
Foreign-Currency Reserve Mandate and Repatriation Checklist
A foreign-currency reserve needs a written mandate: what it is for, how much may be held, where it is kept, how it earns or avoids income, and when money should return to South Africa. Without that record, “offshore cash” can become an indefinite and poorly evidenced holding.
Educational information only: This is not investment, exchange-control, tax or Shariah advice. Verify current requirements with authorised dealers and qualified professionals.
1. Define the reserve purpose
Record whether cash supports travel, education, offshore expenses, investment staging, emergency needs or currency diversification. Set a target time horizon.
2. Identify the owner and account
Capture legal owner, provider, custodian, account number, jurisdiction and currency. Distinguish personal and entity accounts.
3. Verify the provider
Check the bank, platform and intermediary through applicable official sources. Record the legal contracting entity and service provided.
4. Document the funding route
Retain authorised-dealer instructions, source-of-funds evidence, transfer confirmations and declarations. Reconcile the rand debit to foreign currency received.
5. Set the currency allocation
Record target currencies and maximum balances. Link each currency to expected expenses or a documented risk objective.
6. Review the account contract
Establish whether it is a deposit, money-market fund, custody account or another claim. Record who owes the balance and applicable protections.
7. Examine return and cash treatment
Capture how any profit, interest-like amount or fund distribution arises. Refer the exact structure and treatment to the qualified Shariah reviewer.
8. Check access and notice
Document withdrawal limits, notice periods, cards, beneficiaries and digital recovery. Test emergency access without sharing credentials.
9. Record fees and conversion costs
List account, custody, transfer, correspondent-bank and foreign-exchange charges. Reconcile gross and net movements.
10. Monitor currency risk
Report balances in both source currency and rand for household planning. Avoid presenting exchange gains as guaranteed investment return.
11. Define investment triggers
If cash awaits investment, record the decision threshold, authorised person and deadline. Review prolonged cash holdings against the original purpose.
12. Plan repatriation
Document who may instruct the transfer, destination account, evidence required and expected fees. Preserve the transaction chain.
13. Prepare tax records
Keep statements, exchange rates, distributions and ownership records for a registered tax practitioner. Foreign location does not remove South African reporting questions.
14. Coordinate estate access
Record provider death and incapacity procedures, document locations and professional contacts. Obtain cross-border estate advice where needed.
15. Maintain the reserve register
Purpose, target and owner
Provider, account and legal claim
Funding and authorised-dealer evidence
Currency, fees and Shariah treatment
Access, repatriation and review date
Useful official starting points include the SARB Financial Surveillance Department, SARS individual guidance and the SARB deposit-insurance information.
The completed mandate should show why the cash exists, how it was funded, where it is held and the conditions for using, investing or repatriating it.
