Sanctions and PEP screening for South Africa: the FIC's sanctions list, the 5-day terrorist property report and sections 21F to 21H.
Screen against the FIC's targeted financial sanctions list and the UN 1267 list, uploaded by your team or synced from a commercial provider, with fuzzy matching across scripts and spellings. A PEP hit starts an enhanced due diligence review in case management, and every list is versioned, with freshness dashboards showing that screening ran on current data.
South Africa's rules in brief.
- Sanctions lists
- The targeted financial sanctions list maintained by the FIC, and the UN Security Council Resolution 1267 list
- Terrorist property report
- Section 28A, for a party matching either list: no later than 5 days (excluding weekends and public holidays) after the institution establishes it holds the property, unless the FIC approves a later date
- Filing
- On the FIC's goAML portal. Since 1 July 2026, regulation 22(1) requires reports under sections 28, 28A, 29 and 31 to follow the FIC's format and to be sent electronically
- Sanctions breaches
- A possible breach of the section 26B sanctions prohibitions also falls under the section 29 suspicious and unusual transaction duty
- PEP categories
- Foreign politically exposed persons (s.21F), domestic politically exposed persons and prominent influential persons (s.21G), and their family members and known close associates (s.21H)
- Prominent influential persons
- Kept separate from politically exposed persons in Schedule 3C, which the General Laws Amendment Act 22 of 2022 added along with the definition
- Beneficial owners
- Identified, with reasonable steps to verify them, for legal persons, trusts and partnerships (s.21B)
- Prudential Authority
- Expects banks and life insurers to use sanction-screening tools, and to screen all cross-border payments before the funds are released
- Inspection findings
- A bank's screening system did not alert on certain altered UN 1267 names, and new life-insurance clients had not been screened against the FIC's list (PA communications, 2025)
Checked against primary sources on 1 October 2026.
What South Africa requires, and how the module handles it
In South Africa the screening duties come from the FIC Act's terrorist property and PEP provisions, read with the Prudential Authority's directives and inspection findings. Below, each duty with its source, and the screening feature that supports it:
| What South Africa requires | Where it sits | How the module handles it |
|---|---|---|
| Find clients who match the FIC's targeted financial sanctions list or the UN 1267 list | FIC Act s.28A; PA Communication 2 of 2025 | Upload the FIC's list as one you maintain yourself, beside lists synced from commercial providers. Freshness and coverage dashboards confirm screening ran on current data, not a stale copy. |
| Report a match as a terrorist property report within 5 days, excluding weekends and public holidays | s.28A; Regulations, reg 24(1) | Every list is versioned, and each decision on a match sits in an append-only audit log. The report itself is filed on the FIC's goAML portal. |
| Alert on altered spellings of listed names, not only exact ones | PA Communication 1 of 2025 (inspection finding) | Locale-aware fuzzy matching compares names across scripts and spelling variants, and the match-scoring engine lists the top three reasons for every hit. Try it on altered names from the 1267 list in a demo. |
| Identify foreign and domestic politically exposed persons, prominent influential persons, and their family members and known close associates | FIC Act ss.21F–21H; Schedule 3C | A hit on PEP data pushes up the customer's risk rating and starts an enhanced due diligence review in case management, with later reviews set by risk band. |
| Identify the beneficial owners of legal persons, trusts and partnerships, and take reasonable steps to verify them | s.21B | Screening reaches the people behind a corporate client, not just its registered name, through entity resolution and the beneficial-owner graph in the case workbench. |
| Keep records for at least five years after the relationship ends or the transaction concludes | s.23 | Every cleared look-alike carries a recorded reason in the false-positive workflow, so dispositions stay consistent and reviewable and are not redone each time a list changes. |
Summaries of the primary texts as checked on 29 and 30 September and 1 October 2026: the FIC Act, the Money Laundering and Terrorist Financing Control Regulations, the General Laws Amendment Act 22 of 2022, PA Insurer Directive ID1/2022 and the Prudential Authority's 2025 AML/CFT/CPF communications. Not legal advice.
Frequently asked questions.
Which sanctions lists do South African accountable institutions screen against?
The targeted financial sanctions list maintained by the FIC and the UN Security Council Resolution 1267 list. A client who matches either is reported to the FIC as a terrorist property report under section 28A. In its 2025 findings on life insurers, the Prudential Authority recorded new client relationships that had not been screened against the FIC's list.
What is the deadline for a terrorist property report?
As soon as possible, and no later than 5 days after the institution establishes that it holds property associated with terrorist and related activities, unless the FIC approves a later date (regulation 24(1)). Saturdays, Sundays and public holidays are not counted. The report is filed on goAML.
Who is a prominent influential person?
A category section 21G of the FIC Act names alongside domestic politically exposed persons. The General Laws Amendment Act 22 of 2022 inserted the definition and placed these persons in a new Schedule 3C, separate from politically exposed persons. Family members and known close associates are covered by section 21H. Read Schedule 3C itself for the positions it lists before you set up your PEP data.
Do life insurers have to screen policy beneficiaries?
Under the Prudential Authority's Insurer Directive ID1/2022, a life insurer obtains identification particulars when a beneficiary is named or changed, risk-assesses and verifies a named beneficiary before pay-out (surrenders included), takes reasonable measures to find out whether the beneficiary or its beneficial owner is a politically exposed person, and must consider screening beneficiaries against targeted financial sanctions lists.
Can a sanctions breach also need a suspicious transaction report?
Yes. Section 29 covers what a person knew, suspected or ought reasonably to have known or suspected, and that includes possible breaches of the section 26B sanctions prohibitions. The report goes to the FIC within 15 days, excluding weekends and public holidays, of becoming aware of the facts, and tipping off is prohibited.
Does the software freeze or block a client's property?
No. Blocking or freezing happens in your own core banking, policy or wallet system. The module's part is the match: it scores the hit, gives the reasons and stores the analyst's decision in an append-only audit log, and every list it screens against is versioned.
See it on your own data.
Bring your own customers and scenarios to a live demo of the AML compliance software, set up for the country you report in.