Screening clients against sanctions lists

How a South African accountable institution should screen clients and related parties against sanctions lists, given that Achekam runs no screening.

By Achekam · 11 October 2026 · 4 min read · For Accountants & audit firms in South Africa

Most accounting practices that do company or trust work have never found a sanctioned person among their clients, and that is exactly why screening slips. It feels like a formality. Then a new client arrives through a referral: a holding company with a foreign shareholder, a trust with beneficiaries in several countries. The partner signs the acceptance form, nobody checks the names, and the firm has no way of knowing whether it has just begun acting for a listed person.

For a firm that is an accountable institution, screening is not an optional extra. It is the step that makes one of the FIC's reporting duties possible at all, and in Achekam it is a step the firm must perform and record itself.

Why screening matters: terrorist property reports

The Financial Intelligence Centre says a terrorist property report must be filed where a party to a transaction matches the targeted financial sanctions list or the UN Security Council Resolution 1267 list. The FIC refers to Guidance Note 6A for the detail.

That duty cannot be met without knowing whether anyone the firm deals with is on those lists. A firm that never screens has no way to detect a match, and therefore no way to report one. The FIC's page on reporting obligations sets out the terrorist property report alongside the cash threshold and suspicious transaction reports, and is the place to start when writing the firm's screening procedure.

Screening also feeds the suspicion-based reports. The FIC says accountable institutions must report transactions that are unusual or arouse suspicion of money laundering or terrorist financing, as a suspicious transaction report if completed or a suspicious activity report if not. A near-match on a sanctions list, or a client who is evasive about who owns it, may be the thing that raises that suspicion. The reports themselves are covered in FIC cash threshold and suspicious transaction reports.

Which firms this applies to

The duty attaches to accountable institutions. For an accounting practice the usual route in is item 2: the FIC lists as an accountable institution anyone who carries on the business of helping clients plan or carry out the creation, operation or management of a company or close corporation. The FIC directs trust and company service providers to PCC 53 on Risk Management and Compliance Programmes, which is where the firm's screening approach should be written down as part of its wider programme.

Who and when to screen

Screening only the client entity misses most of the risk. A useful scope for an accounting practice:

Timing matters as much as scope. Screen at acceptance, before the firm begins acting. Screen again at each continuance review. Screen when a new director, owner, trustee or beneficiary appears. And screen the whole client base again when the lists change, because a person who was clear last month may be listed this month.

What Achekam does not do

It is important to be clear about this, because firms often assume their practice software covers it. Achekam does not screen prospects or clients against sanctions or PEP lists. On a prospect's profile, the screening row always reads NOT RUN. A person's PEP or sanctions status in Achekam is only what staff record.

Achekam also does not keep client compliance profiles such as FICA documents, AML risk ratings or PEP screening results. Its Compliance Profiles page says so, and lists only clients missing a registration number or an income tax number.

So the screening itself happens outside Achekam, against current copies of the lists obtained from their official sources, or through a screening service the firm chooses. What Achekam can hold is the decision that follows.

Recording the outcome on the acceptance review

In Achekam, a firm can record a client acceptance review after a conflict check against its own clients and contacts, and only a signed-in partner can approve it. Customer due diligence in that review is a tick-box confirmation by the preparer; Achekam runs no automatic FICA, CIPC or sanctions check.

That tick-box is only as good as what stands behind it. Before ticking, the preparer should be able to point to a screening record showing:

1. Who was screened: every party in scope, by full name and, where available, identity number and date of birth.
2. Against what: the targeted financial sanctions list and the UN 1267 list, with the date or version of each.
3. When: the date of the screening.
4. The result: no match, a possible match resolved as a false positive with reasons, or a match.
5. Who did it and who reviewed it.

Refer to that record in the acceptance review, so the approving partner can see that screening was done and where the evidence is. A true match stops the acceptance and goes straight to the person responsible for FIC reporting. The wider acceptance process, including the conflict check, is covered in client acceptance and the conflict check.

Possible matches

Most hits are false positives: a common name, a different date of birth. Resolve each one on evidence, record why it was cleared, and have a second person review the conclusion. Never clear a possible match because it is inconvenient, and never leave one unresolved while the firm continues to act.

List every active client of the firm's company and trust work, with its directors, owners, trustees and beneficiaries. Screen them all against the current lists this month, record the results in the form above, and then add screening to every acceptance and continuance review from now on.

General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.