We look at the two main questions that are asked about document verification: which documents must be verified and who may verify them?

Which documents must be verified?
The Financial Intelligence Centre Act states the following:

Schedule 3: List of Reporting Institutions
A person who carries on the business of dealing in motor vehicles.
A person who carries on the business of dealing in Krugerrands.

Chapter 1: Establishment and verification of identity
Part 1: Introduction
No accountable institution may knowingly establish or maintain a business relationship or conduct a single transaction with a client who is entering into that business relationship or single transaction under a false name. When an accountable institution in terms of the Act must establish and verify the identity of a natural or legal person or a trust, the institution must establish and verify identity in accordance with regulations 2 to 18.

Regulations in terms of the Financial Intelligence Centre Act, 2001
Chapter 1: Establishment and verification of identity
Part 2: Natural Persons
An accountable institution must obtain from, or in respect of, a natural person who is a citizen of, or resident in, the Republic, that person's –

a) full names;
b) date of birth;
c) identity number;
d) income tax registration number, if such a number has been issued to that person; and
e) residential address.

In the case where the accountable institution is aware or ought reasonably to be aware that the person referred to in sub regulation (1) does not have the legal capacity to establish a business relationship or conclude a single transaction without the assistance of another person the accountable institution must, in addition to obtaining the particulars referred to in sub regulation (1), obtain from, or in respect of, of that other person:
a) his or her full names;
b) his or her date of birth;
c) his or her identity number;
d) his or her residential address; and
e) his or her contact particulars.

Regulations in terms of the Financial Intelligence Centre Act, 2001
Chapter 1 : Establishment and verification of identity
Part 2 : Natural Persons
4. Verification of information concerning South-African citizens and residents
1) An accountable institution must verify the full names, date of birth and identity number of a natural person referred to in regulation 3(1)(a), (b) or (c), or 3(2)(a), (b) or (c) by comparing these particulars with –
a) i) an identification document of that person; or
ii) in the case where that person is, for a reason that is acceptable to the institution, unable to produce an identification document, another document issued to that person, which, taking into account any guidance notes concerning the verification of identities which may apply to that institution, is acceptable to the institution and bears:
aa) a photograph of that person;
bb) that person's full names or initials and surname;
cc) that person's date of birth, and
dd) that person’s identity number; and

b) any of these particulars with information which is obtained from any other independent source, if it is believed to be reasonably necessary taking into account any guidance notes concerning the verification of identities which may apply to that institution.

2) An accountable institution must verify the income tax registration number referred to in regulation 3(1)(d) by comparing this number with a document issued by the South African Revenue Service bearing such a number and the name of the natural person.

3) An accountable institution must verify the residential address referred to in regulation 3(1)(e) or 3(2)(f) by comparing these particulars with information which can reasonably be expected to achieve such verification and is obtained by reasonably practical means, taking into account any guidance notes concerning the verification of identities which may apply to that institution.

The National Credit Act does not prescribe what documents need to be verified

Who may verify documents?
The Financial Intelligence Centre Act prescribes an Accountable Institution to verify but the National Credit Act does not prescribe who may verify documents. However, the National Credit Act allows the Credit Provider (Financial institution) to appoint an Agent who is issued with a NCA card for identification purposes. The dealer signs a Master Sales Agreement with the Credit Provider/ Financial Institution whereby the details of the Agent/ NCA carded person is noted. In doing so the requirement of verification is placed on the Agent. A non-NCA carded person is not registered as an Agent and therefore not allowed to do verification in terms of Master Sales Agreements. In terms of section 163 of the NCA it is the responsibility of the Credit Provider to ensure that their Agents are trained in respect of the Act.

It is also the responsibility of the FSP to ensure that their respective representatives are at all stages informed and trained with regards to the Acts which applies to the industry. Therefor IDA Risk Management has developed and implemented an e-learning platform for training purposes in terms of FICA. Please access our website to register for this training: www.ida.co.za

If you experience any problems to register for this training please contact your local IDA Services Manager.