The FIC Act places an obligation on all banks to establish and verify the identity of their clients. A client of a bank may include a natural person, a juristic person, such as a close corporation and a company, a partnership, a trust and an organ of state including government departments.

There is an obligation on all banks to establish and verify the identity of their client even if the client is an organ of state including a government department.

Certain organs of state are incorporated as companies and registered with the Registrar of Companies to conduct business and must be identified as companies. In other instances, Government institutions are constituted as legal persons by statute. Regulations 11 and 12 provide for a category of client referred to as "other legal person", which includes organs of state constituted as legal persons by statute.

Sound business practice would indicate that organs of state that are neither incorporated as companies nor constituted as legal persons by a statute should be dealt with in a manner similar to that used in respect of "other legal persons". This would apply to national, provincial and local government departments.

This implies that, among others, the identities of the persons acting on behalf of an organ of state would have to be established and verified.

In some circumstances, this may include the Chief Financial Officer (IICFO") acting on behalf of a Government department. In such instances, the full name, date of birth and identity number in respect of individuals acting on behalf of the relevant organs of state should be obtained and verified. In addition, information concerning the contact particulars of such persons should be obtained.