Attend Our Upcoming Webinars
View details
Docfox is now ncino kyc Web Banner

nCino KYC FICA FAQs

people sitting in a room strategising
What is the definition of a high-value dealer?
A HVGD is a person (both natural and juristic) that conducts business by dealing with high value goods and receives payment(s) of R100 000.00 or more. In order to fall within this category, the good(s) should be any single physical item valued at R100 000.00 or more.Kruger Rand dealers (the coin can be either gold, platinum or silver), motor vehicles, yachts, vehicle parts, and any precious metals / stones and art over the value of R100 000.00 are all examples of HVG items.

High-value goods dealers (businesses selling single physical items valued at R100,000 or more) must register with the FIC, appoint a Compliance Officer, develop a Risk Management and Compliance Programme (RMCP), conduct customer due diligence, establish beneficial ownership, screen clients against DPEP, FPEP, PIP and TFS lists, monitor transactions, keep records, submit regulatory reports, and provide employee training on FICA obligations.

Law firms must establish and verify client identity, screen clients against prominent influential persons lists (DPEP), global and local sanctions lists, and adverse media, implement a Risk Management and Compliance Programme, conduct regular client reviews, maintain secure record-keeping, and train staff on FICA obligations—nCino KYC’s end-to-end solution ensures law firms implement KYC processes correctly and pass FIC inspections.

nCino KYC offers CPD-approved FICA and AML training courses online at kycafrica.ncino.com/solutions/training-and-webinars, including FICA Awareness, KYC & Exploring UBOs, Anti-Money Laundering, Sanctions Screening, Adverse Media Screening, Understanding PEPs, Navigating Related Party Types, and Money Laundering Risks in the Legal Profession—all led by attorneys and certified anti-money laundering specialists.

Non-compliance with FICA carries serious consequences. The Financial Intelligence Centre and supervisory bodies can impose significant administrative sanctions including monetary penalties for failing to meet FICA obligations. Beyond fines and jail time, businesses risk criminal prosecution for serious violations, potential loss of business licenses or regulatory approvals, reputational damage and exposure to money laundering risks by unknowingly facilitating financial crime. Regulatory inspections may result in enforcement actions if compliance gaps are identified. Protecting your business from these risks is why nCino KYC exists. Our customers routinely pass these inspections because the platform ensures comprehensive FICA compliance through automated processes, expert guidance, and unlimited compliance advice from FICA Compliance professionals.

Section 42A(2) of FICA speaks to the appointment of Compliance Officers. A Compliance Officer must be appointed in writing through a board / management resolution or appointment letter, a named person who has sufficient independence, authority, skill, competence and seniority within the company. There is no specific qualification that has been recommended under FICA. nCino KYC have curated a number of CPD approved trainings that will assist in enhancing skill and competance within the Compliance function.

Non-compliance with FICA carries serious consequences. The Financial Intelligence Centre and supervisory bodies can impose significant administrative sanctions including monetary penalties for failing to meet FICA obligations. Beyond fines and jail time, businesses risk criminal prosecution for serious violations, potential loss of business licenses or regulatory approvals, reputational damage and exposure to money laundering risks by unknowingly facilitating financial crime. Regulatory inspections may result in enforcement actions if compliance gaps are identified. Protecting your business from these risks is why nCino KYC exists. Our customers routinely pass these inspections because the platform ensures comprehensive FICA compliance through automated processes, expert guidance, and unlimited compliance advice from FICA Compliance professionals.
Adverse Media screening is the process of monitoring news sources, regulatory announcements, and various media feeds for information about clients or potential clients that may indicate financial crime, reputational concerns, or regulatory violations. This is highly recommended by both the FIC and the FATF.
An example of adverse media screening is automatically monitoring news sources for reports about a client being investigated for fraud, involved in corruption scandals, facing regulatory sanctions, or linked to money laundering activities. nCino KYC’s platform continuously screens these sources to alert our clients of updates.
Scrutinising client information to make sure they do not appear on the Targeted Financial Sanctions list is a requirement under FICA. Accountable Institutions are to take reasonable measures to identify whether a Prospective or Existing Client, Related Party, UBO, or Representative is designated on a sanctions list.

FICA stands for the Financial Intelligence Centre Act (Act 38 of 2001). It is South African legislation that requires certain businesses, known as Accountable Institutions, to, amongst other requirements, verify who their clients are, keep records, monitor transactions, and report suspicious activity to the Financial Intelligence Centre (FIC). FICA is South Africa’s primary law for combating money laundering, terrorist financing, and proliferation financing.

FICA documents are the supporting documents that an Accountable Institution collects from a client in order to identify and verify their clients. The types of documents that are collected must be articulated in the accountable institution’s Risk Management and Compliance Programme (RMCP) and they typically include in the minimum, a proof of ID and proof of address. For a natural person (an individual), this typically includes a valid South African identity document or passport, and proof of residential address such as a utility bill or bank statement not older than three months. For a juristic entity such as a company, trust, or close corporation, FICA documents include company registration certificates, proof of business address, and identity documents for directors and beneficial owners. The exact documents required depend on the type of client and the risk profile assigned to them and the accountable institution’s risk-based approach as captured in their RMCP.

Being FICA compliant means that your business is meeting all of the legal obligations placed on it as an Accountable Institution under the Financial Intelligence Centre Act. This includes but is not limited to registering on the FIC’s GoAML portal, creating and maintaining  a documented Risk Management and Compliance Programme (RMCP), conducting customer due diligence by verifying client identity and beneficial ownership, screening clients against all required watchlists, reporting prescribed transactions to the FIC, keeping the required records for the prescribed period, and ensuring that your staff have received FICA training. A FICA compliant business must be able to demonstrate that all of these obligations have been adequately addressed if inspected by the FIC or a supervisory body. 

RMCP stands for Risk Management and Compliance Programme. It is a written, institution-specific document that every Accountable Institution under FICA is legally required to develop, implement, and maintain. The RMCP sets out how your business identifies and assesses its exposure to money laundering, terrorist financing, and proliferation financing risks, and what specific controls and processes you have put in place to manage those risks. It must cover client risk assessment, customer due diligence procedures, watchlist screening, record-keeping, reporting obligations, and staff training. A generic or copy-pasted template RMCP is not sufficient. The FIC expects your RMCP to be tailored to the specific risks of your business, client base, products, and geographic exposure. A weak or absent RMCP is one of the most common reasons Accountable Institutions fail FIC inspections.

A UBO, or Ultimate Beneficial Owner, is the natural person who ultimately owns or exercises effective control over a legal entity such as a company, trust, close corporation, or partnership. Under FICA, Accountable Institutions are required to look beyond the registered name of a juristic entity client and identify the actual human beings behind it. Often UBOs of legal entities are more than one individual and must be identified in line with the guidance set out in PCC59 for different entity types. This is because criminals frequently use complex corporate structures to obscure the true ownership of assets and launder money. Identifying UBOs can be one of the most complex elements of FICA compliance, particularly for entities with multi-layered ownership structures. nCino KYC’s platform automates the collection and management of UBO information as part of the client onboarding workflow.

A beneficial ownership declaration is a formal document in which an entity discloses who its ultimate beneficial owners are. Under amendments to the Companies Act administered by the CIPC (Companies and Intellectual Property Commission), all South African companies and close corporations are required to file and maintain a beneficial ownership register with CIPC, declaring the natural persons who own or control the entity. This is a separate obligation from what FICA places on Accountable Institutions. FICA requires Accountable Institutions to independently establish and verify beneficial ownership of their clients as part of customer due diligence, and they cannot rely solely on the CIPC register to discharge this obligation.

These below reflect the updated terminology for politically exposed persons under the FIC Act. 

A domestic politically exposed person (DPEP) is an individual who –  

(a)   holds, including in an acting position for a period exceeding six months, or has held a prominent public function in the Republic, including that of–  

(i)  the President or Deputy President;  

(ii)   a government minister or deputy minister;  

(iii)   the Premier of a province;  

(iv)   a member of the Executive Council of a province;  

(v)   an executive mayor of a municipality elected in terms of the Local Government: Municipal Structures Act, 1998 (Act No. 117 of 1998); 

(vi)   a leader of a political party registered in terms of the Electoral Commission Act, 1996 (Act No. 51 of 1996);  

(vii)   a member of a royal family or senior traditional leader as defined in the Traditional Leadership and Governance Framework Act, 2003 (Act No. 41 of 2003);  

(viii)   the head, accounting officer or chief financial officer of a national or provincial department or government component, as defined in section 1 of the Public Service Act, 1994 (Proclamation No. 103 of 1994);  

(ix)   the municipal manager of a municipality appointed in terms of section 54A of the Local Government: Municipal Systems Act, 2000 (Act No. 32 of 2000), or a chief financial officer designated in terms of section 80(2) of the Municipal Finance Management Act, 2003 (Act No. 56 of 2003);  

(x)  the chairperson of the controlling body, the chief executive officer, or a natural person who is the accounting authority, the chief financial officer or the chief investment officer of a public entity listed in Schedule 2 or 3 to the Public Finance Management Act, 1999 (Act No. 1 of 1999);  

(xi)  the chairperson of the controlling body, chief executive officer, chief financial officer or chief investment officer of a municipal entity as defined in section 1 of the Local Government: Municipal Systems Act, 2000 (Act No. 32 of 2000);  

(xii)  a constitutional court judge or any other judge as defined in section 1 of the Judges’ Remuneration and Conditions of Employment Act, 2001 (Act No. 47 of 2001);  

(xiii)  an ambassador or high commissioner or other senior representative of a foreign government based in the Republic; or  

(xiv)  an officer of the South African National Defence Force above the rank of major-general; or 

A foreign politically exposed person (FPEP) is an individual who holds, or has held, in any foreign country a prominent public function including that of a–  

(a)   Head of State or head of a country or government;  

(b)   member of a foreign royal family;  

(c)   government minister or equivalent senior politician or leader of a political party;  

(d)   senior judicial official;  

(e)   senior executive of a state owned corporation; or  

(f)   high-ranking member of the military 

A prominent influential person (PIP) is an individual who holds, or has held at any time in the preceding 12 months, the position of— 

 (a)   chairperson of the board of directors;  

(b)   chairperson of the audit committee;  

(c)   executive officer; or  

(d)   chief financial officer,  

of a company, as defined in the Companies Act, 2008 (Act No. 71 of 2008), if the company provides goods or services to an organ of state and the annual transactional value of the goods or services or both exceeds an amount determined by the Minister by notice in the Gazette 

All three categories, along with their family members and known close associates, require enhanced due diligence and senior management approval before establishing or continuing a business relationship. These individuals are considered PEPs (Politically Exposed Persons) and according to the FIC require stricter, high-risk, or enhanced monitoring due to potential money laundering risks.  

NCino KYC is known for having  the most comprehensive South African watchlist database – it includes SA prominent individuals and their family members. 

Schedule 1 of the Financial Intelligence Centre Act lists every category of business that qualifies as an Accountable Institution, meaning they are legally required to comply with FICA in full. The list has expanded considerably over the years and currently includes banks and financial institutions, attorneys and legal practitioners, estate agents and property practitioners, motor vehicle dealers, high-value goods dealers, forex traders, financial service providers and financial advisors, stock brokers, credit providers, accountants, and trust company service providers, among others. If your business falls under Schedule 1, FICA compliance is mandatory and not optional. If you are unsure whether your business qualifies as an Accountable Institution, nCino KYC’s compliance team can advise you or look up the list on the FIC’s website. 

Accountable Institutions are required to file a Cash Threshold Report (CTR) with the FIC whenever they are involved in a cash transaction, or a series of related cash transactions, that equals or exceeds R49 999.99. This applies to both the receipt and the payment of cash. The CTR must be submitted within  three business days after the transaction takes place. A Suspicious Transaction Report (STR) must also be submitted when an Accountable Institution suspects a transaction involves the proceeds of unlawful activity or terrorist financing. There is no minimum monetary threshold for an STR, and failure to report is a criminal offence. Please note that the cash threshold reporting rules have been amended and it is important to ensure your RMCP reflects the current requirements at all times.

Greylisting by the Financial Action Task Force (FATF) means that a country has been placed on FATF’s Jurisdictions Under Increased Monitoring list, commonly known as the grey list, due to strategic deficiencies in its anti-money laundering and counter-terrorism financing frameworks. South Africa was greylisted by the FATF in February 2023 following a mutual evaluation that identified significant gaps in the country’s AML/CFT system. South Africa subsequently undertook a substantial programme of legislative and regulatory reforms, including amendments to the FIC Act and the Companies Act relating to beneficial ownership, and was officially removed from the FATF grey list in October 2025. While removal from the grey list is a positive development, Accountable Institutions must continue to maintain strong FICA compliance. The regulatory standards that drove South Africa’s removal remain fully in force.

What are the best digital tools for FICA compliant onboarding?

nCino KYC provides a complete suite of digital tools for FICA compliant onboarding including: a white-label client portal for self-service onboarding, intelligent forms that pre-fill information and guide clients through complex requirements, biometric liveness and identity verification, automated document quality checking that rejects unclear or tampered documents, real-time sanctions and PEP screening, secure document storage that is POPIA compliant, related party management for business entities, and flexible API integration with existing systems.

You can automate FICA compliant onboarding using nCino KYC’s digital platform. The system allows you to send custom-branded email invitations to clients who can then self-onboard by completing smart forms, uploading documents to a secure portal, and completing facial and identity verification. The platform automatically screens clients against sanctions and DPEP lists, verifies documents in real-time, and notifies you when applications are ready for review – completing the entire process within minutes instead of days.

A comprehensive FICA compliant onboarding platform should include: secure digital client portals for document collection, biometric verification with liveness testing and Department of Home Affairs verification, smart forms that eliminate complex PDFs, automatic document quality checking, real-time sanctions and PEP screening, related party management for business onboarding, POPIA compliance for data security, API integration capabilities with existing CRM systems, and configurable workflows that match your business processes.

nCino KYC provides advanced biometric verification as part of its onboarding solution. The system uses world-class liveness testing technology to confirm the presence of a live individual and verifies their identity by cross-referencing captured facial data with the Department of Home Affairs in real-time. This seamless process can eliminate the need for manual document collection while ensuring fast and secure identity verification, all completed within minutes.

A HVGD is a person (both natural and juristic) that conducts business by dealing with high value goods and receives payment(s) of R100 000.00 or more. In order to fall within this category, the good(s) should be any single physical item valued at R100 000.00 or more.Kruger Rand dealers (the coin can be either gold, platinum or silver), motor vehicles, yachts, vehicle parts, and any precious metals / stones and art over the value of R100 000.00 are all examples of HVG items.

High-value goods dealers (businesses selling single physical items valued at R100,000 or more) must register with the FIC, appoint a Compliance Officer, develop a Risk Management and Compliance Programme (RMCP), conduct customer due diligence, establish beneficial ownership, screen clients against DPEP, FPEP, PIP and TFS lists, monitor transactions, keep records, submit regulatory reports, and provide employee training on FICA obligations.

Law firms must establish and verify client identity, screen clients against prominent influential persons lists (DPEP), global and local sanctions lists, and adverse media, implement a Risk Management and Compliance Programme, conduct regular client reviews, maintain secure record-keeping, and train staff on FICA obligations—nCino KYC’s end-to-end solution ensures law firms implement KYC processes correctly and pass FIC inspections.

nCino KYC offers CPD-approved FICA and AML training courses online at kycafrica.ncino.com/solutions/training-and-webinars, including FICA Awareness, KYC & Exploring UBOs, Anti-Money Laundering, Sanctions Screening, Adverse Media Screening, Understanding PEPs, Navigating Related Party Types, and Money Laundering Risks in the Legal Profession—all led by attorneys and certified anti-money laundering specialists.

nCino KYC’s risk rating software provides consistent, automated risk assessment based on your RMCP, triggers enhanced due diligence requirements based on risk scores, sends automated review reminders for low, medium, and high-risk clients, ensures standardised processes across your business, and creates an auditable methodology—all fully configurable to your business needs.

FICA onboarding is the process of collecting and verifying client information and documents in accordance with the Financial Intelligence Centre Act (FICA) requirements. It includes gathering client details, collecting necessary documents, completing relevant forms, and verifying that individuals or businesses are who they claim to be. This process ensures businesses comply with South African anti-money laundering and counter-terrorism financing regulations.

The time required for FICA verification depends on the method used and the complexity of the client’s circumstances. Traditional manual FICA verification processes can take several days or even weeks, involving back-and-forth communication to collect documents, manual verification checks, and waiting for various confirmations. With nCino KYC’s digital onboarding solution, FICA verification is completed within minutes. The platform uses advanced biometric liveness testing and real-time identity verification by cross-referencing with the Department of Home Affairs database. Clients can complete their profiles, upload documents to a secure portal, and undergo facial verification from any device. The system automatically conducts sanctions and PEP screening, and immediately notifies you when the application is ready for review. This rapid turnaround time improves client experience while ensuring thorough FICA compliance.

Non-compliance with FICA carries serious consequences. The Financial Intelligence Centre and supervisory bodies can impose significant administrative sanctions including monetary penalties for failing to meet FICA obligations. Beyond fines and jail time, businesses risk criminal prosecution for serious violations, potential loss of business licenses or regulatory approvals, reputational damage and exposure to money laundering risks by unknowingly facilitating financial crime. Regulatory inspections may result in enforcement actions if compliance gaps are identified. Protecting your business from these risks is why nCino KYC exists. Our customers routinely pass these inspections because the platform ensures comprehensive FICA compliance through automated processes, expert guidance, and unlimited compliance advice from FICA Compliance professionals.

Section 42A(2) of FICA speaks to the appointment of Compliance Officers. A Compliance Officer must be appointed in writing through a board / management resolution or appointment letter, a named person who has sufficient independence, authority, skill, competence and seniority within the company. There is no specific qualification that has been recommended under FICA. nCino KYC have curated a number of CPD approved trainings that will assist in enhancing skill and competance within the Compliance function.

Non-compliance with FICA carries serious consequences. The Financial Intelligence Centre and supervisory bodies can impose significant administrative sanctions including monetary penalties for failing to meet FICA obligations. Beyond fines and jail time, businesses risk criminal prosecution for serious violations, potential loss of business licenses or regulatory approvals, reputational damage and exposure to money laundering risks by unknowingly facilitating financial crime. Regulatory inspections may result in enforcement actions if compliance gaps are identified. Protecting your business from these risks is why nCino KYC exists. Our customers routinely pass these inspections because the platform ensures comprehensive FICA compliance through automated processes, expert guidance, and unlimited compliance advice from FICA Compliance professionals.
Adverse Media screening is the process of monitoring news sources, regulatory announcements, and various media feeds for information about clients or potential clients that may indicate financial crime, reputational concerns, or regulatory violations. This is highly recommended by both the FIC and the FATF.
An example of adverse media screening is automatically monitoring news sources for reports about a client being investigated for fraud, involved in corruption scandals, facing regulatory sanctions, or linked to money laundering activities. nCino KYC’s platform continuously screens these sources to alert our clients of updates.
Scrutinising client information to make sure they do not appear on the Targeted Financial Sanctions list is a requirement under FICA. Accountable Institutions are to take reasonable measures to identify whether a Prospective or Existing Client, Related Party, UBO, or Representative is designated on a sanctions list.
In line with Section 43 of the FIC Act, the Compliance Officer will ensure that all appropriate Employees (including but not limited to all client-facing employees, all employees who engage with, or process client transactions, all employees who perform a function or duty to facilitate the discharge of any part of the RMCP) undergo training around AML/CFT/CPF, the FIC Act and the appropriate content of their RMCP and its related methods, processes, and procedures to enable them to comply with the provisions of the FIC Act and RMCP which are applicable to them. Training will be provided to new Employees before they are permitted to commence their duties.

Such training will be provided at least annually, when changes to the RMCP and/or legislation demand it, or when gaps or weaknesses in employee knowledge are identified.

Redirection Notice

You are being redirected to the nCino KYC App Login. Click ‘Continue’ to proceed to the nCino KYC App or ‘Cancel’ to stay on this website”.

Cancel
Continue

Redirection Notice

You are being redirected to the nCino KYC Knowledge Base Login. Click ‘Continue’ to proceed to the nCino KYC Knowledge Base or ‘Cancel’ to stay on this website”.

Cancel
Continue