South Africa’s FIC Directive 9 of 2024 establishes binding Travel Rule requirements for covered crypto asset service providers (CASPs). Issued by the Financial Intelligence Centre under section 43A(2) of the Financial Intelligence Centre Act 38 of 2001, it was published on November 15, 2024, and took effect on April 30, 2025. It remains in force as of November 2, 2026. Directive 9, paragraphs 1 and 9. FIC implementation guidance.
Scope of South Africa’s crypto Travel Rule
The directive applies to accountable institutions under items 12 and 22 of Schedule 1 that send, receive or intermediate crypto transfers for clients. It covers domestic and cross-border transfers. Domestic transfers have both ordering and receiving CASPs in South Africa; cross-border transfers have either provider outside the country. Its definition of a qualifying transfer captures any positive-value crypto transaction within a business relationship, bringing ongoing customer activity within scope regardless of the amount transferred. Directive 9, paragraphs 2–3.
Customer information and the R5,000 threshold
For qualifying transfers, ordering CASPs transmit prescribed originator details, including names and applicable identity or company-registration information. South African citizens and residents are identified by identity number; other individuals require a passport or foreign national identity number and date of birth. For individuals, the address requirement permits country of birth where a residential address is not readily available. Transfer information also includes relevant ledger addresses and account or reference identifiers. Beneficiary information includes the full name, relevant ledger address, and account number where used and readily available. Originator information is subject to customer due diligence. Directive 9, paragraphs 4.2–4.4.
Paragraphs 4.5–4.6 provide a reduced information set and conditional verification relief for single transactions below R5,000. Sender and recipient information must still be transmitted. FIC’s March 2026 guidance clarifies that the relief concerns once-off transfers outside a business relationship; it does not exempt small transfers by ongoing customers. Suspicion of illicit financing removes the verification relief. Recipients must verify beneficiary information for inward single transfers below R5,000 from an originator in a high-risk or other monitored jurisdiction. Directive 9, paragraphs 4.5–4.6 and 6.3. PCC 61, paragraphs 3.1–3.8.
Transmission and counterparty checks
Ordering and intermediary CASPs must send the required information before or simultaneously with the crypto transfer. Batch transmission is permitted within that timing requirement; sending information afterward is prohibited. They must also transmit and store it securely, preserving its integrity and availability and protecting it against unauthorized disclosure. Directive 9, paragraph 7.
Before sharing information, an ordering CASP must identify and assess its counterpart, including confidentiality safeguards and exposure to illicit or designated actors. Previously completed checks need not be repeated for every transfer, but require periodic and risk-triggered updates. An ordering CASP cannot execute a transfer if it cannot satisfy paragraphs 4.1–4.7. Directive 9, paragraphs 4.7–4.9.
Intermediaries, recipients and self-hosted wallets
Intermediaries must pass originator and beneficiary information through the transfer chain. Recipients have beneficiary-verification duties. Both must take reasonable measures to identify cross-border transfers missing required information and maintain risk-based procedures governing execution, suspension, return and follow-up. These controls belong in their Risk Management and Compliance Programmes. Directive 9, paragraphs 5–6.
An unhosted wallet is one whose user exclusively controls the private keys. Ordering and recipient CASPs must maintain risk-based policies for transfers involving these wallets, including obtaining further information when money-laundering, terrorist-financing or proliferation-financing risk is higher. PCC 61 clarifies that CASPs must collect originator and beneficiary information for these transfers, with wallet-holder details obtained from clients and other sources as appropriate. Directive 9, paragraphs 2.1.8 and 8. PCC 61, paragraphs 4.27–4.30.
Enforcement and subsequent guidance
Failure to comply exposes a CASP to administrative sanctions under section 45C of the FIC Act. In their April 17, 2025 joint advisory, the FIC and Financial Sector Conduct Authority stated that they could not grant categories of CASPs exemptions from Directive 9. On March 30, 2026, the FIC issued PCC 61 as authoritative implementation guidance. That publication explains the existing obligations without replacing the directive or resetting its commencement date. Directive 9, paragraph 9.2. FIC–FSCA joint advisory. PCC 61 publication notice.
