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Financial Intelligence Centre Act, 2001 (Act No. 38 of 2001)


Guidance Note 3

Guidance for Banks on Customer Identification and Verification and Related Matters

Establishing and Verifying Identities

Natural Persons - South African Citizens and Residents

14. Ongoing client detail maintenance


Regulation 19 of the Regulations states that a bank must take reasonable steps, concerning the verification of client identities that may apply to that bank in respect of an existing business relationship so as to maintain the correctness of particulars that are susceptible to change.


Decisions concerning the method by means of which such maintenance is to be achieved should be based on a bank's risk framework, referred to in paragraph 2 above. Some guidance may be taken from international best practice and FATF standards that refer to on going risk-sensitive programmes to maintain relevant client details.


The following procedure for ongoing maintenance of client information may be considered:

banks should apply their know your client (KYC) procedures to existing clients on the basis of materiality and risk, and should conduct due diligence reviews of such existing relationships at appropriate times;
banks need to undertake regular reviews of their existing client records. An appropriate time to do so is when a transaction of significance takes place; or when there is a material change in the way the account is operated; and
if a bank becomes aware at any time that it lacks sufficient information about an existing client, it should take steps to ensure that all relevant KYC information is obtained as quickly as possible.