Offshore Account Document and Adviser Review Checklist
Opening or maintaining an offshore investment account involves more than choosing a fund. South African families need a clean evidence trail for identity, tax residence, source of funds, exchange-control routing, ownership and ongoing advice. This checklist helps a family prepare that file before money moves.
This is general information, not tax, legal, exchange-control or investment advice. Cross-border facts change quickly. Confirm the current position with appropriately authorised South African and destination-country professionals before acting.
1. Define the account’s job
Write one sentence explaining why the account exists: long-term diversification, education costs in another currency, future travel, retirement spending or another documented purpose. Add the expected time horizon, acceptable volatility, liquidity needs and the currency in which the future expense is likely to occur. This prevents an offshore account from becoming a collection of unrelated products.
2. Record the legal owner and beneficial owner
State whether the account is owned by an individual, spouses jointly, a company, a trust or another entity. Record who supplied the capital, who may give instructions, who receives statements and who ultimately benefits. For a trust or company, keep the constitutive documents, authority resolutions and current beneficial-ownership records together. The account application, bank transfer narrative and family records should tell the same ownership story.
3. Build the identity and address pack
Keep clear, current copies of identity documents and accepted proof of address for every relevant person. Include marriage documents where the matrimonial property system affects ownership or consent. Entity accounts usually require additional documents for directors, trustees, authorised signatories and beneficial owners. Ask the provider for its current list instead of assuming that last year’s pack is still sufficient.
4. Document tax residence
Tax residence is a factual and legal question; nationality or a bank address does not settle it. Record each account holder’s declared tax residence, tax numbers and any recent migration or cessation-of-residence advice. Providers may request self-certifications under international information-sharing rules. Ensure the form agrees with the family’s submitted tax returns and professional advice.
5. Preserve source-of-funds evidence
Create a short schedule linking the amount transferred to its origin. Evidence might include bank statements, a payslip trail, a sale agreement, dividend records, audited company distributions, inheritance documents or a prior investment redemption. Keep the path from the original source to the offshore account visible. A large unexplained credit followed by an offshore transfer can create avoidable delays.
6. Confirm the transfer route
Record the authorised dealer or other lawful route used, the transfer date, rand amount, foreign-currency amount, exchange rate and bank charges. Retain bank confirmations and any supporting tax or exchange-control documentation requested for that transaction. The South African Reserve Bank publishes financial-surveillance information, but the operational requirements should be confirmed with the authorised dealer handling the transfer.
7. Review the adviser and platform
Identify each party: South African adviser, offshore adviser, discretionary manager, platform, custodian and bank. Record the services each performs, the jurisdiction governing the agreement, who holds client assets and how complaints are handled. Verify South African financial-service authorisation through the FSCA’s FSP search. An authorisation check does not replace product due diligence.
8. Map every layer of fees
List advice, platform, custody, fund-management, transaction, foreign-exchange, banking and exit fees separately. Show whether each fee is fixed, percentage-based or performance-related, and whether VAT applies. Compare the total against the service actually received. Offshore structures with several intermediaries can make a modest-looking fee at each layer expensive in combination.
9. Keep Shariah evidence current
Store the screening methodology, Shariah board or adviser information, purification policy and the date on which the evidence was reviewed. Check both the underlying assets and the way cash, currency conversion, leverage, securities lending and derivatives are used. A halal label is the start of due diligence, not the evidence file itself.
10. Check liquidity and currency mismatch
Record notice periods, dealing days, settlement times, withdrawal limits and any penalties. Match the account currency to the planned use where practical. A family may hold a sound investment and still face a loss if it must sell during market weakness or convert currency at an unfavourable time to meet a near-term rand expense.
11. Coordinate estate and incapacity records
Record what happens if an account holder dies or loses capacity. Keep beneficiary or nomination forms where applicable, powers or mandates, contact details for executors and advisers, and a secure inventory that tells authorised people where the account exists. Do not assume a South African will automatically deals efficiently with every foreign asset; obtain jurisdiction-specific advice where necessary.
12. Create an annual review page
Once a year, record the account value, purpose, ownership, tax-residence facts, adviser status, total fees, Shariah evidence, liquidity and estate documents. Note decisions, responsible people and deadlines. Where facts changed, update the provider and professional advisers promptly rather than waiting for a withdrawal or estate event.
Official starting points
Practical outcome: the family should be able to explain who owns the account, why it exists, how the money arrived, who advises on it, what it costs, how its Shariah status is supported and what happens during incapacity or death.
