From CompliNEWS | Financial Services Intelligence Watch

TFS List amended – Accountable institutions must re-screen existing clients

The Financial Intelligence Centre has advised that the South African Targeted Financial Sanctions List has been amended through the following notices:

• TFS-871-01/08/2026
• TFS-872-01/08/2026
• TFS-873-01/08/2026
• TFS-874-01/08/2026
• TFS-875-01/08/2026.

Although the notification was circulated on Friday, 31 July 2026, the amendment notices are dated 1 August 2026.

Action required

Accountable institutions should, without delay, screen the updated TFS designations against all existing information held concerning:

• clients and prospective clients
• beneficial owners
• persons acting on behalf of clients
• persons on whose behalf clients are acting
• authorised representatives and controlling persons
• known connected persons and entities
• parties to transactions, where applicable. 

This should not be deferred until the client’s next periodic review.

Why is re-screening required?

The obligation does not arise merely because the institution considers a particular client to be high risk. Targeted financial sanctions apply irrespective of the client’s ordinary money-laundering risk classification.

FIC Public Compliance Communication 44A states that client information must be scrutinised when the TFS List is updated and that all existing information concerning clients must be screened against the updated list. The FIC further advises that this should take place without delay.

The reason is straightforward: an existing client or beneficial owner who was not previously designated may have been added to the list. Unless existing records are checked following the update, the institution may continue providing financial services or dealing with property for the benefit of a designated person.

Manual and automated screening

The FIC does not prescribe expensive or sophisticated screening technology. Screening may be completed manually or through an automated screening solution.

Where an external screening provider is used, the accountable institution should verify that:

• the provider has incorporated the latest South African TFS amendments
• the existing client population has been screened against the updated data
• potential matches have been properly investigated
• an audit trail can be produced. 

Outsourcing the screening function does not transfer the institution’s accountability. The process must be documented in the RMCP, and the institution must be able to demonstrate that the screening provider’s lists are current.

Evidence to retain

Accountable institutions should retain evidence showing:

• the date and time the updated list was received or identified
• when the screening exercise was completed
• the population and data fields screened
• confirmation that the amended TFS data was used
• the screening results
• investigation and resolution of possible matches
• any escalation, freezing or reporting action taken. 

The FIC recommends retaining the results of screening, including the date on which it was performed.

Where a possible match is identified

Do not transact or proceed on the strength of an initial name match alone. The available identifiers must be compared carefully to determine whether the person or entity is the designated party or a false positive.

Where a confirmed match is established, the institution must immediately apply the relevant freezing and reporting requirements under FICA. No funds or property may be made available, directly or indirectly, to or for the benefit of the designated person or entity.

Institutions should also ensure that no action is taken that could amount to tipping off.

Compliance takeaway

A monthly, quarterly or annual screening schedule does not replace event-driven screening when the TFS List changes.

The defensible approach is to:

Update the screening data, screen the full existing client and connected-person population without delay, investigate possible matches and retain evidence of completion.

The institution’s RMCP should clearly record this process, including responsibility, escalation requirements, record keeping and the use of any third-party screening provider.

Categories: Compliance