Many trust service providers reckon they cannot submit the beneficial ownership registers as their clients have not provided them with the required information to submit. Such an argument may get the trust service provider into trouble, as they may very well qualify as an "accountable institution" and should be registered with the Financial Intelligence Centre (FIC). Then, such trust service provider should 'know their clients' and have the required documents to verify the information. Penalties for Non-compliance Failure to comply with these requirements can result in substantial penalties, including fines (up to R10 million) and/or imprisonment for trustees. Trust service providers may incur fines for non-compliance as 'accountable institutions'. The FIC may also fine-trust service providers who do not comply with the FIC Act.