Explainer · Illustrative scenario

How Fintegris is designed to stop illicit funds — an FSP scenario

This companion walkthrough summarises the Fintegris compliance explainer in text, so the story is accessible and discoverable. It follows a fictional Category I FSP, "Carefree Capital", as a prospective investor's illicit funds meet the platform's designed compliance controls.

Illustrative scenario. Characters and data are fictional and the capabilities shown are designed/planned. Fintegris is in development and not yet available for commercial deployment. Nothing here is compliance, legal or financial advice.

What happens in the scenario

The scenario shows how Fintegris is designed to carry an FSP through the FICA compliance lifecycle, end to end, with a human review gate at the decision points:

  1. The setupA prospective investor, "Mr. Money Flow", brings R5 million — originating from illicit financial flows — to a licensed Category I FSP.
  2. Client intake & CDD (FICA s.21)Fintegris is designed to trigger the customer due diligence workflow, create the client record, generate a personalised document checklist, and request the required documents.
  3. Identity verification (VerifyNow)The SA ID and a selfie are validated, then cross-checked against the Home Affairs population register with a live face-match and liveness check.
  4. Sanctions & PEP screening (ComplyAdvantage)Screening against UN/OFAC/EU sanctions lists, PEP databases and adverse media raises a flag: an associate-of-a-PEP match with adverse-media hits.
  5. Explainable AI risk rating (XGBoost + SHAP)The risk engine is designed to weigh 40+ factors and return a VERY HIGH rating, with SHAP explainability so the compliance officer can see why. Enhanced Due Diligence is triggered under FICA s.21A.
  6. EDD & STR filing (FIC goAML)Source of funds cannot be verified. Fintegris is designed to auto-prepare a Suspicious Transaction Report for MLRO authorisation and filing with the Financial Intelligence Centre, with an immutable audit trail.
  7. The outcomeIn the scenario, the FSP is protected: the risk is detected, escalated and reported, with the compliance record maintained throughout.

Why it matters for South African FSPs

Enforcement against licensed FSPs has intensified: the FSCA reported that licence withdrawals rose from 75 to 382 in 2024/25, mainly due to non-submission of statutory returns, alongside 767 new enforcement cases opened. The scenario illustrates how automating and evidencing the FICA lifecycle is designed to reduce exactly this kind of exposure — while keeping a person accountable for material decisions.

Full transcript

Introduction

This is an illustrative scenario. Fintegris is an AI-native compliance platform being designed for South African Financial Service Providers — built on AWS Cape Town for FICA, FAIS, POPIA, and Guidance Notice 7A. It is currently in development and not yet available for commercial deployment.

The scenario

Meet Mr. Money Flow. He approaches Carefree Capital, a licensed Category One FSP, wanting to invest five million rand. But his money has a dark secret — it originates from illicit financial flows. Without proper compliance controls, Carefree Capital could face criminal liability, licence withdrawal, and significant administrative penalties.

Client intake

Mr. Flow contacts the investment advisor. Fintegris is designed to trigger the FICA Section 21 Customer Due Diligence workflow — automatically creating a client intake record, generating a personalised document checklist, and issuing encrypted upload links, in seconds and with minimal manual effort.

Identity verification

Mr. Flow submits his South African ID document and a selfie. Fintegris is designed to validate the documents via OCR, then call the VerifyNow API to cross-check against the Home Affairs population register, with a real-time face match and liveness check. Identity is confirmed — but the platform doesn't stop here.

Sanctions & PEP screening

In real time, Fintegris is designed to call ComplyAdvantage — cross-referencing United Nations, OFAC, and European Union sanctions lists, Politically Exposed Person databases, and adverse media feeds. In this scenario the result is alarming: Mr. Flow is flagged as an Associate of a PEP, with four adverse media hits across financial crime, fraud, and money laundering categories.

AI risk rating

The XGBoost risk engine is designed to process over forty risk factors — transaction size, geographic risk, PEP association, and inconsistent source of funds declarations. In this scenario Mr. Flow scores ninety-four out of one hundred — a VERY HIGH risk rating. With SHAP explainability, the MLRO can see exactly why. Enhanced Due Diligence is triggered under FICA Section 21A.

EDD & STR filing

Enhanced Due Diligence cannot verify Mr. Flow's source of funds. Fintegris is designed to automatically prepare a Suspicious Transaction Report, pre-populating the FIC goAML portal. The MLRO reviews the AI-prepared report and authorises submission. The STR is filed with the Financial Intelligence Centre, a case number is issued, and the entire audit trail is locked immutably on AWS S3 — designed to meet FICA Section 22 five-year retention requirements.

Outcome

In this scenario, Carefree Capital is protected. Fintegris is designed to detect, escalate, and report the illicit financial flow across twelve compliance stages — automatically, avoiding penalty exposure, with full audit coverage. Intelligent. Automated. Compliant. Fintegris — end-to-end compliance for South Africa, built on AWS Cape Town.

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