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Check source-of-funds documents before they go into the FICA file

When a client explains where the money for a transaction comes from, the proof is usually a bank statement or payslip in PDF. Check it for signs of editing the eye cannot see before you rely on it.

Source of funds rests on documents clients supply

Property transfers, trust deposits and large cash contributions all raise the same question: where does the money come from? Clients answer with statements, payslips and letters, and the compliance officer or conveyancing secretary files them. The FICA file shows that documents were collected. It does not show whether anyone checked that they were unaltered.

A file check adds a documented step between receiving the proof and accepting it. If a document shows signs of editing, you ask for a fresh one or escalate under your risk management and compliance programme, before the transaction goes any further.

A property transfer, two ways

Filed, not checked

A purchaser pays a large deposit from what they say are savings, and sends six months of statements to show it. The conveyancer’s office files them with the ID copy and moves on to the transfer. Months later a query arrives, and the only thing on file is a statement nobody examined.

Checked when it arrives

The compliance officer uploads the statements on receipt. One shows signs of editing. The office asks the client for statements downloaded directly from the bank, records the result in the FICA file and considers, under its own programme, whether a report to the FIC is needed. The exported report shows what was checked and when.

What goes into the FICA file

  • A verdict you can record

    Each document gets a plain result: signs of editing found, no signs of editing found, or could not be assessed. Note it next to the client’s source-of-funds explanation.

  • A score where the file allows it

    Text-based PDFs get an integrity score. A scan or photograph of a statement is checked as an image and gets a report without a score; ask for the original PDF when the amount matters.

  • An exportable PDF report

    Save the report to the matter or to the client’s FICA file, so a later review can see the check that was done.

  • What it does not say

    “No signs of editing found” is the best result for an unsigned file. It does not confirm that the bank issued the statement or that the funds are legitimate. That judgment stays with you.

FIC Act section 21A: understanding the source of funds

When an accountable institution takes on a new client for an ongoing business relationship, section 21A of the Financial Intelligence Centre Act requires it to understand the nature and intended purpose of that relationship and the source of the funds the client expects to use. Attorneys, estate agents and credit providers are among the accountable institutions listed in Schedule 1.

For estate agents, the FIC’s Public Compliance Communication 56 confirms that anyone doing estate-agent work is covered, including letting property and collecting rent, even under the newer title of property practitioner. A document check supports the information you gather under section 21A; it does not replace your risk management and compliance programme. This is a plain summary, not legal advice.

Recommended plan for compliance teams

Firms that check source of funds on every new matter or sale get through documents steadily. The Pro pack gives you 40 checks, valid for 180 days. Larger firms can compare Business on the pricing page.

Recommended

Pro pack

R299 once-off

R7.48 per check

For agencies, consultancies and small lenders with a steady flow of files.

  • 40 checks
  • Valid for 180 days
  • Full report + PDF export
  • Email and WhatsApp support
Get this pack

See pricing →

Statements from these banks

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Questions compliance officers ask

Does Atomara make us FICA compliant?

No tool does that on its own. Atomara checks whether a document shows signs of editing. Your compliance obligations, and the judgment on whether funds are legitimate, stay with your firm.

Does section 21A ask for source of wealth?

Section 21A refers to the source of funds a client expects to use. Source of wealth belongs to the provisions on politically exposed persons, in sections 21F to 21H. Ask your compliance adviser which applies to a given client.

Can we check a stamped or certified statement?

Yes, if you have it as a PDF up to 10 MB. Several banks issue stamped or certified statements from their apps. A stamp on the page and a check of the file answer different questions, so use both where you can.

What if the client sent a scan?

A scanned or photographed document inside a PDF is checked as an image and gets a report without a score. A picture cannot show which document it was taken from, so ask for the file downloaded from online banking.

How long do you keep client documents?

Uploaded files are deleted automatically within 30 days. Keep the exported report in your own records for as long as your record-keeping duties require.

Add a document check to your FICA process

Tell us roughly how many new clients you take on each month and how their documents reach you. We reply within one business day.

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