You are an accountable institution. Now what?

The FIC Amendment Act widened the net. Estate agents, legal practitioners, trust and company service providers, high-value-goods dealers and a long list of others are now accountable institutions, with the same obligations a bank has carried for years. Most of them found out the hard way: a letter, an inspection, or a client who asked for a compliance certificate they did not have.

Who is caught

If you are on Schedule 1 of the FIC Act, you are in. The test is not your size or your turnover. It is the activity. A single-practitioner conveyancer handling a property transfer carries the same screening and record-keeping duties as a large firm. The regulator does not scale the obligation to the business.

What screening actually means

Screening is not a once-off box at onboarding. It means checking every client, and every beneficial owner behind that client, against sanctions lists, politically exposed person (PEP) lists and adverse media — and then doing it again, on a schedule, because the lists change and so do the people on them.

The part most firms miss is the second half. A client screened clean in March is not a client screened clean today. Continuous monitoring is the obligation, not the courtesy.

What an audit trail has to show

When an inspector arrives, they do not ask whether you meant to comply. They ask for the record: who you screened, when, against which lists, what the result was, and who signed it off. If that record lives in someone's memory or in an email thread, you do not have a record.

A defensible audit trail is dated, attributable and complete. It survives the person who created it leaving the firm. That is the bar, and it is the bar RAHN Monitor was built to meet.

If you have just become an accountable institution, start with one question: if an inspector asked for your last screening run, could you produce it in a form that would satisfy them? If the answer is no, that is the work.