According to section 43 of the Financial Intelligence Centre Amendment Act (FICAA), Accountable Institutions must provide ongoing training relating to anti-money laundering (AML) and the counter financing of terrorism (CFT) to its employees with the purpose of complying with the provisions set out by FICAA and their internal Risk Management and Compliance Programme (RMCP).
FICA training is a mandatory regulatory requirement. Accountable Institutions that do not provide employees with the required training are considered non-compliant with the Act and expose themselves to potential administrative sanctions.
The Consequences of Non-Compliance: Discovery Bank
In a recent enforcement, the Prudential Authority imposed administrative sanctions on Discovery Bank Limited as a result of its non-compliance with certain provisions of the FIC Act. Amongst other areas of non-compliance, it was found that there was inadequate staff training, resulting in a R1 million fine. The bank failed to provide mandatory FICA training as outlined in its own Risk Management and Compliance Programme (RMCP). 84 of 155 new employees had not received training within 30 days of their appointment, 47 of 109 employees missed their annual refresher training, and 2 of 6 senior managers had not been trained on time. The bank failed to implement its own training requirements. FICA requires accountable institutions to provide ongoing staff training.
Training is an Ongoing Compliance Obligation
Training is not a one-time event. It's an ongoing compliance obligation under FICA. Your RMCP should specify training frequency, with annual refresher training generally expected for all staff. However, higher-risk roles may require more frequent training to ensure continued awareness and compliance.
New Employee Training Requirements
Implement new employee training within 30 days of appointment. This isn't just a best practice; regulators actively check this during inspections. Create a formal onboarding process that includes FICA training and track completion dates meticulously.
Tailor training roles and responsibilities. Front-line staff need different training than compliance officers or senior management. Everyone needs to understand FICA, but the depth and focus should match their responsibilities. This ensures that each employee receives the relevant knowledge required to fulfil their specific obligations under the Act.
Keep training records. Document who was trained, when, what content was covered, and maintain evidence of completion, such as attendance registers or assessment results. These records are critical during regulatory inspections and demonstrate your institution's commitment to ongoing compliance.
Frequently Asked Questions About FICA Training
What does FICA require regarding staff training?
Section 43 of the Financial Intelligence Centre Amendment Act mandates that Accountable Institutions must provide ongoing training to employees relating to:
- Anti-money laundering (AML)
- Counter financing of terrorism (CFT)
- Financial sanctions obligations compliance
This training must enable employees to comply with provisions set out by FICA and the institution's internal Risk Management and Compliance Programme (RMCP).
Is FICA training a once-off requirement?
Training is not a one-time event – it's an ongoing compliance obligation under FICA. Your RMCP should specify training frequency, with annual refresher training generally expected for all staff. Higher-risk roles may require more frequent training to ensure continued awareness and compliance.
When must new employees receive FICA training?
New employees must receive FICA training within 30 days of appointment. This isn't just a best practice; regulators actively check this during inspections. The Discovery Bank case demonstrated that failing to train 84 of 155 new employees within this timeframe resulted in a R1 million fine.
What happens if we don't provide adequate training?
Non-compliance with Section 43 can result in:
- Administrative sanctions from the Financial Intelligence Centre or your supervisory body
- Criminal penalties under Section 62 of the FIC Act
- Reputational damage and loss of client trust
- Regulatory fines, as evidenced by Discovery Bank's R1 million penalty
Does training need to be tailored to different roles?
Yes. Front-line staff need different training than compliance officers or senior management. Everyone needs to understand FICA, but the depth and focus should match their responsibilities. This ensures each employee receives the relevant knowledge required to fulfil their specific obligations under the Act.
What records must be kept for FICA training?
You must document and maintain records of:
- Who was trained
- When the training occurred
- What content was covered
- Evidence of completion (attendance registers, certificates, assessment results)
These records are critical during regulatory inspections and demonstrate your institution's commitment to ongoing compliance. Records must be kept for at least five years.
Can we use external training providers?
Yes. To mitigate reputational and financial impact, accountable institutions can use third-party training such as nCino KYC FICA Awareness Training. This 1-hour introductory session covers:
- Money laundering and terrorist financing
- The FIC Amendment Act requirements
- Ongoing Due Diligence and Know Your Client (KYC)
- Record keeping and red flags
- Reporting suspicions
- Consequences of non-compliance
Attendees receive a certificate of attendance evidencing compliance and can claim 2 CPD points if they are FAIS representatives, Key Individuals, or FPI members.
What topics must FICA training cover?
At a minimum, training should address:
- The provisions of FICA and its amendments
- Your institution's Risk Management and Compliance Programme
- Customer due diligence requirements
- Identification and verification procedures
- Record-keeping obligations
- Recognising suspicious transactions and red flags
- Reporting requirements and procedures
- Consequences of non-compliance
- Terrorist financing and financial sanctions
- Ongoing due diligence and monitoring
How do we demonstrate training compliance during an inspection?
Inspectors will request:
- Your training programme documentation
- Attendance registers with dates and signatures
- Training certificates or completion records
- Assessment results (if applicable)
- Your RMCP's training schedule and frequency requirements
- Evidence that training content aligns with current FICA requirements
Failure to produce adequate documentation can result in findings of non-compliance.
What advanced training options are available beyond basic awareness?
For enhanced FICA/AML knowledge, consider specialised training including:
- Advanced AML investigation techniques
- Senior management compliance workshops
- FICA Masterclass: Fundamentals for 2026
- Risk-based approach implementation
- Sanctions screening and PEP identification
- Suspicious transaction report writing
nCino KYC FICA Training
To mitigate the reputational and financial impact, Accountable Institutions can use third-party training, such as nCino KYC FICA Awareness Training. As per regulatory requirements, this introductory training course provides an overview and general awareness of the vital components of FICA.
This 1-hour training session is centred around the requirements that FICA places on Accountable Institutions and their employees. Topics include money laundering and terrorist financing; the FIC Amendment Act; Ongoing Due Diligence and Know Your Client (KYC) facets; Record Keeping; Red Flags; Reporting Suspicions; and the consequences of non-compliance.
Upon completion of this training, attendees are issued a certificate of attendance to evidence their compliance with FICA training requirements, practical tips that they can put into practice, and they will also be able to claim 2 CPD points towards their annual requirements if they are a FAIS representative, Key Individual, or member of the FPI.
Ready to Ensure your Team is FICA Compliant?
Don't wait for a regulatory inspection to discover training gaps. Book your spot at one of our weekly FICA Awareness Training sessions today.
Visit the nCino KYC training page or email kycafrica.compliance@ncino.com for more information.
