A South African financial services provider needed FICA beneficial ownership declarations from clients who had never submitted them. This is what was asked for, what we proposed instead, and what the difference turned out to be worth. The client is unnamed because the lessons apply widely.
The obligation, briefly
Under FICA, a financial institution must establish who ultimately owns and controls each of its clients. For an individual that is largely a matter of confirming identity, while for a company or trust it means tracing ownership through to the actual people behind it. After South Africa was grey-listed, the 2022 amendments put real inspection pressure behind these records. An institution with a back book of clients who never completed a declaration has a compliance gap that grows more expensive to ignore every year.
The ask, and what we proposed instead
The brief was modest: reach the non-compliant clients, and give them a place to upload a completed PDF declaration. To see why that seemed like enough, look at what the existing process asked of a client. They had to download the form, print it, complete it by hand, sign it, scan it, and send the result back, along with the documents that have to accompany a declaration. An upload button would at least have given all of that paper somewhere to go.
We proposed going further, because an upload button digitizes the filing cabinet rather than the process. The client would still face the same print-sign-scan round trip, which is where declarations were going to die, and the compliance team would still open, read, check, and retype every scan that survived it. So we suggested digitizing the entire journey: the declaration itself as an online form, and the outreach as a managed campaign rather than a mailshot.
What we built
Two declaration forms, because the two kinds of client have little in common. A natural person confirms their own details in a few minutes. A juristic client, a company or trust, works through its ownership step by step until the form reaches the people behind the structure. Each form asks its questions in plain language rather than statutory wording, checks answers as they are entered, and delivers the completed declaration as structured data instead of a scan waiting to be retyped. Uploading survived where it belongs, because a declaration travels with a set of supporting documents, and the form collects each one at the step it relates to rather than as a loose pile of attachments.
Reaching the clients was the other half of the build. We created and flighted separate email campaigns for natural and juristic clients, since a shareholder register request reads very differently from a personal details confirmation. The campaigns monitored engagement, tracking who opened, who clicked, and who completed, and sent follow-up emails to those who stalled. Chasing, which had been a manual task the compliance team could never keep up with, became something the system did on schedule.
Delivery, honestly
The campaign ran for nine months and reached 8,200 clients. Because each declaration arrived as checked, structured data rather than a scan, the compliance team saved up to four hours of processing per submission. The stubborn tail is human: some clients respond only to a phone call, and a campaign narrows that list rather than removing it.
What we would tell you
- Question a brief that asks for an upload button. It moves the paper problem online while leaving the reading, checking, and retyping exactly where it was.
- Natural and juristic clients need separate journeys. One form serving both ends up interrogating individuals and under-serving companies, and the same goes for the emails that bring them there.
- Reaching non-compliant clients is a campaign discipline. Engagement tracking and automatic follow-ups collect more declarations than any redesign of the form itself.
- Keep statutory wording off the client’s screen. Clients know who owns their company long before they know what the Act requires, so the form must translate between the two.
Facing the same obligation, or the same filing cabinet? Tell us what’s on fire