FICA (Financial Intelligence Centre Act)

The Financial Intelligence Centre Act 38 of 2001 (FICA) is South Africa's anti-money-laundering and counter-terrorist financing law. Property practitioners are listed as accountable institutions in Schedule 1 of the Act, which means strict compliance obligations apply.

Core FICA obligations for property practitioners

• Verify the identity of every client (Know Your Client / KYC)
• Keep records of identification, transactions, and correspondence for at least 5 years
• Maintain a Risk Management and Compliance Programme (RMCP)
• Report suspicious or unusual transactions to the Financial Intelligence Centre
• Report cash transactions of R49 999.99 or more
• Train staff on FICA and money-laundering risks

What KYC looks like in practice

Before concluding any mandate or sale, the practitioner must verify the client's identity using their ID document or passport, proof of address (no older than 3 months), and (for legal entities) the registration documents and beneficial-owner information. Verification documents must be retained on file.

Penalties for non-compliance

FICA non-compliance can result in administrative sanctions of up to R10 million per violation, plus reputational damage and PPRA disciplinary action. The FIC has been increasingly active in inspecting accountable institutions, and property is a focus area following SA's grey-listing.

How REAPS supports FICA

REAPS captures KYC documents against every Person and Legal Entity, flags missing or expired verification before deal progression, and produces the audit trail your RMCP requires. Cash threshold reporting is automated against the FIC schema.