FATF Greylisting Exit — AML/CFT Legislative Package
Theme: Financial regulation / governance
Assessment
Responsible: National Treasury / FIC / SARS / NPA / FSCA
Feasibility Assessment
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.
Stakeholder Landscape
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…
Idea 21 lists Treasury among lead departments, and its recorded payoff — lower correspondent-banking costs and 50–100 basis points off sovereign borrowing — serves the brief's core interest in fiscal consolidation and debt stabilisation.
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…
Description
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 2025 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
Implementation Roadmap
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
International Comparisons
View all →Mauritius was placed on the Financial Action Task Force grey list in February 2020 and removed in October 2021 — some twenty months — for a jurisdiction whose financial-centre business depends on correspondent banking and cross-border fund administration. It treated the listing as a commercial emergency rather than a compliance exercise. The action plan was driven centrally rather than left to each supervisor: supervision of the global business sector and the non-financial professions was rebuilt on a risk basis, beneficial-ownership data was made accessible in time to be useful, and law enforcement was equipped to run money laundering investigations alongside the predicate offence. The European Union removed Mauritius from its own high-risk list three months later, in January 2022.
Approach
The action plan was run as one government programme rather than parcelled out to each supervisor, and it had five recorded strands. Risk-based supervision was built for the global business sector and for the designated non-financial businesses and professions that had been supervised nominally. Beneficial-ownership information was made accurate and available in time to be used. Law enforcement was given the capacity to run money-laundering investigations, including financial investigations in parallel with the predicate offence. Supervision of the non-profit sector was put on the same risk basis. And targeted financial sanctions were actually implemented.
Timeline: Grey-listed February 2020; action plan completed and delisted at the October 2021 plenary; the EU high-risk listing lifted in January 2022
Lessons for South Africa
South Africa has already made this exit, confirmed at the October 2025 FATF plenary after clearing the action plan, so the comparator's value is in what holds the exit. What underwrites the Mauritian position is the supervision rebuilt for the non-financial professions and for the non-profit sector — which is precisely where South Africa's residual exposure sits: provincial-level AML supervision of estate agents, motor dealers and cash-intensive businesses, plus NPO-sector compliance. With the next progress report to FATF due in 2027, sustaining the AML/CFT capacity at the FIC, the NPA and the Hawks that produced the exit is the difference between a delisting and a re-listing.
Evidence & Research
Research corpus →- ACTION FIVE: Energise the NPA
CDE · Sept 2024
The paper addresses NPA prosecutorial capacity, which is explicitly named in the policy idea as a binding constraint requiring sustained capacity to implement the FATF Action Plan's priority actions on financial crime prosecution.
Links proposed by lexical matching and screened by a calibrated research judge. Follow the paper for the full argument and its caveats.
Parliamentary record
3 meetingsCommittee sittings this reform was drawn from, most recent first. Each row opens the meeting on this site; the PMG link goes to the source record.
Finance Standing Committee
29 November 2023Public Procurement Bill: deliberation and adoption of proposed amendments
Finance Standing Committee
1 November 20222022 MTBPS: PBO & FFC briefing
Finance Standing Committee
9 November 2021National Treasury & SARS 2020/21 Annual Report & Audit Outcomes; with Deputy Minister
How to cite
Wilse-Samson, L. (2026). FATF Greylisting Exit — AML/CFT Legislative Package. SA Policy Space. Retrieved 24 August 2026, from https://sa-policy-space.vercel.app/ideas/fatf-greylisting-exit-amlcft-legislative-package?snapshot=2026-08-24
Status History
tracked since Mar 2026- Recorded as Implemented when status tracking began — held since at least Mar 2026.Mar 2026
Data as of 2026-08-24 · latest PMG meeting 2026-08-21