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Customer Due Diligence Checklist
A comprehensive checklist to ensure thorough customer due diligence procedures are followed for all clients. Covers all FICA Section 21 requirements.
How to Use This Checklist
This checklist covers all Customer Due Diligence requirements under FICA Section 21. Use it when onboarding new clients to ensure all required information is collected and verified. Check off each item as completed and document any exceptions.
1. Client Identification
- Collect full legal name
- Obtain date of birth
- Record residential address
- Gather contact information (phone, email)
- Collect identification number (ID, passport, etc.)
- For entities: Obtain registered name and registration number
- For entities: Record nature of business
- For entities: Collect names of directors/controlling persons
2. Verification of Identity
- Verify identity documents (check authenticity)
- Cross-check information with independent sources
- Conduct electronic verification (Home Affairs, CIPC)
- Perform biometric verification (if required)
- Verify address through proof of residence
- For entities: Verify registration documents
- For entities: Verify founding documents (MOI)
- Document all verification steps taken
3. Determine Nature of Business Relationship
- Understand purpose and intended nature of business relationship
- Gather information on occupation or business activities
- Determine expected transaction patterns
- Establish expected source of funds
- Document the reason for the business relationship
4. Beneficial Ownership
- Identify all beneficial owners (for entities)
- Determine ownership percentages (>25% threshold)
- Verify identities of beneficial owners
- Understand ownership and control structure
- Document the chain of ownership
- Identify any nominee arrangements
5. Risk Assessment
- Assess client risk profile (low/medium/high)
- Consider geographical risk factors
- Evaluate product/service risks
- Assess delivery channel risks
- Document risk rating and rationale
- Determine if EDD is required
6. Enhanced Due Diligence (if applicable)
- Conduct PEP screening
- Screen against sanctions lists
- Conduct additional verification for high-risk clients
- Obtain senior management approval
- Determine and document source of funds/wealth
- Implement enhanced ongoing monitoring
7. Ongoing Monitoring
- Set up transaction monitoring system
- Establish process for periodic client reviews
- Implement procedure for updating client information
- Schedule re-screening against PEP/sanctions lists
- Define trigger events for additional due diligence
- Establish suspicious activity escalation procedures
8. Record Keeping
- Maintain records of all CDD measures taken
- Keep copies of identification documents
- Keep records of all transactions
- Document all verification steps and outcomes
- Ensure records are easily retrievable
- Retain records for minimum 5 years after relationship ends
9. Training and Compliance
- Train staff on CDD procedures
- Establish clear escalation procedures
- Conduct regular audits of CDD processes
- Keep training records
- Update procedures as regulations change
Legal Reference
This checklist is based on requirements from FICA Section 21 (Customer Due Diligence), Section 21A (Enhanced Due Diligence), Sections 22-23 (Record Keeping), and related FIC Guidance Notes. Always ensure your procedures align with the latest regulatory guidance.
Download Printable Checklist
Get a printable PDF version of this checklist with checkboxes and space for notes. Perfect for audit documentation.
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