South Africa’s 2022 amendment to Schedule 1 of the Financial Intelligence Centre Act, 2001 brought crypto asset service providers (CASPs) within the Act’s accountable-institution framework from 19 December 2022. The change forms part of Government Notice 2800, published in Government Gazette 47596 on 29 November 2022. As checked on 2 November 2026, item 22 remains in force and continues to appear on the FIC’s sector page. Government notice; current FIC classification.
What the Schedule 1 amendment covers
The Minister of Finance issued the notice under sections 73, 75 and 76 of the FIC Act. It amended Schedules 1, 2 and 3, with the crypto-specific designation appearing in Schedule 1, item 22. That item covers a person conducting one or more specified business activities for clients. One qualifying service is enough; a provider does not need to perform all five activities to fall within the designation. Notice 2800, pages 3 and 5.
- Converting between crypto assets and fiat money.
- Exchanging different crypto assets.
- Transferring crypto assets between addresses or accounts.
- Holding or administering crypto assets, including instruments giving control over them.
- Participating in and supplying financial services connected with an issuer’s crypto asset offering or sale.
The definition concerns electronically tradable or transferable digital value used for payments or investment and treated by users as a medium of exchange, accounting unit or store of value. It excludes digital representations of fiat currency and securities defined by the Financial Markets Act, 2012. Item 22 definition.
Business scope and personal transactions
The FIC’s July 2023 Public Compliance Communication 57 interprets the designation by reference to commercial services performed, rather than the technology used. It excludes activity undertaken solely in a personal capacity. Peer-to-peer participants are not automatically CASPs; a participant must independently meet the business-activity test. The guidance identifies providers established, registered, incorporated or licensed in South Africa as subject to FIC registration when performing the listed services. PCC 57, sections 2.2–2.7.
Registration and anti-money-laundering obligations
Designation brings covered businesses within the FIC Act’s compliance system. The FIC identifies registration, client due diligence, a compliance function, staff training, risk assessment and a risk management and compliance programme among the resulting obligations. These requirements arise under the wider Act and supporting measures. FIC implementation announcement.
The framework also includes transaction monitoring, prescribed reporting and recordkeeping. The FIC’s reference guide describes electronic registration and reporting through goAML, together with controls proportionate to identified risks. It generally describes five-year retention periods, measured from the relevant relationship termination, transaction or suspicious-activity report. FIC reference guide, pages 6–12.
Supervision, enforcement and the transition
The FIC supervises item 22 activities. Providers that also fall within item 12 as financial services providers are subject to FSCA supervision; the regulators coordinate their oversight. FIC registration and authorization under the Financial Advisory and Intermediary Services Act serve different regulatory purposes. FIC sector assessment, section 3.1.4.
The original announcement described an initial 18-month supervisory approach focused on implementation, inspections and remedial sanctions, with financial penalties not envisaged for newly covered sectors. This was an enforcement approach, not a postponement of the amendment’s effective date. Transitional supervisory approach.
The parent Act provides for cautions, reprimands, remedial directions, restrictions or suspensions of specified business activities, and financial penalties. Section 45D provides an appeal mechanism for administrative sanctions. FIC Act, sections 45C–45D.
Relationship to later crypto rules
The 2022 notice established the accountable-institution designation. Subsequent measures developed its application, including Directive 9’s crypto transfer travel rule, which entered operation on 30 April 2025. Those later transfer-information requirements should be distinguished from the original Schedule amendment and its commencement date. FIC sector assessment, section 8.2.
