FICA Ongoing Due Diligence: Using the Government Gazette to Keep Customer Records Current

Ongoing due diligence is a monitoring problem, not an onboarding problem

Most accountable institutions have onboarding under control. Identity is verified, documents are collected, screening runs, and the file is opened. The harder obligation is what comes next: keeping that customer information current for the life of the relationship.

The Financial Intelligence Centre Act (FICA) requires accountable institutions to conduct ongoing due diligence on business relationships — monitoring transactions and keeping customer due diligence information accurate and up to date, rather than treating verification as a once-off event at account opening. In practice, that means an institution must be able to answer a supervisor's question: when this customer's circumstances changed materially, how did you find out, and what did you do?

South Africa exited the FATF grey list on 24 October 2025, 32 months after being listed in February 2023. The exit was granted on the basis that reforms were sustainable — which means supervision has not relaxed. The FIC and the FSCA have signalled continued intensified supervision, and the FATF framework requires ongoing demonstration of effectiveness through investigations, sanctions and enforcement outcomes. Delisting removed a reputational drag. It did not remove a single obligation.

What the Government Gazette actually tells a compliance team

The South African Government Gazette is published weekly, on Fridays, and carries statutory notices that are, in compliance terms, hard status-change signals about individuals and legal entities. The categories that matter most to a bank or FSP are:

• Deceased estate notices — the section 29 notice to creditors under the Administration of Estates Act 66 of 1965, and the later section 35 notice that the liquidation and distribution account lies open for inspection
• Sequestrations — voluntary surrender and compulsory sequestration notices under the Insolvency Act 24 of 1936
• Company liquidations and business rescue notices
• Sales in execution of immovable and movable property
• Curator and administrator appointments
• Name changes — relevant to identity matching and screening hygiene

Each of these is a documented, dated, publicly published event tied to a named person or entity — often with an ID number, estate number or company / CK registration number attached. That combination is what makes the gazette useful as a compliance data source: it is authoritative, it is timestamped, and it is matchable to your customer master file.

Why these events are CDD events

A customer who has died, been sequestrated, been placed under curatorship, or whose company is in liquidation or business rescue is no longer the customer you risk-rated at onboarding. The change affects:

• Legal capacity and mandate. Who may now operate the account — an executor, a trustee, a curator, a business rescue practitioner? Continuing to act on the original mandate after a sequestration or death is a control failure.
• Risk rating. Insolvency, curatorship and estate events are material inputs to a risk profile and may warrant enhanced due diligence.
• Credit and collections exposure. Under the National Credit Act, and for anyone collecting under the Debt Collectors Act, continuing to pursue a debtor whose estate has been sequestrated or who has died is both commercially futile and conduct risk. Claims belong in the insolvent estate or the deceased estate, lodged within the statutory windows.
• Record accuracy. FICA's ongoing due diligence duty is precisely about the accuracy of the information you hold.

Building the gazette into a monitoring control

The failure mode most institutions fall into is treating the gazette as something you consult reactively, when a payment bounces or a branch flags something. Used properly it is a scheduled, evidenced control that runs on the gazette's own weekly cycle.

1. Periodic screening of the customer base

Run your customer identifiers — ID numbers for natural persons, registration or CK numbers for entities — against the gazette index on a defined cadence. Gazette Search indexes more than 900,000 notices dating back to 2004 and supports search by ID number, name, estate number, company (CK) number, and deep full-text search across notice bodies. Bulk upload handles up to 100,000 identifiers in a single batch, with CSV export and an API so results can be pushed straight into a case management or core banking workflow rather than re-keyed.

ID-number matching is the point here. Name-only screening on a South African customer book generates false positives at a rate that destroys the control's credibility; matching on ID or registration number produces findings an analyst can act on the same day.

2. Continuous monitoring on high-risk and high-exposure accounts

Batch screening every quarter is a floor, not a ceiling. For customers where the exposure justifies it — large facilities, guarantors, directors of borrowing entities, politically or commercially sensitive relationships — add the identifier to a watchlist with email alerts. The gazette publishes on Friday; the alert reaches the responsible officer in the same cycle, which is materially faster than waiting for the next quarterly sweep or for the customer to tell you.

3. Resolving the appointed professional

Once a hit lands, the next question is operational: who do we now deal with? The Find-a-professional directory indexes executors, trustees, liquidators and sheriffs, and executor contact details are surfaced alongside the notice record. That closes the gap between "our customer's estate has been sequestrated" and "here is the trustee we must lodge with and correspond through."

4. Keeping the audit trail

Supervisors do not credit controls that cannot be evidenced. Group notices, searches and correspondence for a single customer event into a case, so the file shows the notice, the date it published, the date you detected it, the action taken, and the professional you engaged. That sequence — publication, detection, action — is exactly the narrative an inspection asks for.

The cost argument, plainly

Compliance monitoring usually fails on unit economics rather than on principle. Manual per-search legal or data lookups through traditional channels can run R500 or more per enquiry, which makes book-wide screening unaffordable and turns the control into a token exercise on a handful of accounts.

Gazette Search runs on prepaid credit packs at one credit per search, regardless of how many results that search returns:

• Free tier: 5 free searches — a search returning no result does not use one up
• Single: R35 per search
• Starter: 100 credits for R1,000 (R10 per search)
• Pro: 2,500 credits for R15,000 (R6 per search)
• Bulk tiers (Business, Bulk, Volume) run down to R0.55 per search, billed per record submitted, hit or miss

On the free tier and the Single through Pro packs, a search that returns no result is not charged — you pay for successful searches. Credits remain valid for 12 months, and auto-refill carries a 10% discount. For a compliance function, that pricing changes what is possible: screening a 20,000-name book stops being a budget submission and becomes a line item.

A control you can hand to an auditor

Summarised, the ongoing due diligence control looks like this:

1. Define the population — all active customers, with ID or registration numbers, plus related parties where risk warrants.
2. Set the cadence — batch screening monthly or quarterly, sized to your risk appetite and documented in policy.
3. Screen on identifiers, not names, using bulk upload and API where volume justifies it.
4. Watchlist the exposures that cannot wait for the next batch, and route Friday alerts to a named owner.
5. Triage each hit — confirm the match, classify the event (death, sequestration, liquidation, business rescue, curatorship), and update the risk rating and mandate.
6. Identify the appointed professional and lodge or correspond within the statutory window.
7. Record everything in a case file, with dates, so detection lag is measurable and defensible.

The gazette is not a substitute for transaction monitoring, sanctions screening or adverse media. It sits alongside them, covering a category those tools handle poorly: formal legal status changes, published by the state, on a predictable weekly schedule.

Frequently asked questions

Does FICA require ongoing due diligence, or is verification at onboarding enough?

FICA requires accountable institutions to conduct ongoing due diligence on business relationships, which includes monitoring transactions and keeping customer due diligence information current — not only verifying identity at onboarding. Institutions should be able to show a supervisor how they detect material changes in a customer's circumstances and what action followed. The specific scope and frequency should be set in your own Risk Management and Compliance Programme.

Did South Africa's FATF grey list exit reduce compliance obligations?

No. South Africa was removed from the FATF grey list on 24 October 2025 after addressing all 22 action plan items, but the removal was granted on the basis that the reforms are sustainable. The FIC and FSCA have indicated continued intensified supervision, and the FATF framework requires ongoing demonstration of effectiveness through enforcement outcomes. Statutory obligations under FICA are unchanged.

Which Government Gazette notices matter most for customer due diligence?

The highest-value categories are deceased estate notices under the Administration of Estates Act 66 of 1965, sequestration notices under the Insolvency Act 24 of 1936, company liquidations and business rescue notices, curator and administrator appointments, sales in execution, and name changes. Each records a legal status change affecting capacity, mandate and risk rating. All are published in the weekly Friday gazette.

Can we screen an entire customer book against the gazette?

Yes. Gazette Search supports bulk upload of up to 100,000 identifiers in one batch, with CSV export and an API for integration into existing compliance workflows. Screening on ID numbers or company registration numbers rather than names substantially reduces false positives on a South African book. Bulk tiers are billed per record submitted and run down to R0.55 per search.

How quickly will we know if a customer is sequestrated or has died?

The Government Gazette is published weekly on Fridays. If the customer's identifier is on a watchlist with email alerts, the responsible officer is notified in the same publication cycle rather than at the next scheduled batch screen. For lower-risk accounts, a monthly or quarterly batch sweep is usually proportionate — the cadence should be set and documented in policy.