South Africa’s Financial Surveillance Department (FinSurv) has issued a draft framework to license and supervise Alternative Remittance Providers (ARPs) and is seeking public comment by 31 March 2026. The proposal delivers on the 2025 Budget Review and aligns with FATF standards (notably Recommendation 14, which deals with licensing and oversight of money or value transfers) to curb illicit flows while keeping remittances accessible.
What are ARPs and why should we regulate them?
ARPs facilitate person-to-person cross-border transfers using both formal and informal mechanisms (e.g., hawala-type networks). They meet real remittance needs but pose AML/CFT risks if unsupervised; the framework brings them under licensing, clear conditions and ongoing supervision.
The draft framework at a glance
FinSurv sets out who qualifies as an ARP, the entry criteria, what ARPs may and may not do, and what they must report using a risk-based, proportionate approach aligned to the FIC Act.
How the ARP Manual fills in the details
The ARP Manual situates ARPs within the Currency and Exchanges Act, 1933 and Exchange Control Regulations, alongside Authorised Dealers (AD) and Authorised Dealers with Limited Authority (ADLAs), and confirms ARPs serve natural persons under defined permissions. ARPs remain subject to the Financial Intelligence Centre Act, 2001 and related statutes (Prevention of Organised Crime Act, 1998 and the Protection of Constitutional Democracy against Terrorist and Related Activities Act, 2004).
Permitted channels and key limits
Permitted activity includes outward transfers via Ads and ADLAs, cross-border rand note transport in SADC via approved local transporters, value transfer via approved foreign agents, and settlement of foreign agent invoices via an AD. Key limits are: value transfers up to R5,000 per client per day and R15,000 per month; rand banknotes up to R25,000 per transporter per SADC road trip; and settlement of foreign agent invoices up to R100,000 per transaction.
Governance, prudential expectations and AML/CFT
ARPs must hold minimum unimpaired capital (kept in a segregated investment-type account), with a base of R50,000 or a percentage of projected volumes for new entrants. Core AML/CFT expectations include fit-and-proper checks, ongoing sanctions screening aligned to FIC guidance, and a board-approved Risk Management Compliance Programme (RMCP) covering risk identification, mitigation and monitoring.
Application and supervisory process
Applications must include company and ownership documents, director fit-and-proper packs, staffing and business plans, channel/partner details, funding sources, projections and a RMCP. FinSurv assesses fitness and propriety, interviews management and may grant conditional approval (typically within six months), followed by Gazette publication and a Formal Letter of Approval before go-live.
Reporting, inspections and enforcement
ARPs must file monthly transaction spreadsheets (using prescribed codes) by the seventh of the next month and share copies of FIC STR/CTR filings. They must also provide annual audited financials and risk returns, and semi-annual confirmations of AML officers, signatories and unimpaired capital. FinSurv may inspect and seize records and will impose remedial action for breaches of the Regulations, approvals, the Manual or the FIC Act.
What happens next
This is a chance to shape a proportionate regime that formalises alternative remittance channels while protecting the system. Comments on the framework may be sent to SARB-ADLA@resbank.co.za, The deadline for comments is 31 March 2026.