The TFS list changed last night.
Do you know if it affects your clients?
Automated FIC Act Targeted Financial Sanctions (TFS) list screening for South African accountable institutions - daily FIC list synchronisation, dual-source FIC SA and UN sanctions screening, and audit-ready compliance certificates
InTouch synchronises with the FIC's Targeted Financial Sanctions list every day, detects every change, automatically re-screens your entire client base against both the FIC SA and UN consolidated lists, and delivers an audit-ready report to your compliance team the same morning.
The law says "without delay". Manual processes cannot keep pace.
Section 28A(3) of the FIC Act, as amplified by PCC 44A (February 2024), requires accountable institutions to scrutinise client information against the TFS list at onboarding, when transacting, and - critically - every time the list is updated. The screening obligation extends beyond the direct client to beneficial owners, persons acting on behalf of the client, persons on whose behalf the client acts, and other parties to the client's transaction. There is no de minimis exemption and no risk-based discretion: every client, every update, every time.
| When you must screen | What the law requires |
|---|---|
| At onboarding | Screen every prospective client before any business relationship is established - no exceptions, regardless of the client's nationality, transaction size, or perceived risk level. |
| When transacting | Screen at the time of conducting transactions with existing clients. |
| On TFS list update | Re-screen the entire existing client base against the updated list without delay - the list can change on any day, without warning. |
| On UNSC adoption | UNSC resolutions have immediate effect in South Africa. Institutions must act immediately upon adoption of a new resolution - before the FIC has even updated its website. |
The list can change on any day
The FIC TFS list mirrors live UNSC resolutions covering terrorism, terrorist financing and proliferation financing. New designations take legal effect immediately - a weekly manual check leaves your institution exposed for days at a time.
Full-book re-screening is onerous
A single list change requires re-checking every client, beneficial owner and counterparty. For a book of 5,000 clients, this represents a substantial operational burden - repeated with every update.
No evidence, no compliance
PCC 44A requires records indicating the date of each screening event and its outcome. When the FIC or FSCA inspects, "we screened them" is not sufficient - informal records do not survive an inspection.
Set it once. Compliant on every update.
InTouch's Continuous TFS Screening is a fully automated pipeline - from daily list ingestion to audit certificate delivery - with a paper trail an inspector can verify at a glance.
Daily list synchronisation
Every day, InTouch retrieves the latest TFS list from the FIC - covering both the FIC SA list and the UN consolidated sanctions list simultaneously.
Change detection
The new list is compared against the prior version to identify every new entry, amendment, and de-listing - including new UNSC designations that require immediate action.
Automatic client re-screening
When a change is detected, your full client portfolio is automatically re-screened against the updated list without delay - in compliance with section 28A(3)(c) of the FIC Act.
Match scoring & flagging
Every hit returns the match type (NAME_EXACT or NAME_PARTIAL), a confidence score from 0–100%, the TFS entry name, reference number, source, designated nationality and sanction regime - so your team reviews signal, not noise.
Report delivery
A consolidated screening report identifies all flagged clients, new TFS entries since your last scan, and clients that have been de-listed - so your compliance team can act immediately.
Certificates on demand
Generate a per-client TFS screening certificate - with the client's complete screening history - at any time, for audit trail purposes, FIC inspection readiness, or documentary evidence of ongoing due diligence.
Two authoritative sources. Screened simultaneously.
Screening against both sources provides the fastest possible detection of new designations, and is consistent with good practice guidance in PCC 44A, which recommends institutions also scrutinise against the UNSC consolidated list as a supplementary control.
FIC SA - TFS List
The Financial Intelligence Centre's published TFS list - the primary list that creates legal obligations under the FIC Act. This is the mandatory screening source under sections 26A, 26B and 28A, covering UNSC sanctions regimes relating to terrorism, terrorist financing and proliferation financing.
UN Consolidated Sanctions List
The United Nations Security Council's own consolidated list - the source from which the FIC's TFS list is derived. UNSC resolutions have immediate effect in South Africa upon adoption, so screening against the UN list directly gives your institution early visibility of new designations, before the FIC has updated its website.
What your team stops doing. Permanently.
Manual TFS compliance
- ✕Monitor the FIC website for list updates - every business day
- ✕Compare each new list version against the previous one manually
- ✕Re-run every client, beneficial owner and counterparty by hand
- ✕Build and maintain your own screening evidence records
- ✕Reconstruct history from emails when the inspector arrives
- ✕Rely on staff availability to catch updates that land on weekends or public holidays
With InTouch Continuous TFS Screening
- ✓List synchronised, compared and actioned automatically - 365 days a year
- ✓Entire client base re-screened on every change, with no manual intervention
- ✓Flagged clients delivered with confidence scores and full match detail
- ✓Every check permanently logged with timestamp, source and outcome
- ✓Audit certificates generated in one click, per client, at any time
- ✓Your compliance team focuses on judgement calls - not list administration
Every TFS obligation in the FIC Act. Covered.
This is not partial coverage or best effort. Every screening requirement the Act, PCC 44A and Directive 8 place on accountable institutions is handled by the service - and evidenced.
| Legal basis | Your obligation | How InTouch delivers | |
|---|---|---|---|
| s28A(3) | Screen every prospective client against the TFS list before or at take-on. | Per-client TFS screening triggered at onboarding via portal or API, with a certificate generated as evidence. | ✓ |
| s28A(3) | Screen existing clients when conducting transactions. | Automated portfolio re-screens on your configured schedule, plus on-demand per-client screens at any time. | ✓ |
| s28A(3)(c) | Re-screen all existing clients without delay every time the TFS list changes. | Daily list synchronisation with automatic full-portfolio re-screening triggered on change detection. | ✓ |
| s26A | New UNSC designations take effect in South Africa immediately upon adoption. | Simultaneous screening against the UN consolidated list provides the earliest possible detection of new designations. | ✓ |
| s28A | Screening extends to beneficial owners, representatives, and transaction counterparties. | The service screens direct clients, beneficial owners, authorised representatives and counterparties - the full scope of the s28A obligation. | ✓ |
| s26B | On identification of a designated person or entity, property must be frozen immediately - no FIC consent or court order required. | Flagged-client reports enable immediate compliance action. Certificates serve as evidence of the exact detection date and time. | ✓ |
| s28A | File a Terrorist Property Report (TPR) with the FIC following a confirmed match; file a s29 STR for suspected but unconfirmed links. | Match details, references, sources and confidence scores in each certificate support accurate and complete TPR and STR filing via goAML. | ✓ |
| s42 / RMCP | Screening processes must be documented in your Risk Management & Compliance Programme. | InTouch provides a process description and evidence package suitable for direct inclusion in your institution's RMCP. | ✓ |
| PCC 44A | Records of every screening event - date performed and outcome - must be retained. | Every certificate includes a timestamped screening history log. Every check is permanently recorded. | ✓ |
| PCC 44A | Institutions using a third-party screener must demonstrate the provider's list is kept current without delay. | Daily synchronisation timestamps provide this evidence directly - your accountability obligation, discharged with proof. | ✓ |
| Directive 8 | Prospective and current employees must be screened against the TFS list, with enhanced frequency for senior and key roles. | Individual screening applies equally to employee TFS checks, with the same certificate output as evidence. | ✓ |
Screening frequency, configured to your risk profile
Choose the cadence that matches your institution's risk appetite and compliance programme.
Clients re-screened automatically the moment InTouch detects a change in the TFS list - the most responsive option, ensuring full compliance with the "without delay" obligation in PCC 44A
All clients screened every day regardless of list changes - suited to higher-risk institutions or large, dynamic client bases
Clients screened every week on a nominated day - a strong baseline for low-to-medium risk institutions with stable portfolios
A monthly cycle - appropriate for small or low-risk portfolios where clients are also screened at onboarding and per transaction
Reports built for compliance teams.
Certificates built for auditors and inspectors.
Every document is timestamped, identifies the sources screened and the user who performed the screen, and is permanently logged - designed for FIC and FSCA inspection readiness.
- ✓Client details - name, identity number, date of birth, nationality, and the user who performed the screen
- ✓Screening summary - total checks performed, most recent check date, active TFS flags
- ✓Clear or Flagged status - with each active flag's TFS entry name, FIC reference, source, match type, confidence score and date flagged
- ✓Complete screening history - every event with date, method, sources, match resolution, match count and highest score
- ✓Organisation details - name, registration number, legal name and screened-by user
- ✓Screening summary - total checks performed, latest check date, active TFS flag count
- ✓Clear or Flagged status - the CLEAR certificate confirms screening against all active TFS entity entries (FIC SA and UN) with no matches found
- ✓Date-stamped log of every screening event, source, match resolution and confidence score
Works the way your institution works
InTouch Portal
A secure web-based interface providing direct access to TFS screening, report retrieval and per-client certificate generation. No technical integration required - sign in and screen.
InTouch API
A RESTful API for institutions that wish to integrate TFS screening directly into their own onboarding systems, CRM platforms or compliance workflows. Results and certificates are returned programmatically for full automation.
Third-Party Partners - Iress Xplan
InTouch is available to financial advisers and FSPs using Iress Xplan, enabling TFS screening directly within the Xplan environment. Screen clients and retrieve certificates as part of your existing adviser workflow - no platform switching.
What non-compliance actually costs
Since South Africa's FATF grey-listing, FIC and FSCA enforcement has intensified sharply - and TFS screening failures are among the most commonly cited inspection findings. TFS compliance is under closer scrutiny than at any previous point in the FIC Act's history.
| Risk category | Consequence |
|---|---|
| Criminal liability | Failure to comply with the section 26B freeze obligation is a criminal offence under section 49A of the FIC Act. |
| Administrative sanctions | Penalties of up to R10 million for a natural person and R50 million for a legal entity. Recent enforcement actions in the sector have reached R7.8 million. |
| FSCA enforcement | FSPs are subject to FSCA inspection. TFS screening failures have been among the most commonly cited findings in recent inspection cycles. |
| Reputational damage | Facilitating a transaction for a designated person - even inadvertently - poses severe reputational risk to the institution and its licence standing. |
| FATF grey-listing context | Heightened domestic enforcement continues as South Africa works to exit grey-listing - the supervisory focus on sanctions screening will only increase. |
TFS screening is one obligation. InTouch covers them all.
Continuous TFS Screening sits within a complete FICA compliance ecosystem - so your institution can meet its full suite of FIC Act obligations through one integrated platform, with a single audit trail.
KYC & KYB verification
Individual and company identity verification with document management - the foundation of your CDD obligation.
PEP & adverse media screening
Politically exposed person identification and adverse media checks in addition to every TFS screen.
Risk rating & assessment
Client risk rating tools supporting the risk-based approach your RMCP requires - for everything except TFS, where zero tolerance applies.
RMCP & documentation support
Compliance documentation and process descriptions ready for inclusion in your Risk Management & Compliance Programme.
Regulatory reporting workflow
Structured match evidence that supports accurate TPR and STR filing with the FIC via goAML.
Live in days, not months
Contact InTouch
We discuss your institution type, client volume and risk profile to configure the service correctly from day one.
Configure your screening
Your screening frequency and integration method - Portal, API, Xplan or 3rd party partner - are set up to match your workflow.
Baseline screen
Your client data is loaded and an initial baseline screen is performed across your full book, against both the FIC SA and UN TFS lists.
Continuous protection begins
From this point, your clients are automatically re-screened on every list update, on your configured schedule, and on demand.
Evidence on tap
Reports and per-client certificates are available immediately via the InTouch portal - inspection-ready from your first screening cycle.
Continuous TFS screening, explained
Common questions about how InTouch automates Targeted Financial Sanctions screening under the FIC Act.
Continuous TFS (Targeted Financial Sanctions) screening is the automated, ongoing checking of your entire client base against the FIC Targeted Financial Sanctions list. InTouch synchronises with the FIC TFS list every day, detects every change, and automatically re-screens all of your clients against both the FIC SA list and the UN consolidated sanctions list whenever the list is updated - delivering an audit-ready report to your compliance team the same morning.
Section 28A of the Financial Intelligence Centre Act (FIC Act), amplified by PCC 44A (February 2024), requires accountable institutions to screen clients against the TFS list at onboarding, when transacting, and every time the list is updated. Section 26A gives new UNSC designations immediate effect in South Africa, and section 26B requires a self-executing asset freeze on a true match - with no court order required. Non-compliance is a criminal offence under section 49A, carrying administrative penalties of up to R50 million for a legal entity.
InTouch synchronises with the FIC TFS list daily - 365 days a year. Any list change automatically triggers a full-portfolio re-screen without delay. On top of this baseline, you can configure additional regular screening at your chosen cadence: on every update, daily, weekly, or monthly, matched to your institution's risk profile.
InTouch screens simultaneously against two authoritative sources: the FIC SA TFS list (the mandatory source that creates legal obligations under the FIC Act) and the UN Security Council consolidated sanctions list (an early-detection source, since UNSC resolutions take immediate effect in South Africa upon adoption - often before the FIC has updated its website).
When InTouch detects a change during its daily synchronisation, it compares the new list against the prior version to identify every new entry, amendment and de-listing, then automatically re-screens your full client portfolio against the updated list - in compliance with section 28A(3)(c) of the FIC Act. A consolidated report identifying all flagged clients, new TFS entries and de-listed entries is delivered to your compliance team so freezes can be applied and lifted correctly.
TFS screening is available three ways: through the secure InTouch web portal (no integration required), through the InTouch RESTful API for institutions integrating screening into their own onboarding, CRM or compliance systems, and directly within Iress Xplan for financial advisers and FSPs - screening clients and retrieving certificates as part of their existing adviser workflow.
Every screening cycle produces a timestamped report and per-client TFS screening certificates. Each certificate records the client details, sources screened (FIC SA and UN), clear or flagged status with match type, FIC reference and confidence score, and a complete date-stamped screening history. Every check is permanently logged with timestamp, source and outcome - providing the records that PCC 44A requires and demonstrating that a third-party screener's list is kept current without delay.
Let's talk automation.
Have questions or want to see how Intouch can work for your team? Drop us a message.
Fully automated TFS compliance, from day one.
Join the accountable institutions that have automated their sanctions screening with InTouch. Your full client base receives a baseline screen on day one, with continuous monitoring from that point forward.
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