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SA Policy Space

FATF Greylisting Exit — AML/CFT Legislative Package

Corruption & GovernanceImplementedQuick WinRaised 3× in committeeFinance Standing Committee

Theme: Financial regulation / governance

First raisedNov 2021Last discussedNov 20233 meetings on the record ↓

Reform at a glance

What changes
Strengthen anti-money-laundering and counter-terrorist-financing rules, beneficial ownership transparency and enforcement.
Responsible actor (recorded)
National Treasury / FIC / SARS / NPA / FSCA
Recorded status
Implemented — editorial assessment.
Milestone described by this status
FATF removal from increased monitoring, 24 October 2025.
Next documented milestone
Monitor sustained AML/CFT effectiveness; do not attribute borrowing-cost changes without analysis.
Source review details

Agent-prepared claim inventory from committed snapshot; primary-source checks only where explicitly dated. Pending human review. Proposal summary prepared from the recorded reform scope on 2026-09-20; it makes no claim of implementation or quantified impact. Numerical impacts and implementation claims below remain provisional where the findings identify unresolved checks.

  • FATF confirms removal from increased monitoring in October 2025. The claimed rand savings and 50–100 basis-point effect are not established by that decision.
  • Numerical or dated statements require source-by-source verification before reuse as established findings.
  • Numerical or dated statements require source-by-source verification before reuse as established findings.
  • Numerical or dated statements require source-by-source verification before reuse as established findings.
  • Recorded status is implemented. Scope of completion and present implementation have not been independently verified in this preparation.
  • Recorded owner: National Treasury / FIC / SARS / NPA / FSCA. Present allocation of responsibilities requires verification.
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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.

Assessment

Growth Impact4/5
Feasibility4/5

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

Coalition Read

AI-drafted stances · 0 reviewed

100/100Mapped support: strong

Anchor: Presidency / Operation Vulindlela.

Political Tractability

—Needs reviewed signals

No reviewed signals · 0% of mapped influence has been reviewed.

Backers4 stakeholders
Presidency / Operation VulindlelaCoalition anchorInfluence 10/10

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…

National TreasuryCoalition anchorInfluence 9/10

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…

Business Unity South Africa (BUSA)Coalition anchorInfluence 8/10

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…

South African Reserve BankCoalition anchorInfluence 8/10

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…

OECD

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.

1

Operationalise beneficial ownership registers for companies (CIPC) and trusts (SARS): integrate with the FIC database and enable law enforcement query access

Q1–Q2 2026CIPC / SARS / Financial Intelligence Centre (FIC)
2

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

Q1 2026–Q2 2027National Prosecuting Authority (NPA) / SAPS / Department of Justice
3

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

Q1–Q4 2026FSCA / FIC / Law Society of SA / IRBA
4

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

Q2 2026–Q1 2027Department of Social Development / FIC
5

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

Q1–Q4 2027National Treasury / FIC / NATJOINTS
6

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

Q1–Q2 2026National Treasury / SARB / FSCA / Banking Association SA
Timeline

Exit achieved October 2025; 18-month post-exit institutionalisation phase (Q4 2025–Q2 2027); FATF follow-up report 2027

Estimated Cost

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

Required Legislation

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).

Political Feasibility

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.

International Precedents

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.

International Comparisons

View all →
🇲🇺Mauritius2020

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.

  • Position Papers | Criminal Justice System

    PARI · Apr 2020

    The paper directly addresses prosecutorial capacity and institutional independence at the NPA, which is explicitly named in the policy idea as requiring sustained AML/CFT capacity and is central to South Africa's FATF Action Plan for exiting greylisting.

Links proposed by lexical matching and screened by a calibrated research judge. Follow the paper for the full argument and its caveats.

Policy documents

No linked official-document evidence yet. Coverage is incomplete.

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Status History

tracked since Mar 2026
  1. Recorded as Implemented when status tracking began — held since at least Mar 2026.
    Mar 2026

Data as of 2026-10-12 · latest PMG meeting 2026-10-09