FICA Compliance Checklist for Property Rental Businesses

Administrative FICA Compliance Checklist:

• You must have a unique RMCP Policy in place – a template policy is NOT sufficient!
• If you do rentals in your business (irrespective of the volume – and this includes both procurement and/or management), your Policy must separate these departments and each department must have their own risk rating forms and their own questionnaires
• You must use the new client questionnaires
• You must have a proper risk rating against which you test:
  • the client’s status (landlord before listing and tenant before occupation)
  • the transaction (thereafter)
• You need to have management control checklists
• You need to also have a set of guidelines in place of what ADDITIONAL and ENHANCED due diligence must be done, and when these should be done
• You must have a Risk & Compliance Officer appointed
• You must register your business on the goAML as an organisation and if you have branches, each of the branches must also be registered under the organisation
• You were obliged to file the Directive 6 Self-Assessment (first by end of May 2023 and then the extended deadline which was 13 October 2023)
• You must comply with the Directive 8 proficiency test and integrity check and screen all the agents and employees on the TFS lists
• You must arrange formal training for all the agents and employees
• You must report cash deposits in excess of R49,999,99

Are you non-compliant and in need of help?

We have you covered with our on-demand FICA-focussed training facilitated by renowned Specialist Regulatory Compliance Consultant, Melanie Coetzee . . .

Practical (Implementation) FICA Compliance Checklist:

• Your RMCP Policy must be approved by management
• Your tests must be marked and a summary of the results must be discussed by management
• Additional training must be arranged for the agents and employees that did poorly in the test
• You must sign up with one of the KYC software applications (Lexis Nexis, DocFox, Beeswax etc) as you must screen all clients:
  • against the TFS lists;
  • against the PIP and PEP lists;
  • for other associations or adverse media;
  • ID verification (if South African)
• The RCM must be trained in order to guide the agents on what additional or enhanced measures must be taken when there is medium or high risk identified
• The RCM must act as conduit between the agents and management where management’s approval is required in order to proceed
• Clients must be risk-rated before listings are published or lease agreements are signed
• Transactions must then be risk rated before registration
• Management must sign the management control checklists
• The RCM must report matters
• The MLRO must be registered on the goAML platform

Need guidance on any of the above? Watch our on-demand recordings of FICA workshops facilitated by renowned Specialist Regulatory Compliance Consultant, Melanie Coetzee . . .

If any of the above are missing you may have problems with an FIC Audit

Need help getting your FICA Compliance corrected? We have a solution for you!

A series of four practical FICA workshops facilitated by one of the premier Specialist Regulatory Compliance Consultant, Melanie Coetzee! This is a superb opportunity to get all your rental-related FICA Compliance questions answered by a top FICA expert!

Click here to find out more about Melanie Coetzee

We also have a recording available of a previous 1 hour webinar facilitated by Melanie, which is more of an overview of, or an introduction to FICA. It’s ideal as training for new staff, or as a refresher for existing staff . . .