FICA verification is the customer due diligence that banks and other accountable institutions must perform under the Financial Intelligence Centre Act 38 of 2001. It is the reason a bank asks for your ID and proof of address before opening an account, and the reason it asks again years later.
The Act was substantially amended to move South Africa to a risk-based approach. That change explains something customers find puzzling: two people opening the same account can be asked for different documents, because the institution assesses risk individually rather than applying one fixed checklist.
Business Requirements at a Glance
At minimum, an accountable institution must establish and verify who you are.
- Identity — a valid South African ID or smart card, or a passport and appropriate permit for foreign nationals
- Residential address — verified through documents the institution accepts
- Income tax number, where the institution requires it
- For a business: CIPC registration documents and the entity’s details
- For a business: identification and verification of beneficial owners and those exercising control
- Source of funds or source of wealth information, where the risk assessment requires it
- Ongoing due diligence, meaning the institution keeps your information current
Registration and Legal Requirements
The risk-based approach is the key change. Institutions must have a Risk Management and Compliance Programme and apply due diligence proportionate to assessed risk. Lower-risk customers may face simplified requirements; higher-risk customers face enhanced due diligence, including questions about source of funds.
That is why requirements differ between customers and between institutions, and why you may be asked for something a friend was not asked for. It is not arbitrary, and staff cannot waive it.
Beneficial ownership is where businesses are now caught. Institutions must identify the natural persons who ultimately own or control an entity, tracing through holding companies, trusts and nominees. Companies must also keep a beneficial ownership register and file it with the CIPC. Have that information organised before you approach a bank.
Domestic and foreign prominent influential persons — people holding senior public positions, and their close associates and family — attract enhanced due diligence by law. If this applies to you, expect additional questions; it is a legal requirement rather than a judgement about you.
South Africa’s greylisting by the Financial Action Task Force resulted in intensified enforcement and stricter application across the sector. That is why verification requests increased.
Documents and Ownership Information Required
What institutions typically accept, though each sets its own list under its compliance programme.
- Valid South African ID document or smart card, or passport with a valid permit or visa
- Proof of residential address — commonly a utility bill, municipal statement, bank statement, lease agreement, retail account statement or an insurance policy document
- Where the address document is not in your name: an affidavit from the account holder together with their proof of address and ID
- SARS income tax number confirmation, where required
- For a business: CIPC registration documents, a company profile and the memorandum of incorporation
- For a business: identification of directors, members and beneficial owners
- For a trust: the trust deed and letters of authority from the Master of the High Court
- Resolutions authorising the persons who will operate the account
Tax, Licence and Compliance Requirements
Proof of address is the recurring problem. Many people do not hold documents in their own name — they live with family, rent informally, or have all utilities in a landlord’s name. Institutions accept an affidavit from the person whose name is on the document, together with that person’s own proof and ID. Ask what your institution accepts rather than assuming you cannot comply.
Ongoing due diligence means it does not end at account opening. Institutions must keep customer information current and may request updated documents periodically. Failing to respond can result in the account being restricted, which is disruptive and entirely avoidable by replying promptly.
Record keeping. Accountable institutions must keep customer and transaction records for the prescribed period, and must report cash transactions above the prescribed threshold and any suspicious or unusual transactions to the Financial Intelligence Centre. Those reports are made without notifying the customer, and that is lawful.
Non-compliance is expensive for institutions, with administrative sanctions and substantial penalties, which is why they will not compromise on documentation. Frontline staff have no discretion.
If you believe an institution is applying requirements unreasonably, raise it with the institution’s complaints process first, then the National Financial Ombud Scheme, which is free to consumers.
Process, Deadlines and Ongoing Obligations
Prepare before you go. Most account opening and verification delays are document problems, and every one of them is solvable in advance.
If you have no proof of address in your own name, obtain the affidavit and the supporting documents before your appointment rather than making a second trip.
- Take your original ID, not a copy
- Bring proof of address that the institution accepts — ask what qualifies first
- If the address document is not in your name, bring an affidavit plus the holder’s proof and ID
- For a business, bring CIPC documents, the company profile and beneficial ownership details
- Keep your beneficial ownership register current and filed with the CIPC
- Respond promptly to periodic verification requests to avoid account restrictions
- Expect enhanced questions if you hold a prominent public position
- Complain first to the institution, then to the National Financial Ombud Scheme
Frequently Asked Questions
Why do requirements differ between customers?
The Act requires a risk-based approach. Institutions apply due diligence proportionate to assessed risk, so lower-risk customers may face simplified requirements and higher-risk customers enhanced ones.
What if I have no proof of address in my name?
Institutions generally accept an affidavit from the person whose name is on the document, together with that person’s own proof of address and ID. Ask what yours accepts.
Why am I being asked to verify again?
Ongoing due diligence requires institutions to keep customer information current. Failing to respond can result in the account being restricted.
What is beneficial ownership?
The natural persons who ultimately own or control an entity. Institutions must identify them, and companies must keep a register and file it with the CIPC.
Verification requirements, accepted documents and reporting thresholds are set under the Financial Intelligence Centre Act and by each institution’s compliance programme, and they change. Confirm current requirements with your institution.