FICA COMPLIANCE CHECKLIST
FICA KYC Checklist
Estate Agents
Estate agents and property practitioners are accountable institutions under FICA Schedule 1, Item 6, regulated by the PPRA. This checklist covers CDD for buyers, sellers, and entities involved in property transactions. Both buyer and seller must be verified — failure to do so is a common FIC enforcement finding.
STEP 1
Seller — Natural Person CDD
- Certified copy of SA ID or Smart ID card
- Proof of residential address (not older than 3 months)
- Proof of ownership (title deed or deeds office confirmation)
- Income tax reference number
- Source of funds declaration if purchase price exceeds R49 999 cash
STEP 2
Buyer — Natural Person CDD
- Certified copy of SA ID or Smart ID card
- Proof of residential address (not older than 3 months)
- Source of funds declaration (FICA S.21)
- Proof of bond approval or cash purchase evidence
- PEP screening confirmation
STEP 3
Legal Entity Buyer or Seller — CDD
- CIPC registration certificate
- Memorandum of Incorporation (MOI)
- Proof of registered business address
- List of directors and beneficial owners (5% threshold — FIC PCC 59)
- Certified ID documents for all beneficial owners
- Board resolution authorising the transaction signatory
STEP 4
Trust Buyer or Seller — CDD
- Trust deed (certified copy)
- Letter of authority from Master of the High Court
- Certified ID documents for all trustees
- Certified ID documents for beneficiaries (if determinable)
- Proof of address for the trust
STEP 5
Transaction Monitoring & Reporting
- File STR via goAML if transaction circumstances are suspicious (FICA S.29)
- Cash Threshold Report for cash transactions above R49 999 (FICA S.28)
- KYC records retained for 5 years after transaction (FICA S.22)
- PPRA registration confirmation on file for the agent
REGULATORY BASIS
Based on FICA 38 of 2001 (as amended) and FIC PCC 59 (August 2024). Verify at fic.gov.za.