South Africa's New Cash Conveyance Report: Are You Ready?

South Africa's New Cash Conveyance Report: Are You Ready?

As of 1 July 2026, a long-dormant part of FICA has come into operation. Sections 30, 54, 55 and 70 of the Financial Intelligence Centre Act commenced, alongside amendments to the Money Laundering and Terrorist Financing Control (MLTFC) Regulations. At the centre of this change is a new reporting obligation: the Cash Conveyance Report, or CCR.

We're all familiar with the regulatory reporting landscape FICA has built over the years. Cash Threshold Reports (CTRs) for large cash transactions. Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs) for unusual client behaviour. International funds transfer reports for cross-border electronic movement of money. The CCR is different. It isn't triggered by what happens inside a financial institution. It's triggered by physically carrying cash, or certain financial instruments, across South Africa's borders.

What exactly is the Cash Conveyance Report?

Section 30 of FICA creates a reporting mechanism for cash or bearer negotiable instruments moving into or out of South Africa above a prescribed threshold. A bearer negotiable instrument is broadly defined and includes things like cheques, promissory notes and money orders that can be converted into currency on presentation.

The regulations confirm the threshold at R100,000.00 or higher, or the foreign currency equivalent. Reporting isn't automatic in every instance, it's triggered when a person who is conveying, intends to convey, or has conveyed cash or instruments above that amount is asked by an "authorised official" to report the prescribed particulars. That official is defined as a customs officer under the Customs and Excise Act, or someone delegated by the SARS Commissioner for that purpose. Once the official has the information, it must be forwarded to the Financial Intelligence Centre within two days.

Who actually has to do this, and what gets reported?

This is where the CCR breaks from the usual FICA pattern. CTRs, STRs and SARs are obligations placed on accountable institutions, your bank, your attorney, your estate agent. The CCR obligation sits with the individual physically conveying the cash. If you, your client, or a courier is moving cash or qualifying instruments above R100,000 across a border, the reporting duty falls on that person when asked, not on an institution monitoring a transaction after the fact.

Regulation 23G sets out exactly what must be reported once a demand is made. This includes the traveller's full personal details (name, date of birth, nationality, ID or travel document details, contact information, occupation and reason for travel), details of any legal entity or other natural persons on whose behalf the cash is being carried, the entry or exit point and travel details (flight, vessel or vehicle registration), and full particulars of the cash itself, including the amount, where it came from, how it was obtained, and its intended purpose.

That distinction matters enormously for compliance teams. It means client education, not just internal controls, is now part of the compliance function. Clients travelling internationally with cash, businesses moving funds physically rather than electronically, and even private individuals carrying inheritance money or sale proceeds across a border can find themselves caught by this requirement, often without realising it.

Why the urgency: the penalties are serious

Failing to comply isn't a minor administrative slip. Section 54 makes it an offence to wilfully fail to report, and section 55 creates a separate offence for the authorised official if the report isn't forwarded to the FIC correctly. The regulations also create an offence for failing to provide the information required under regulation 23G.

Section 70 adds further teeth: cash or instruments involved in a violation can be searched for, seized, and ultimately forfeited to the State, with protections built in for innocent third parties who can show they held a genuine, unknowing interest in the property.

Are we ready?

This is the real question, and for many accountable institutions and their clients, the honest answer is: not entirely, or only just. Unlike CTRs and STRs, which have been embedded in compliance processes for years, the CCR represents an entirely new category of reporting tied to physical border movement rather than financial transactions, and the reporting format itself still needs to be specified by SARS. Institutions whose clients regularly move funds internationally (forex providers, attorneys handling cross-border matters, businesses with international cash dealings) should be reviewing client communications now, updating risk and compliance programmes to reflect the R100,000 threshold, and making sure front-line staff understand this is a client-facing duty, not just another internal report to file.

With the new regime now in force, getting ahead of it, both in terms of internal awareness and client guidance, will matter far more than scrambling to respond once the first enforcement actions begin.