Verify the buyer before release
Identity of the natural person, or the registration, directors and beneficial owners of a company or trust buyer, verified and on file before the vehicle leaves the floor.
FIC Act Schedule 1 · Supervised by the FIC
FICA Compliance for Motor Vehicle Dealers
Dealerships moved from reporting institutions to full accountable institutions in 2022. RCC puts the RMCP, verification and reporting in place that the FIC now inspects for.
From one cash report to the full FIC Act.
Until December 2022 motor vehicle dealers were reporting institutions under Schedule 3 of the FIC Act, with a single duty to report cash above the threshold. The 2022 amendment moved them into Schedule 1 as accountable institutions, supervised directly by the Financial Intelligence Centre. A dealer now needs the same framework as a bank: registration on goAML, a responsible person, a Risk Management and Compliance Programme, customer and beneficial-owner due diligence, sanctions screening, transaction monitoring, suspicious transaction reporting, five-year records and staff training.
The money laundering risk in the sector is specific: high-value purchases in cash or from third parties, trade-ins that convert vehicles to value, vehicles bought for export, and finance structures that layer funds. RCC's FICA implementation service writes the RMCP around those risks as they arise on your floor, and trains the sales, F&I and admin staff who handle each deal.
What the Act requires of a dealer
The obligations on every deal
Know where the money comes from
Payments from a third party, split payments, foreign payments and cash above the threshold are flagged in the RMCP, with the questions to ask and the approvals required.
Screen and rate
Every buyer screened against the targeted financial sanctions lists and assessed for prominent influential person status, with a risk rating recorded on the deal file.
Report
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.
Keep records
Buyer identification and transaction records kept for five years in a form that can be retrieved for an inspection within a reasonable time.
Train the floor
Sales, finance and admin staff trained on the Act and the dealership's RMCP, with attendance records, repeated when the programme changes.
In-house finance
Dealer finance brings the National Credit Act too
A dealership that extends credit under instalment agreements, or that offers rent-to-own or in-house finance, must be registered with the National Credit Regulator before it concludes the first agreement, whatever the size of the book. RCC handles NCR credit provider registration, the affordability-assessment and agreement templates the Act requires and the returns that follow, alongside the FIC Act programme. A dealer that arranges finance for a bank or financier as an intermediary may also need an FSP licence for the credit life and short-term insurance products sold with the vehicle.
Common questions
Questions we are asked
Are all motor dealers accountable institutions?+
Schedule 1 covers a person who carries on the business of dealing in motor vehicles. New and used vehicle dealers, and dealers in motorcycles and commercial vehicles, are included. A private seller is not. Confirm your position and keep a note of the reasoning.
Who supervises motor dealers for FICA?+
The Financial Intelligence Centre supervises motor vehicle dealers directly, inspects under section 45B and may impose administrative sanctions under section 45C of up to R10 million for a natural person and R50 million for a legal person.
Do we still file cash threshold reports?+
Yes. The cash threshold report for cash of R49 999.99 or more remains, and the suspicious and unusual transaction report, terrorist property report and the duty to respond to FIC requests are added.
What does FICA implementation for a dealership cost?+
A fixed fee for the risk assessment, RMCP, templates and training, quoted after a short scoping call based on the number of sites and the deal 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
- NCR credit provider registrationApplications, statutory returns and certificate renewals.Explore ncr credit provider registration
- 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
See where your obligations actually stand.
Book a consultation: a structured review of your current obligations, gaps and exposure, with no obligation to proceed.