Theme: Financial regulation / governance
Responsible: National Treasury / FIC / SARS / NPA / FSCA
Fully implemented. Exit confirmed 24 October 2025 at FATF Plenary, Paris. SA now in regular enhanced follow-up cycle; next progress report to FATF due 2027. Post-exit risks: provincial-level AML supervision gaps (estate agents, motor dealers, cash-intensive businesses) and NPO sector compliance remain ongoing enforcement challenges.
Who backs this reform, who needs convincing, and which interests or red lines shape political feasibility.
Backers
35
4 stakeholders
Negotiation weight
0
0 conditional actors
Opposition weight
0
0 opposing actors
Review coverage
0/4
All mapped stance notes are still draft
Provenance warning
Every mapped stakeholder stance for this idea is still draft. The coalition score is directional only until at least the high-influence actors are reviewed.
Coalition Read
Anchor: Presidency / Operation Vulindlela.
Political Tractability
No reviewed signals · 0% of mapped influence has been reviewed.
FATF greylisting exit was a top Presidential priority, now implemented, with ongoing monitoring.
Interest: Cross-cutting structural reform coordination across energy, logistics, water, digital infrastructure, and visa reform. Operation Vulindlela, establish…
Concern: Implementation bottlenecks within line departments; regulatory capture of NERSA and ICASA; SOE institutional inertia; ensuring quick wins translate in…
Engagement path: Already fully engaged. Seeks line department buy-in, NEDLAC social compact legitimacy, and international DFI financing alignment on key reform milesto…
Treasury co-led the FATF greylisting exit as a joint priority with the Presidency.
Interest: Fiscal consolidation with public debt stabilising below 75% of GDP; structural reforms that improve revenue without expanding contingent liabilities;…
Concern: Unfunded mandates in energy transition (JETP co-financing); Eskom's R400bn+ debt and how restructuring socialises costs; reform proposals that create…
Engagement path: Reforms must be fiscally neutral or revenue-positive over the MTEF window; SOE restructuring must demonstrably reduce contingent liabilities; credible…
BUSA supported the FATF exit as essential for financial system credibility and correspondent banking relationships.
Interest: Cross-sector structural reform across energy security, logistics efficiency, regulatory certainty, labour market flexibility, and digital infrastructu…
Concern: Slow implementation pace relative to policy announcements; inconsistency between reform rhetoric and regulatory decisions (e.g. NERSA tariff approvals…
Engagement path: Already actively engaged. Seeks implementation accountability mechanisms with published milestones, predictable regulatory timelines, and NEDLAC outco…
SARB supported the FATF exit as essential for financial system integrity and correspondent banking relationships.
Interest: Price stability under the 3–6% inflation targeting framework; financial system stability under the Twin Peaks prudential model; integrity of the Natio…
Concern: Fintech entry that could destabilise the payment system or create unregulated credit channels; fiscal dominance risks if public debt crowds out moneta…
Engagement path: Fintech reforms must operate within SARB's NPS oversight framework; fiscal reforms must maintain credible debt trajectory; new financial entrants requ…
South Africa was greylisted by the Financial Action Task Force (FATF) in February 2023 following assessments of deficiencies in anti-money laundering (AML) and counter-financing of terrorism (CFT) frameworks. The legislative response included the General Laws Amendment Act (2022), Financial Sector Laws Amendment Act (2022), and subsequent amendments to the Companies Act and Trust Property Control Act. The FATF Action Plan required 22 priority actions across beneficial ownership registers, prosecutorial capacity, and financial intelligence. South Africa exited the greylist in October 2024 after addressing most action items. The reform's significance extends beyond the list: greylisting raised correspondent banking costs, deterred foreign portfolio investment, and increased compliance burdens on SA financial institutions. Sustained AML/CFT capacity at the FIC, NPA, and Hawks is needed to maintain the exit and prevent re-listing.
Referenced in OECD Economic Surveys: South Africa
OECD SA Survey (2020, 2022, 2025). Port productivity improvement recommended across surveys as critical for trade competitiveness.
South Africa's exit from the FATF grey list on 24 October 2025 — completing all 22 action items in 32 months — demonstrates that a constitutional democracy can execute a comprehensive AML/CFT reform programme while maintaining the rule of law. — FATF Plenary Statement, Paris, October 2025
South Africa formally exited the FATF grey list on 24 October 2025 after completing all 22 action items within 32 months. The remaining agenda is institutionalisation: ensuring the legislative reforms passed under pressure (General Laws Amendment Act, FIC Act amendments, NPO Act reforms) are fully operationalised and not reversed. The FATF regular follow-up report due 2027 is the next external accountability checkpoint. A correspondent banking relationship restoration and S&P sovereign outlook upgrade in November 2025 confirm the macroeconomic dividend is already materialising.
Operationalise beneficial ownership registers for companies (CIPC) and trusts (SARS): integrate with the FIC database and enable law enforcement query access
Expand the Asset Forfeiture Unit (AFU): fill 120 vacant investigator posts, implement case management system upgrade, and extend the Specialised Commercial Crime Unit (SCCU) to all 9 provinces
Implement risk-based AML/CFT supervision framework for Designated Non-Financial Businesses and Professions (DNFBPs): real estate agents, attorneys, accountants, car dealers — sector-specific risk guidance papers to be gazetted
Non-Profit Organisation sector risk framework: operationalise the NPO Regulatory Framework published under the amended NPO Act; establish risk-based monitoring for high-risk NPOs without restricting legitimate civil society activity
Hong Kong's ICAC, established 1974, reduced the territory from one of Asia's most corrupt jurisdictions to a global benchmark within 15 years. Key design: independent funding (not through the police budget), a Prevention department auditing government procedures proactively, a Community Relations department normalising anti-corruption as civic culture, and statutory powers to investigate any public officer's bank accounts without court order. By 1985 Hong Kong's CPI equivalent exceeded 8/10. SA's NPA, SIU and Hawks lack ICAC's institutional independence and community trust-building mandate.
Anti-Extortion and Construction Mafia Task Force
National Treasury PPP Unit and Infrastructure Financing Reform
Fiscal Consolidation and Debt Stabilisation
SAPS Detective Service Capacity and Case Clearance
NPA Prosecution Capacity and Independence
SARS Capacity Expansion and Revenue Recovery
How to cite
Wilse-Samson, L. (2026). FATF Greylisting Exit — AML/CFT Legislative Package. SA Policy Space. NYU Wagner School of Public Policy. Retrieved 11 May 2026, from https://sa-policy-space.vercel.app/ideas/fatf-greylisting-exit-amlcft-legislative-package?snapshot=2026-05-11
Data as of 2026-05-11 · latest PMG meeting 2026-05-08
Prepare FATF Mutual Evaluation Follow-Up Report (due 2027): convene inter-agency NATJOINTS working group; compile implementation evidence disaggregated by action item; engage FATF Secretariat
Restore and maintain correspondent banking relationships: bilateral engagement with SWIFT, Citibank, Standard Chartered, and Deutsche Bank to confirm full reinstatement of tier-1 correspondent access at reduced KYC compliance premium
Exit achieved October 2025; 18-month post-exit institutionalisation phase (Q4 2025–Q2 2027); FATF follow-up report 2027
R4.2 billion committed across the 22 action item programme (2023–2025); ongoing annual cost approximately R800 million — AFU staffing ~R350m, FIC systems ~R200m, FSCA supervisory expansion ~R150m, NPA capacity ~R100m
All primary legislation enacted: General Laws (AML/CFT) Amendment Act 22 of 2022; FIC Amendment Act (2023); NPO Act amendments (2024); Criminal Procedure Act amendments (crypto-asset seizure provisions). Secondary legislation outstanding: NPO Risk Framework Regulations (Department of Social Development); FSCA DNFBP sector-specific risk guidance papers (FIC Act framework).
Extremely high political salience — grey list exit is among the GNU's most credible reform achievements. Cross-party support is strong. The primary risk is implementation fatigue: momentum that characterised 2023–2025 may dissipate with immediate FATF pressure removed. The 2027 FATF follow-up deadline provides the external accountability mechanism to sustain reform.
Pakistan exited the FATF grey list in October 2022 after a 4-year programme; AFU-equivalent (NAB) staff tripling was credited as the decisive factor. Mauritius exited in 2021 after an 18-month programme — its trust registry reform directly parallels SA's CIPC beneficial ownership register. Botswana (2021) demonstrated that politically committed governments can exit rapidly with targeted legislative packages even under resource constraints.