FICA Schedule 1 for Property Transactions: Who, What, and When
The FIC Act puts FICA duties on a list of Accountable Institutions. If you are letting property, managing a portfolio, or transferring a deed in South Africa, you are on that list - and the data points the schedule asks for are not optional.
What is the FIC Act and what is Schedule 1?
The Financial Intelligence Centre Act (FIC Act) is South Africa's anti-money-laundering and counter-terror-financing law. Schedule 1 to the Act lists the businesses that count as Accountable Institutions and therefore have to do client due diligence, keep records, and report suspicious transactions. The list includes property practitioners, transfer attorneys, and several adjacent roles in the property chain.
Which property parties are accountable institutions under Schedule 1?
In practice that means residential letting agencies, property managers running portfolios on behalf of owners, sales estate agents on certain transactions, and transfer attorneys handling the conveyancing. Body corporates handling FICA on owners and tenants in a sectional title scheme often run the same flow even where they are not the named institution, because the underlying duty has been pushed down by the managing agent or the trustees.
What client due diligence is required for tenants, landlords, buyers, and sellers?
The standard data set is identity (full name, ID number, or passport for non-citizens), residential address verified by a recent utility bill or bank statement, contact details, and a confirmed source of funds where the transaction warrants it. For natural persons that is usually enough. For companies and trusts you also have to verify the legal entity itself - the registration number, the registered address, and the natural persons who ultimately benefit.
What is beneficial ownership, and how do you verify it for a trust or company?
Beneficial ownership is the natural person who ultimately owns or controls the applicant. For a company the test is usually shareholding above a defined threshold; for a trust it is the founder, the trustees, and the named beneficiaries. Verification means collecting the same identity documents for those natural persons that you would collect for an individual applicant. The point is that the regulator wants to look through the corporate veil to a real person.
When does a politically exposed person check apply to a residential lease?
A Politically Exposed Person (PEP) is someone who holds a prominent public office, or a close family member or known associate of one. The FIC Act asks Accountable Institutions to identify PEPs and apply enhanced due diligence to them. For a standard residential lease this is typically a yes-or-no declaration on the application form, with enhanced checks only triggered when the answer is yes.
What records must you keep and for how long?
The FIC Act requires Accountable Institutions to keep the identity and verification records for at least five years from the end of the business relationship. Practically that is the FICA pack itself (the documents and the structured fields), the signed declarations, and the audit trail of when each was captured. Storing that pack inside an inbox or a shared drive does not meet the standard - the records have to be retrievable on demand and protected against tampering.
How LetSignal collects and stores the FICA pack
The FICA Verification flow runs against any party with one reusable per-firm link. It captures identity, proof of address, bank account, PEP and source of funds, and a signed declaration - all the Schedule 1 data points - and produces a structured PDF report alongside an append-only audit trail. Beneficial ownership is captured for corporates and trusts. Retention is configurable to the FIC Act's minimum. For the tenant-specific walkthrough see the how to FICA a tenant guide; for the firm-level posture (Accountable Institution duties, RMCP, Directive 6) see the property practitioner FICA requirements guide.
LetSignal does not provide legal advice. Compliance with the FIC Act, POPIA, and any sector-specific regulator remains the responsibility of the Accountable Institution.