A common misconception is that FICA compliance obligations end after a customer is onboarded. This is not the case. FICA treats compliance as an ongoing process and it requires Accountable Institutions to keep their customer information current and to re-check customers for financial crime risk throughout the life of the relationship. For a business with hundreds, thousands, or millions of customers, doing this manually is simply not feasible.

This is precisely the problem that bulk services are designed to solve. This guide explains what FICA requires for customer re-screening, how often it must be done, and how ThisIsMe's bulk services allow businesses to meet those obligations across their entire customer base efficiently and cost-effectively.

For a foundational explanation of why ongoing monitoring matters, refer to our guide: Once-Off AML Screening vs Continuous AML Monitoring: What's the Difference?

What is Re-Screening and Why Does FICA Require It?

Re-screening is the process of re-checking existing customers against financial crime risk indicators after they have been onboarded. It exists because a customer's risk profile is not fixed. An individual who presented no risk at onboarding can, at any time afterwards, be added to a sanctions list, become a Politically Exposed Person, appear in adverse media, or otherwise change in a way that affects the risk they pose.

The Financial Intelligence Centre Amendment Act (FICA) requires Accountable Institutions to conduct ongoing due diligence, which includes keeping customer information up to date and monitoring the relationship for changes in risk. In practical terms, this means periodically re-screening customers to confirm that the information held about them remains accurate and that no new risk has emerged. Life happens continuously and risk evolves: an existing client may be placed under sanction, may take up a senior government position that makes them a Domestic Politically Exposed Person, or may form a close association with a PEP. Without re-screening, a business would remain unaware of any of these changes. For an explanation of which businesses carry these obligations, refer to our guide: What is an Accountable Institution? FICA Obligations Unpacked.

How Often Must You Re-Screen Your Customers?

A common question is how frequently re-screening must take place. FICA does not prescribe a single universal interval. Instead, under South Africa's Risk-Based Approach, the frequency of re-screening is determined by the risk profile of the customer and set out in the institution's own Risk Management and Compliance Programme (RMCP). This principle is reflected in the FIC's Guidance Note 7A, which took effect on 13 February 2025 and governs the RMCP requirements.

In practice, the frequency of review is calibrated to risk. Lower-risk customers are reviewed less frequently, often every two to three years. Medium-risk customers are reviewed periodically. Higher-risk customers, including foreign PEPs, require continuous or detailed monitoring, frequently reviewed at least annually. Sanctions screening warrants particular attention, because the FIC expects screening to take place not only at onboarding but also whenever the United Nations Security Council adopts new targeted financial sanctions, which can happen at any time.

Many businesses adopt a regular re-screening cycle, such as screening their entire customer base against updated PEP and sanctions data every three or six months, as a practical and defensible way of ensuring that customer information never becomes significantly outdated. The right interval for any given business should be documented in its RMCP and applied consistently. For guidance on handling higher-risk customers specifically, refer to our guide: How to Conduct Enhanced Due Diligence on High-Risk Clients in South Africa.

What Should You Re-Screen For?

Effective re-screening covers the risk indicators most likely to change over time. The core checks include PEP status, to detect a customer who has become politically exposed since onboarding, sanctions screening, to detect a customer who has been added to a sanctions or watchlist, and adverse media screening, to detect negative news indicating an emerging financial crime risk. These three checks form the backbone of AML re-screening. For a detailed explanation of each, refer to our guide: What is AML Screening? PEP, Sanctions & Adverse Media Explained.

Beyond AML, re-screening can also confirm that other customer information remains current. Vital status confirmation detects whether a customer is still living, which is important for preventing fraud on accounts of deceased persons. Address verification can ensure that a customer's residential address and other contractibility information is up-to-date. Bank account verification confirms that account details on record remain valid and correctly owned. For business customers, company and director information can be re-verified to detect changes in ownership or control.

The Challenge: Re-Screening at Scale

The difficulty with re-screening is rarely the individual check, but rather the sheer volume. Screening one customer is straightforward. Screening an entire base of tens of thousands or hundreds of thousands of customers, repeatedly, on a defined cycle, is a substantial operational undertaking that manual processes cannot handle efficiently. This is the point at which many businesses fall short of their ongoing monitoring obligations, not because they lack the intent to comply, but because they lack a practical way to re-screen at scale.

How Bulk Services Solve the Re-Screening Challenge

ThisIsMe's bulk services are designed specifically to address the challenge of re-screening large customer bases. Rather than checking customers one at a time, bulk services allow a business to submit its entire customer dataset and run the selected checks across all of it in a single operation.

The process is straightforward. A business selects which services and verifications it wishes to run, such as AML risk screening, vital status confirmation, or bank account verification, and submits its customer dataset. ThisIsMe's dedicated Batch Handler then securely processes the data and returns the results. This allows a business to re-screen its whole customer base against up-to-date PEP, sanctions, and other risk data at whatever interval its RMCP requires, turning what would be an impractical manual exercise into a single, repeatable workflow. Bulk services are available to all clients other than those on prepaid plans, and they are purpose-built for FICA's ongoing monitoring and bulk KYC workflows.

Which Bulk Services Support Re-Screening Compliance?

Several bulk services offered by ThisIsMe map directly onto the re-screening obligations that FICA imposes.

• Bulk AML Risk Screening is the central re-screening service. It screens an entire customer base against PEP, sanctions, and adverse media data, identifying any customer whose risk status has changed since they were last screened. Running this check at regular intervals is the most direct way to satisfy the ongoing AML monitoring obligation.

• Bulk Live IDV, including vital status confirmation and cache refresh, keeps identity information current across the customer base and detects changes such as a customer becoming deceased. Bulk Bank AVS re-verifies that the bank account details held for customers remain valid and correctly owned, which supports both fraud prevention and accurate record-keeping. For a detailed explanation, refer to our guide: What is Bank AVS? How Account Verification Prevents Fraud.

• For business customers, Bulk KYB services, including Company Search and Director Lookup, allow a business to re-verify the registration, status, and directorship of its corporate clients, detecting changes in ownership or control that may affect risk. Additional bulk services, such as address search, forensic assessment, and driver's licence checks, allow businesses to refresh other categories of customer information as their risk framework requires.

How to Set Up a Re-Screening Cycle with Bulk Services

Establishing a compliant re-screening cycle using bulk services can be broken down into a clear sequence of steps.

Step 1: Define Your Re-Screening Policy in Your RMCP

Begin by documenting your re-screening approach in your regulator-approved RMCP, including which customer segments are re-screened, which checks are applied to each, and at what frequency. This documentation is what demonstrates to the FIC that your ongoing monitoring is deliberate and risk-based rather than ad hoc.

Step 2: Segment Your Customer Base by Risk

Group your customers according to their risk rating, so that higher-risk customers can be re-screened more frequently and more thoroughly than lower-risk customers. This proportionate approach is both compliant and efficient, concentrating effort where the risk is greatest.

Step 3: Select the Services to Run

Choose the bulk services appropriate to each segment. For most businesses, bulk AML risk screening will be the core check applied across the entire base, supplemented by vital status, bank AVS, or KYB checks as the risk framework requires.

Step 4: Submit Your Dataset at Defined Intervals

Submit your customer dataset to ThisIsMe's Batch Handler at the intervals set out in your RMCP, for example every six months for AML re-screening. Because the process runs across the whole base in a single operation, re-screening a large customer base becomes a routine, scheduled task rather than a major project.

Step 5: Review and Action the Results

When the results are returned, review any customer whose status has changed. A new PEP match should trigger Enhanced Due Diligence, a sanctions match should trigger immediate escalation, and any material change should be assessed and actioned according to your RMCP. Any suspicious activity identified must be reported to the FIC, and any cash transaction exceeding R49,999 requires a Cash Threshold Report.

Step 6: Retain Records of Every Re-Screening

Retain a complete record of each re-screening exercise, including the checks run, the date, and the outcomes. FICA requires customer due diligence records to be kept for at least five years, and a documented re-screening history is essential evidence of ongoing compliance during a FIC audit.

The Cost Advantage of Bulk Re-Screening

Beyond the compliance and efficiency benefits, bulk re-screening offers a significant cost advantage through economies of scale. ThisIsMe's bulk services are priced on a volume-tiered basis, which means the per-check cost decreases as the size of the dataset increases. A business re-screening a large customer base therefore pays a lower rate per check than it would for individual verifications, making comprehensive, regular re-screening not only compliant but cost-effective. This tiered model directly rewards the kind of large-scale, whole-base re-screening that FICA's ongoing monitoring obligation calls for.

Re-Screening and Bulk Services Solutions for South African Businesses

As South Africa's leading provider of world-class KYC, AML screening, and due diligence solutions, ThisIsMe gives businesses the tools they need to meet FICA's ongoing monitoring obligations across their entire customer base. Our bulk services allow you to select the verifications you need, from AML risk screening to vital status, bank AVS, and KYB checks, and run them across your whole customer base in a single, secure operation, at whatever interval your RMCP requires. Combined with volume-tiered pricing that makes large-scale re-screening cost-effective, our bulk services turn FICA's re-screening requirement into a simple, repeatable workflow. To experience our full suite of bulk services and find out how we can serve your business, contact our team here.