Estate Agency RMCP Discovery & Assessment

1
Which role(s) do you currently perform? Select all that apply.* This field is required.
Head Office / Group Management
FICA / Compliance Officer
Principal Property Practitioner
Branch Manager
Property Practitioner
Administrative / Support Role
Other
2
Who is the principal responsible for this agency / branch / office?* This field is required.
Principal Property Practitioner
Branch Manager
Property Practitioner
Other
3
Is the principal based at this agency / branch / office?* This field is required.
Yes
No
Don't know
4
Province* This field is required.
Please Select
Please Select
Eastern Cape
Free State
Gauteng
KwaZulu-Natal
Limpopo
Mpumalanga
North West
Northern Cape
Western Cape
5
Franchise / network / platform (if applicable)* This field is required.
Please Select
Franchise / network / platform
Standalone agency
Multi-branch group
Not applicable
Don't know
6
Agency / branch / office name* This field is required.
7
Legal entity / accountable institution* This field is required.Accountable institution means the legal entity registered with the FIC, not merely the agency, branch or trading name. Please enter the legal company/entity under which this business operates for FIC purposes. If you genuinely do not know, enter “Don’t know”.
8
FIC Org ID* This field is required.This is the organisation number allocated to the accountable institution on goAML. If you do not know it, please say so rather than guessing.
FIC Org ID means the organisation number allocated on goAML.
9
PPRA firm number / FFC awareness* This field is required.We are checking whether the branch knows which PPRA firm registration / Fidelity Fund Certificate applies to the accountable institution.
Yes
No
Don't know
10
Mobile number
Please enter a valid phone number.
11
Gmail address for secure J9Compliance folder access
example@example.com
12
PPRA firm number / FFC reference* This field is required.If you do not have one please say "No Number / No Reference"
13
Respondent name* This field is required.Please provide your name so that we can follow up where clarification is required. This is not an individual performance assessment.
First Name
Last Name
14
Respondent email* This field is required.A copy of this form will be emailed to you when you have completed it
example@example.com
15
Is the agency / branch / office’s legal entity / accountable institution relationship formally confirmed?* This field is required.We want to know whether there is clear evidence showing which legal entity this branch operates under for FIC and PPRA purposes.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
16
Where is the supporting CIPC / PPRA / FIC evidence kept?* This field is required.Please tell us where you would actually go to find this evidence today. If it is stored in more than one place, select the main location. If you select Other, please specify where. If you genuinely do not know, select I don’t know.
Paper file at branch
Local branch computer
Branch shared drive
Head Office system
RMCP
Another system
I don’t know
Other
17
Are all current branches/locations reflected on goAML?* This field is required.Please answer based on your current goAML registration information. We are checking whether the accountable institution’s actual operating locations are reflected in its registration records.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
18
Where is the latest registration extract kept?* This field is required.Please tell us where you would actually go to find this evidence today. If it is stored in more than one place, select the main location. If you select Other, please specify where. If you genuinely do not know, select I don’t know.
Paper file at branch
Local branch computer
Branch shared drive
Head Office system
RMCP
Another system
I don’t know
Other
19
Has the agency / branch / office / entity changed ownership, legal entity, principal, franchise or platform structure in the last 3 years?* This field is required.Examples include a change of company, franchisee, principal, ownership or the branch moving from one accountable institution to another.
Yes
No
Don't know
20
If yes, were FIC/goAML, PPRA and RMCP records updated?
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
21
Where is the update evidence kept?* This field is required.Please tell us where you would actually go to find this evidence today. If it is stored in more than one place, select the main location. If you select Other, please specify where. If you genuinely do not know, select I don’t know.
Paper file at branch
Local branch computer
Branch shared drive
Head Office system
RMCP
Another system
I don’t know
Other
22
Is there a current primary and backup authorised goAML user?* This field is required.We are checking access continuity. There should be somebody able to perform the required goAML activities even if the primary user is unavailable or leaves. Do not provide passwords.
0 = N/A
1 = Don’t know
2=No
3 = Yes
Other
23
State the primary and backup authorised user name and role (no passwords).
Primary Name
Primary role
Backup Name
Backup role
24
Can the current responsible person access goAML today?Answer Yes only if the authorised person can actually log into the relevant goAML account now. Registration alone does not mean access is working.
Yes
No
Don't know
N/A
25
Has the most recent RCR obligation for this accountable institution been reviewed/completed and is evidence retained?* This field is required.A current RMCP means the latest formally approved Risk Management and Compliance Programme that applies to the legal entity and relevant branch or branches.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
26
Where is the RCR evidence/status kept?Think practically: if you needed the relevant FICA procedure today, would you know where to find it?
Paper file at branch
Local branch computer
Branch shared drive
Management / group management / responsible authority system
RMCP
Another system
Other
I don’t know
27
Is there a current RMCP that clearly applies to this accountable institution and its operating structure?* This field is required.A current RMCP means the latest formally approved Risk Management and Compliance Programme that applies to the legal entity and relevant branch or branches.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
28
Has the current RMCP been formally approved?* This field is required.Formal approval means the RMCP has been approved/sign-off by the accountable institution’s appropriate senior management or governing authority. Having a copy of the RMCP does not necessarily mean it has been formally approved.
Yes
No
Don’t know
29
When was the RMCP last formally approved?Formal approval means the RMCP has been approved/sign-off by the accountable institution’s appropriate senior management or governing authority. Having a copy of the RMCP does not necessarily mean it has been formally approved.
Date
Month
Day
Year
30
Does the RMCP identify the actual services, geography, client types, and delivery channels?* This field is required.We are checking whether the RMCP reflects how the business actually operates rather than being a generic template.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
31
Are responsibilities for the principal, compliance officer, branch manager, and practitioner documented?* This field is required.This means whether it is clear who performs each task, who owns the final decision, who must be consulted and who must be informed. It does not have to be a document called a “RACI”.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
32
Do you know exactly who to escalate to when unsure about a FICA decision?* This field is required.We are checking whether staff have a clear escalation route when a client, transaction, screening result or FICA requirement is uncertain.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
33
Services performed by this agency / branch / office / accountable institution* This field is required.Select all services that are actually performed. The service mix affects the risks and controls that may apply.
Residential Sales: Buying and selling homes, apartments, and residential land.
Residential Rentals: Leasing houses, townhouses, and multi-family residential units.
Commercial Sales: Buying and selling office buildings, retail centers, and business parks.
Commercial Rentals: Leasing office space, retail shops, and hospitality venues.
Industrial Sales & Rentals: Transacting and leasing warehouses, factories, and manufacturing plants.
Agricultural / Farm Sales: Buying and selling rural land, farms, and agricultural holdings.
Residential Property Management: Overseeing tenant placement, rent collection, and maintenance for homes and apartments.
Commercial Property Management: Managing day-to-day operations, tenant relations, and common areas for commercial properties.
Industrial & Special Purpose Management: Managing specialized facilities like logistics hubs, healthcare centers, and self-storage.
Facilities Maintenance & Upkeep: Cleaning, repairs, security, and general upkeep coordination.
Property Auctions: Publicly bidding and selling distressed, luxury, or commercial real estate assets.
Buyer's Agency / Representation: Locating, evaluating, and securing properties exclusively on behalf of buyers.
Real Estate Investment Consulting: Advising on capital allocation, portfolio growth, and market trends.
Property Valuations & Appraisals: Determining official market and financial values of land and buildings.
Home & Building Inspections: Assessing structural integrity, safety, and physical quality before purchase.
Corporate Real Estate Services: Strategic portfolio optimization, lease auditing, and workplace strategy.
Title, Closing, & Escrow Services: Handling legal transfers, title searches, and closing documentation
Other
Other
34
Does this agency / branch / office regularly deal with non-resident / foreign clients or cross-border funds?* This field is required.This includes clients who live outside South Africa, foreign legal entities, or transactions involving funds entering or leaving South Africa.
Yes
No
Don't know
35
Does this agency / branch / office handle commercial, trust, company, or other complex legal-person transactions?* This field is required.We are identifying transactions where ownership, control or beneficial ownership may require additional checks.
Yes
No
Don't know
36
Are risk factors formally reviewed when business changes occur (new service, branch, system, client type, or geography)?* This field is required.Examples include opening a new branch, introducing a new service or system, dealing with a new client type, or operating in a new geographic area.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
37
Required FICA information is obtained and verified before entering into a business relationship or transaction* This field is required.Answer according to what happens in practice. We are testing whether required client due-diligence information is obtained before the business proceeds.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
38
If required FICA information is incomplete, can a transaction proceed?* This field is required.We want to understand whether incomplete FICA information stops the process, or whether an exception can be authorised and recorded.
Yes
No
Depends / exception process
Don’t know
39
If yes or depends, who approves the transaction and how is the approval recorded?
40
Beneficial owners/controllers for companies, trusts or partnerships are identified and verified* This field is required.Beneficial ownership means identifying the natural person or persons who ultimately own or control the company, trust, partnership or other legal arrangement.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
41
Where is the beneficial ownership evidence kept?* This field is required.Please tell us where you would actually go to find this evidence today. If it is stored in more than one place, select the main location. If you select Other, please specify where. If you genuinely do not know, select I don’t know.
Paper file at branch
Local branch computer
Branch shared drive
Management / group management / responsible authority system
RMCP
Another system
I don’t know
Other
42
When ownership or control cannot be established, staff know what to do* This field is required.We are checking whether there is a clear stop, escalation or enhanced-review process when beneficial ownership cannot be satisfactorily established.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
43
Are clients assigned a risk level using the accountable institution’s own methodology?* This field is required.This means whether each client is assessed as, for example, Low, Medium or High risk using the accountable institution’s own approved approach. The accountable institution remains responsible for its risk decision.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
44
Are the reasons and criteria for Low, Medium and High risk documented and current?* This field is required.We are checking whether there are clear and current rules explaining why a client receives a particular risk classification.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
45
Where is your client risk-rating methodology kept?* This field is required.This means the document, procedure or part of the RMCP that explains how your accountable institution decides whether a client is Low, Medium or High risk. We are asking where you would actually go to find it.
Paper file at branch
Local branch computer
Branch shared drive
Management / group management / responsible authority system
RMCP
Another system
I don’t know
Other
46
Does a High risk rating automatically trigger enhanced due diligence and/or approval?* This field is required.Enhanced Due Diligence (EDD) means additional checks, information or approvals for higher-risk clients. We are testing whether a High-risk result automatically leads to those additional controls.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
47
Is senior management approval recorded where required for higher-risk relationships?* This field is required.We want to know whether required approvals are formally recorded so that the decision can later be evidenced.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
48
Where is the approval evidence kept?* This field is required.Select the main place where evidence of senior-management or other required approval would be found.
Paper file at branch
Local branch computer
Branch shared drive
Management / group management / responsible authority system
RMCP
Another system
I don’t know
Other
49
Do you know what additional information or evidence is required for a high-risk client?* This field is required.Examples could include additional source-of-funds or source-of-wealth information, further verification, management approval or other enhanced checks required by your process.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
50
Are clients and relevant related persons screened for PEP/prominent-person and sanctions/TFS exposure?* This field is required.We are checking whether the required people are screened for prominent-person exposure and sanctions / Targeted Financial Sanctions risks.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
51
Where is the screening evidence kept?* This field is required.Please tell us where you would actually go to find this evidence today. If it is stored in more than one place, select the main location. If you select Other, please specify where. If you genuinely do not know, select I don’t know.
Paper file at branch
Local branch computer
Branch shared drive
Management / group management / responsible authority system
RMCP
Another system
I don’t know
Other
52
Do you know whether you may proceed, and who must review a possible PEP or sanctions/TFS match?* This field is required.We are testing whether staff know what to do when screening produces a possible match — including whether the matter must be stopped, reviewed or escalated before proceeding.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
53
Are false positives and match decisions documented so the rationale can be evidenced later?* This field is required.A false positive is a screening result that appears to match a person but is subsequently confirmed not to be the same person. We are checking whether the review and decision are recorded.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
54
Staff know how to escalate suspicious or unusual activity internally* This field is required.This means knowing who to contact internally and what process to follow when something about a client or transaction appears suspicious or unusual.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
55
Staff understand they must not disclose to a client that a suspicious transaction/activity report may be considered or made* This field is required.This tests awareness of the prohibition on alerting the client or another person that a suspicious-activity reporting process may be underway.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
56
Reportable events are tracked from internal escalation through to goAML submission and evidence retention* This field is required.We are checking whether there is an end-to-end record from the original internal concern through the decision, any regulatory report and the retained evidence.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
57
Most recent RCR obligation reviewed for this accountable institution and evidence retained* This field is required.RCR means Risk and Compliance Return. If you do not know whether an RCR applied or was submitted for this accountable institution, select Don’t know.
Paper file at branch
Local branch computer
Branch shared drive
Management / group management / responsible authority system
RMCP
Another system
I don’t know
Other
58
Defined location for completed FICA records* This field is required.We are checking whether staff know the authoritative place where a complete client FICA record should be stored.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
59
Authorised staff can promptly retrieve a complete client FICA record* This field is required.Think practically: if management, the FIC or another authorised reviewer requested the file today, could the complete record be produced without difficulty?
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
60
Retention deletion/disposal and extended hold arrangements are documented* This field is required.This means there are rules for how long FICA records are retained, when they may be deleted or disposed of, and when they must be kept longer because of an investigation or other requirement.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
61
Responsibilities, access and continuity/backup arrangements for third-party record storage are understood* This field is required.This applies where records are stored in your systems or another external provider. We want to know who retains responsibility, who can access the records and what happens if the service is unavailable.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
62
Is there a current training matrix showing who requires what FICA training and when?* This field is required.A training matrix is simply a record showing which roles require which training, whether it has been completed and when refresher training is due.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
63
Where is the training matrix kept?* This field is required.A training matrix is simply a record showing which roles require which training, whether it has been completed and when refresher training is due.
Paper file at branch
Local branch computer
Branch shared drive
Management / group management / responsible authority system
RMCP
Another system
I don’t know
Other
64
Have you completed FICA/RMCP training appropriate to your role within the last 12 months or current cycle?* This field is required.Answer for your own role. We are identifying current training coverage and future training needs.
Yes
No
Don't know
65
Does the training include practical scenarios such as high-risk clients, PEP/TFS matches, incomplete CDD, and escalation?* This field is required.We are distinguishing practical, role-based training from general theory-only training.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
66
Are attendance, assessment results, acknowledgements, and refresher needs retained as evidence?* This field is required.We are distinguishing practical, role-based training from general theory-only training.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
67
Are client files periodically reviewed or tested for FICA control compliance?* This field is required.This means checking a sample of actual client files to confirm that the required controls are working in practice.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
68
Where are the review results kept?* This field is required.
Paper file at branch
Local branch computer
Branch shared drive
Management / group management / responsible authority system
RMCP
Another system
I don’t know
Other
69
Are exceptions such as missing CDD, or failed screening escalations tracked to closure?* This field is required.We are checking whether identified problems are assigned, followed up and formally closed once corrected.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
70
Where is the exception or corrective-action register kept?* This field is required.
Paper file at branch
Local branch computer
Branch shared drive
Management / group management / responsible authority system
RMCP
Another system
I don’t know
Other
71
Does management receive a regular view of FICA control performance, open issues, and overdue remediation?* This field is required.This could be a dashboard, report, register or management review showing what is working, what is outstanding and what needs attention.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
72
Which report or dashboard is used?
73
Do material incidents, entity changes, regulatory changes, or system changes trigger an RMCP or risk-assessment review?* This field is required.We are checking whether the RMCP and risk assessment are actively updated when the business or regulatory environment changes.
0 = N/A
1 = Don’t know
2 = No / not operating
3 = Partially / inconsistently
4 = Operating, but evidence weak
5 = Operating and evidenced
74
Where is the change or review evidence kept?* This field is required.
Paper file at branch
Local branch computer
Branch shared drive
Management / group management / responsible authority system
RMCP
Another system
I don’t know
Other
75
What is the single biggest FICA/RMCP difficulty you are currently experiencing?* This field is required.Please tell us the practical issue that causes the most uncertainty, delay, frustration or risk in your current environment. There is no “correct” answer.
76
Are any parts of your current RMCP or process routinely ignored, worked around, or found impractical? Please explain.* This field is required.Please be candid. A process that looks good on paper but is regularly bypassed is exactly the kind of issue this assessment is designed to identify.
77
If you selected ‘OTHER’ for any evidence or document location above, please tell us which question it related to and where the information is kept. If you did not select Other anywhere, enter N/A.* This field is required.
Huge
Large
Normal
Small
Ok
Ok
78
Which evidence or documents should J9 review next to validate your response? For management / group management / responsible authority, FICA / Compliance Officer, Principal Property Practitioner, or Branch Manager: identify the evidence or its location only. Do not upload client IDs, bank statements, or client FICA packs.* This field is required.Identify the document, report, system or evidence location only. Do not upload client IDs, bank statements, passwords or confidential client files here.
Evidence means where the proof is kept. Do not upload sensitive client documents in this first assessment.
79
Thank you. Your answers help identify where support, clarification or remediation is needed, especially when you’ve answered No or Don't know. Please keep focusing on the real operating environment rather than the answer management might expect.
80
J9Compliance (Pty) Ltd will use the information provided in this assessment to evaluate your FIC/RMCP compliance position, contact you about the assessment, create and maintain your compliance workstream where applicable, and deliver any agreed compliance services. Information will be handled in accordance with the Protection of Personal Information Act, 2013 (POPIA). You can read the full J9Compliance Privacy Notice here: https://j9web.co.za/privacy-notice/
81
I consent to J9Compliance (Pty) Ltd collecting, using, storing and otherwise processing the personal and business information I provide in this form for the purposes described above. I confirm that I am authorised to provide the information submitted, including information relating to my business and its practitioners or responsible persons where applicable.* This field is required.
I consent
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