as a linked transaction?+
Payments that appear to be linked, such as a purchase split into several payments or several items bought in one arrangement, are added together for the R100 000 trigger. The RMCP must say how the business identifies linking.
Who supervises high-value goods dealers?+
The Financial Intelligence Centre supervises item 20 accountable institutions directly, inspects under section 45B and may impose administrative sanctions under section 45C.
What does FICA implementation for a dealer cost?+
A fixed fee for the risk assessment, RMCP, counter procedures and training, quoted after a short scoping call based on the number of outlets and the transaction volume, with an optional monitoring retainer thereafter.
Related services
Services that go with this one
- FICA implementationRMCP drafting, AML and CFT measures, inspection readiness.Explore fica implementation
- Industry trainingFAIS, FICA, TCF, POPIA and conflict of interest.Explore industry training
- Compliance monitoringOngoing FAIS, FICA and NCA monitoring, plus outsourced compliance officer services.Explore compliance monitoring
- Governance frameworksInternal controls and regulatory readiness that survive scrutiny.Explore governance frameworks
See where your obligations actually stand.
Book a consultation: a structured review of your current obligations, gaps and exposure, with no obligation to proceed.