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.
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 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.
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.
Section 43 of the Financial Intelligence Centre Amendment Act mandates that Accountable Institutions must provide ongoing training to employees relating to:
This training must enable employees to comply with provisions set out by FICA and the institution's internal Risk Management and Compliance Programme (RMCP).
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.
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.
Non-compliance with Section 43 can result in:
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.
You must document and maintain records of:
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.
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:
Attendees receive a certificate of attendance evidencing compliance and can claim 2 CPD points if they are FAIS representatives, Key Individuals, or FPI members.
At a minimum, training should address:
Inspectors will request:
Failure to produce adequate documentation can result in findings of non-compliance.
For enhanced FICA/AML knowledge, consider specialised training including:
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.
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.