Financial Intelligence Centre enforces strict geographic reporting for accountable institutions

The Financial Intelligence Centre has moved from consultation to enforcement, requiring accountable institutions to disclose detailed information on their group structures and locations, with a deadline of 29 October 2026 for compliance.

The Financial Intelligence Centre has moved from consultation to enforcement on geographic reporting, issuing Directive 10 and requiring accountable institutions to tell the regulator where their group structures are based. The measure, published under section 43B(2) of the Financial Intelligence Centre Act, applies to institutions in Schedule 1 and covers both new registrations and profile updates already on file with the centre.

According to the directive as summarised by ACTS and the Financial Intelligence Centre’s own draft notice, firms must provide verified details for their head office, every domestic and international branch, the head office of each subsidiary and the branch network attached to those subsidiaries. The aim is to give the regulator a clearer picture of where accountable institutions operate, and how their wider group structures are arranged, for supervisory and risk-assessment purposes.

The rules took effect on 31 July 2026, the date of gazette publication. Institutions that were already registered before that date have a 90-day transition period, leaving a compliance deadline of 29 October 2026. The centre says failures to submit or update the information by then may amount to non-compliance and could trigger administrative action, including reprimands, remedial directives or financial penalties.

The shift follows an earlier draft released in December 2025 and opened for comment until 13 February 2026. Guidance published by ENS Africa during the consultation noted that the proposal was framed as a disclosure requirement rather than a fresh registration duty for every branch or subsidiary, provided those entities were not separate legal persons. Even so, the latest directive makes clear that accountable institutions will need to map their footprint carefully and keep the information current, particularly where group structures cross borders.

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