Employee screening is an essential requirement under the Financial Intelligence Centre Act (FIC Act) and is one of the key measures evaluated during regulatory inspections. Accountable institutions must integrate employee vetting into their Risk Management and Compliance Programme (RMCP). Under the FIC Act, institutions must actively ensure that employees are competent, trustworthy, and not a source of financial crime risk.

What the FIC Act requires

Your RMCP must include detailed processes for screening both prospective and current employees, covering:

1. Competence and integrity checks

Institutions must verify that employees are fit and proper by confirming:

Qualifications and experience
Employment history
Criminal background
Potential involvement in financial crimes or AML-related misconduct

2. Sanctions List Screening

Existing Employees as well as prospective employees must be screened against the FIC’s Targeted Financial Sanctions (TFS) list.

3. Recordkeeping

FICA requires accountable institutions to keep evidence of all screening activities. Auditors and regulators may request proof that specific employees were vetted.

4. Re-screening

Screening is not a once-off exercise. Employees must be re-screened on a risk based approach at intervals defined by their risk level (low, medium or high risk) and when new adverse information arises.

ClientScanner and employee screening

ClientScanner reflects FICA-aligned screening practices, helping institutions maintain accuracy, consistency, and proper documentation throughout the entire employee lifecycle.

Here’s what ClientScanner can help with:

TFS Screening for Clients and Employees

ClientScanner screens individuals across sanctions lists, PEP databases, and adverse media sources and provides a full profile for onboarding or ongoing monitoring.

Daily sanctions monitoring

ClientScanner automatically checks employee profiles against the UN sanctions list every day. You will be alerted immediately if someone appears on the sanctions list.

Re-screening

ClientScanner recently launched automated re-screening notifications based on your subject’s next review date. Each subject’s next review date is set according to their risk level. This applies to business relationships and employees.

The system runs weekly and alerts you on the Dashboard and Notifications panel when subjects are overdue or due soon for a FICA review. A new “Due for FICA Review” list enables you to view and export all such subjects to an Excel sheet.

Identity and document verification

From ID photo verification to address retrieval and optional liveness checks, ClientScanner helps you confidently verify identity and prevent impersonation or fraud.

Automated risk scoring

Its built-in risk matrix allows you to generate FICA-aligned risk ratings for both clients and employees instantly, based on factors such as adverse news, PEP exposure, or high-risk jurisdictions.

Records and reports

Export organised employee lists or reports at any time for audits or FIC inspections.

Compliance documentation and RMCP support

ClientScanner also offers a FICA RMCP template, guidance on customisation, and optional annual FICA monitoring, which is ideal for institutions needing structured, ongoing compliance support.

The importance of employee screening under the FIC Act