A frequently asked question among Accountable Institutions is “What documents should I be requesting in order to adequately perform FICA for certain clients or situations”. As the Financial Intelligence Centre Amendment Act (FICAA) takes a risk-based approach, the answer is often “it depends”!
Whilst the Act does set out minimum requirements around the identification and verification of clients, there is no prescribed list of documents that should be collected for evidence and verification purposes. Help is at hand as over time there has become a generally accepted list of many FICA documents that Accountable Institutions use to evidence their client’s due diligence.
For example, to evidence proof of identity, in South Africa, the only documents recognised for this purpose is a green barcoded ID book or ID card, which could be verified through physical presentation, certification or validation against a reputable third-party source. However, what if the person lost their ID book? In this situation, you could look at taking a risk-based approach and perhaps accept a passport as a temporary measure with supporting evidence that the loss has been reported to SAPS and Home Affairs, along with a reminder to request the ID document to identify and verify as soon as the replacement is received.
Similarly, for proof of address, a wide range of documents from governmental or reputable institutions could be accepted, such as a municipality bill, bank statement or perhaps a current lease agreement.
For evidencing more unique elements such as the source of funds or gaining a level of comfort as part of an enhanced due diligence activity, would depend on the matter on hand and the information you were looking to confirm. For example, for evidencing a loan you may ask to see a copy of a signed loan agreement to check that the parties, amounts and terms align with any declaration a client has made. For an escrow matter, you can ask to see a copy of the underlying transaction contract identifying all related parties, values, terms and conditions.
We know how demanding the task of collecting and analysing FICA documents can be, and that’s why we built DocFox to simplify and automate the process. Whether your clients are individuals or juristic entities, DocFox can analyse anything on any document from anywhere in the world.
With DocFox you can seamlessly upload a range of supporting documents, your clients can either use their phone camera to take a photo of the documents or upload files via our user-friendly online portal. The system will then analyse the documents and flag any issues. Key information is also extracted from the documents and compared against third party data from home affairs, credit bureaus and CIPC. Leaving you with the simple task of making a decision whether or not to accept the documents.