6 practical FICA compliance training tips for financial institutions

Earlier in November 2025, the South African Reserve Bank announced that it would impose administrative sanctions on two finance companies for failing to comply with the Financial Intelligence Centre Act (FICA).

The greater of the two penalties, a R3 million fine, was imposed on Discovery Bank for failing to report 24 suspicious transactions on time. The other case saw eZI Remit (formerly Ezaga Remit (Pty) Limited) getting a warning for weaknesses in its FICA-related control measures.In both instances, the companies were reprimanded because their staff weren’t given adequate FICA compliance training.

In the case of Discovery Bank, it was highlighted that 84 out of 155 new employees had not received training within 30 days of being appointed; 47 out of 109 of its employees had not received annual refresher training within a period of a year; and two out of six of its senior management had not received training within 30 days of being appointed.If anything, these two cases are a clear signal of South Africa’s tightening stance on financial crime.

These incidents also showcase that accountable institutions must see people as the frontline of defence.Below are six practical, actionable training tips and tricks for accountable institutions to ensure that teams understand the law and that compliant behaviour is embedded into daily operations.

#1 Design your training thoughtfully

Remember that training is something your team must fit in on top of their other responsibilities, so keep sessions short and focused. Avoid long lectures, slide-heavy presentations, and lengthy manuals; too much content at once can be overwhelming. Modules that are 10-15 minutes are ideal. To keep content relevant, tailor it to each team’s compliance requirements. For example, onboarding teams need to know all the ins and outs of Customer Due Diligence (CDD) and Know Your Customer (KYC) checks, and sales teams should understand how to explain why documents are required without making clients feel like you don’t trust them.

#2 Be clear about the realities

To help staff apply the right rules in the right contexts, move away from theory and share real-world scenarios. For example, what your team should do if a client refuses to provide proof of address, or how to respond if a long-standing client suddenly starts making unusual cash transactions. Highlighting scenarios will help staff to better recognise red flags. As part of this, it is important to clearly spell out the risks organisations face for non-compliance, including financial penalties and reputational harm, as well as potential business disruptions.

#3 Consider compliance cheat sheets

It’s helpful to create compliance checklists and cheat sheets that are easily accessible and simple to digest, so your teams can refer back to them as needed. This could include a document verification checklist or lists of high-risk customer indicators and examples of suspicious and unusual transactions. Many training gaps stem from staff not knowing what to say when compliance checks are questioned, but having a few simple scripts to use in response to queries makes it easier for them to stand their ground. Some good examples could include:

• “FICA helps us verify who we are dealing with. It ensures we comply with the law and helps prevent criminal activity from entering the financial system.”
• “We do this not just because it’s required by law, but because it helps prevent fraud, identity theft, and financial crime. It’s in everyone’s best interest.”
• “By following FICA, we make sure your account is secure and that we’re dealing with legitimate customers only.”

#4 Run training sessions regularly

FICA compliance changes often, which is why short, quarterly refreshers are a must. Not only does this keep compliance top of mind, but it also reinforces key behaviours and provides a space to outline new regulatory updates. In addition, you should consider running regular mock exercises and spot checks to boost your team’s confidence in handling situations before they need to do so in real life. Staff often think of FICA as only important during the onboarding process. Training should emphasise the value of ongoing due diligence.

#5 Get senior leaders involved

Culture starts at the top. If senior leaders are seen attending and participating in training, this signals that compliance is important. Where this isn’t possible, something as simple as featuring senior leadership in a short intro video shows your employees that everyone is accountable.

#6 Prioritise psychological safety

Employees need to feel comfortable asking questions, admitting when they don’t understand something, and reporting red flags without fear of blame or punishment. When staff feel safe to speak up, they are more likely to escalate suspicious activity, question unusual customer behaviour, or highlight gaps in processes.

As part of compliance training, take time to reinforce that mistakes should be reported promptly and that no one will be punished for reporting concerns. This reduces silent non-compliance.As financial crime increases and criminals become more sophisticated, accountable institutions need all the help they can get to better detect, prevent, and report suspicious activities. Not only do automated compliance tools make it easier to meet regulatory obligations, but they also free up staff to learn more about what’s out there and, in doing so, stay one step ahead of financial crime.

* Kumandan is the MD of SW360.

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