We all know that the Financial Intelligence Centre has been working furiously trying to pass the necessary changes to the Financial Intelligence Centre Act in a desperate attempt to try and persuade the Financial Action Task Force that South Africa should not be grey listed.  The latest attempt is the amendment of Schedule 1 to the FIC Act which includes as accountable institutions anyone dealing in “high-value goods”.  Sounds innocuous until you think about it.  Although the draft Public Compliance Communication 119 (PCC 119) (interestingly, although the amendment is already law, PCC 119 is still a draft and if you want to comment on it you need to submit comments to the FIC by 20 January 2023) about these amendments suggests that the usual culprits comprise “high-value goods” PCC 119 does point out that this concept is not defined in the FIC Act.  While art, antiques, vehicles, jewellery, boats and yachts are obviously high value goods, PCC 119 begs the question about more ordinary goods it appears that the FIC will consider any item having a value of R100 000 or more (including things like furniture, computer equipment, farming and construction equipment and livestock) to be high-value goods.  This means that any person (natural or a company) which trades in items any of which has a value exceeding R100 000 must register with the FIC and comply with the FIC Act including doing all the risk assessment and customer due diligence required of accountable institutions.  To say that this will have a massive practical compliance impact on most retail businesses trading in goods any of which has a value of R100 000 or more and their customers is a gross understatement.  To make matters more complicated, it appears that the FIC considers a firm to be an accountable institution only in circumstances where it trades in high-value goods and where it actually is buying or selling a high-value good.  According to PCC 119, for example a jeweller doesn’t have to comply with the FIC Act except where they are selling items having a value of R100 000 or more.  Considering the penalties for non-compliance with the FIC Act are high and that enforcement is a key focus area for the FIC, the amendment to the FIC Act which became effective on 19 December 2022 is likely to be a shock to many South African businesses.