What is a High-Value Goods Dealer? A High-Value Goods Dealer is any person (natural/juristic) that carries on the business of selling or trading singular items, known as High-Value Goods, for R100 000.00 or more. If you or your Company fall within this definition, you are considered to be an Accountable Institution and Financial Intelligence Centre Act “FICA”) obligations will therefore apply.
High-Value Goods are only tangible items that can be either movable or immovable. Non-tangible items such as shares, trading stock and commodities investments are not considered to be High-Value Goods.
If you or your company meets the definition of a High-Value Goods Dealer, you need to ensure that you are or it is FICA compliant. Failure to be FICA compliant may result in a hefty administrative sanction or fine issued by the Financial Intelligence Centre (“FIC”).
FICA compliance entails, but is not limited to, the following:
- Registration with the Financial Intelligence Centre;
- The appointment of a Compliance Officer;
- The development and implementation of a Risk Management and Compliance Programme;
- Training staff on anti-money laundering legislation;
- Conducting Customer Due Diligence processes;
- Targeted Financial Sanctions screening, and
- Reporting to the FIC.
The FICA obligations that apply to High-Value Goods Dealers are rightfenced to scenarios where the full High-Value Goods Dealer definition is met. This means that the full FICA obligations are limited to scenarios where a High-Value Good is being sold and not where items under R100 000.00 are being sold.
It is important to note that suspicious and unusual transactions reporting where necessary and Targeted Financial Sanctions (TFS) must always be completed.
Get in touch for more insights on how to navigate this complex legislation.
Dr Pete Mhlanga
Advocate of the High Court of South Africa
PhD Law (UNISA)
Harvard Professional and Executive Program
Risk Management | Regulatory Compliance | Corporate Governance Law (Wits University)
LLM (Public International Law) (UNISA)
LLB (Tax Law | Company Law) (UNISA)
