Enforcement action
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Individual Reform: Enforcement action 2026 - 2027

Recent amendments to FICA have aimed to strengthen South Africa's AML/CFT regime to align it with international standards. Despite some progress in arrests and confiscations, concerns persist regarding whether major players are being targeted effectively. Additionally, insufficient prosecutions undermine the progress made with arrests. The Financial Intelligence Centre (FIC), operating under the Anti-Corruption Task Team (ACTT), collaborates with the National Prosecuting Authority (NPA), Directorate for Priority Crime Investigation (DPCI), and South African Revenue Service (SARS) on a joint project to confiscate criminal proceeds.

SAPS demonstrates increase in requesting information

Summary

Historically another problematic area with SAPS being too slow to take on more staff particularly financial investigators and forensic accountants. Because of this, SAPS was less effective in utilising financial intelligence in money laundering cases.

Canvas not supported.

Is it working?

While these agencies are making some progress on arrests and confiscations, there are still concerns on whether key big players are being targeted. Furthermore, insufficient prosecutions are undermining the progress being made with arrests.

Actions

Legislation governing enforcement action against money laundering and terrorist financing primarily falls under the Financial Intelligence Centre Act (FICA) of 2001 and its subsequent amendments. In recent years, the FICA has been amended to strengthen South Africa's AML/CFT regime and align it with international standards and best practices. These amendments have included provisions for enhanced customer due diligence, suspicious transaction reporting, and the implementation of risk-based approaches to AML/CFT supervision.

Are there plans?

Led by the FIC (under the auspices of the Anti-Corruption Task Team) (ACTI) - the NPA, DPCI and SARS are collaborating on a joint project to confiscate criminal proceeds. The law enforcement agencies will use existing asset recovery legislation to secure appropriate orders issued by the courts.

Is it on the agenda?

Government began raising the issue around the mid-2010s. The issue gained momentum as government wanted to improve the effectiveness of enforcement actions in combating financial crimes.

Goals

As noted in the November 2023 Follow-up report - Law enforcement action against unauthorised MVTS activity has been stepped up although no sanctions have been imposed as yet and the enforceability of the Currency and Exchanges Manual which requires that ADLA’s RMCP include agents in their AML/CFT programmes and monitor them, is not clear. SAPS should demonstrate a sustained increase in proactive requests for financial intelligence from the FIC for its ML/TF investigations.

Departments / Govt Institutions

Financial Intelligence Centre (FIC) National Treasury South African Police Service

Summary

Historically, the SAPS has been too slow to take on more staff particularly financial investigators and forensic accountants. Because of this, the SAPS was less effective in utilising financial intelligence in money laundering cases.

Canvas not supported.

Is it working?

While these agencies are making some progress on arrests and confiscations, there are still concerns on whether key big players are being targeted. Furthermore, insufficient prosecutions are undermining the progress being made with arrests. As noted in the November 2023 follow-up report, law enforcement action against unauthorised MVTS activity has been stepped up although no sanctions have been imposed as yet. Also, the enforceability of the Currency and Exchanges Manual which requires that ADLA’s RMCP include agents in their AML/CFT programmes and monitor them, is not clear. SAPS should demonstrate a sustained increase in proactive requests for financial intelligence from the FIC for its ML/TF investigations.

Actions

Legislation governing enforcement action against money laundering and terrorist financing primarily falls under the Financial Intelligence Centre Act (FICA) of 2001 and its subsequent amendments. In recent years, the FICA has been amended to strengthen South Africa's AML/CFT regime and align it with international standards and best practices. These amendments have included provisions for enhanced customer due diligence, suspicious transaction reporting and the implementation of risk-based approaches to AML/CFT supervision.

Are there plans?

Led by the FIC (under the auspices of the Anti-Corruption Task Team) (ACTI) - the NPA, DPCI and SARS are collaborating on a joint project to confiscate criminal proceeds. The law enforcement agencies will use existing asset recovery legislation to secure appropriate orders issued by the courts.

Is it on the agenda?

Government began raising the issue around the mid-2010s. The issue gained momentum as government wanted to improve the effectiveness of enforcement actions in combating financial crimes.

Goals

Enforcement action for the SAPS through increased information requests should ensure that more police officers and other crime experts are provided with and have access to the relevant (and adequate) information to tackle all crimes. This should be carried out by providing the adequate resources and level of authority which would enable them to increasingly gather information to aid them in combating crimes. Over time with increased numbers and depth of investigations, effectiveness will be proven as SAPS accumulates more information to conclude investigations.

Departments / Govt Institutions

Financial Intelligence Centre (FIC) National Treasury South African Police Service

Summary

Historically, the SAPS has been too slow to take on more staff, particularly financial investigators and forensic accountants. Because of this, the SAPS has been too ineffective in utilising financial intelligence in money laundering cases.

Canvas not supported.

Is it working?

The FATF’s recent upgrades signal that South Africa’s increased enforcement activities are having a positive impact, with enhanced regulatory scrutiny and sanctions application leading to higher compliance levels. To meet the FATF’s requirements fully, South Africa will need to maintain and demonstrate a pattern of strong enforcement actions, particularly in high-risk and non-compliant sectors. A sustained increase in enforcement actions is critical to building credibility with the FATF and proving the effectiveness of South Africa’s AML/CFT regime. The FATF has emphasised the need for consistent sanctions; therefore, South Africa’s authorities will need to focus on applying enforcement measures uniformly and transparently across all regulated entities leading into the February 2025 evaluation.

Actions

Enforcement actions focus on demonstrating a sustained increase in investigations and prosecutions of serious and complex money laundering and terror financing cases. This includes tackling both domestic and cross-border financial crime, with specific measures targeting unlicensed MVTS operators and other high-risk entities.The government has directed anti-money laundering/terrorism supervisors and law enforcement agencies to apply sanctions consistently for non-compliance, including financial penalties, licence revocations and legal prosecution where necessary. Plans also include the development of guidelines to ensure that sanctions are applied proportionally, effectively and consistently across sectors, especially in cases involving designated non-financial businesses and professions .

Are there plans?

Led by the FIC (under the auspices of the Anti-Corruption Task Team) (ACTI), the NPA, DPCI and SARS are collaborating on a joint project to confiscate criminal proceeds. The law enforcement agencies will use existing asset recovery legislation to secure appropriate orders issued by the courts. SAPS faces several challenges in implementing FATF reforms for anti-money laundering and counter-terrorist financing. These include insufficient training and capacity in handling financial intelligence, weak inter-agency coordination and resource constraints, particularly in accessing advanced technology for financial crime investigation. To address these challenges, targeted training is being implemented to enhance officers' capacity in financial intelligence, alongside improved inter-agency collaboration.

Is it on the agenda?

Government began raising the issue around the mid-2010s. The issue gained momentum as government wanted to improve the effectiveness of enforcement actions in combating financial crimes.

Goals

Enforcement action for the SAPS through increased information requests should ensure that more police officers and other crime experts are provided with and have access to the relevant (and adequate) information to tackle all crimes. This should be carried out by providing the adequate resources and level of authority which would enable them to increasingly gather information to aid them in combating crimes. Over time with increased numbers and depth of investigations, effectiveness will increase as the SAPS accumulates more information to conclude investigations.

Departments / Govt Institutions

Financial Intelligence Centre (FIC) National Treasury South African Police Service

Summary

Historically, the SAPS has been too slow to take on more staff, particularly financial investigators and forensic accountants. Because of this, the SAPS has been too ineffective in utilising financial intelligence in money laundering cases.

Canvas not supported.

Is it working?

The FATF’s recent upgrades signal that South Africa’s increased enforcement activities are having a positive impact, with enhanced regulatory scrutiny and sanctions application leading to higher compliance levels. To meet the FATF’s requirements fully, South Africa will need to maintain and demonstrate a pattern of strong enforcement actions, particularly in high-risk and non-compliant sectors. A sustained increase in enforcement actions is critical to building credibility with the FATF and proving the effectiveness of South Africa’s AML/CFT regime. The FATF has emphasised the need for consistent sanctions; therefore, South Africa’s authorities will need to focus on applying enforcement measures uniformly and transparently across all regulated entities leading into the February 2025 evaluation.

Actions

Enforcement actions focus on demonstrating a sustained increase in investigations and prosecutions of serious and complex money laundering and terror financing cases. This includes tackling both domestic and cross-border financial crime, with specific measures targeting unlicensed MVTS operators and other high-risk entities.The government has directed anti-money laundering/terrorism supervisors and law enforcement agencies to apply sanctions consistently for non-compliance, including financial penalties, licence revocations and legal prosecution where necessary. Plans also include the development of guidelines to ensure that sanctions are applied proportionally, effectively and consistently across sectors, especially in cases involving designated non-financial businesses and professions .

Are there plans?

Led by the FIC (under the auspices of the Anti-Corruption Task Team) (ACTI), the NPA, DPCI and SARS are collaborating on a joint project to confiscate criminal proceeds. The law enforcement agencies will use existing asset recovery legislation to secure appropriate orders issued by the courts. SAPS faces several challenges in implementing FATF reforms for anti-money laundering and counter-terrorist financing. These include insufficient training and capacity in handling financial intelligence, weak inter-agency coordination and resource constraints, particularly in accessing advanced technology for financial crime investigation. To address these challenges, targeted training is being implemented to enhance officers' capacity in financial intelligence, alongside improved inter-agency collaboration.

Is it on the agenda?

Government began raising the issue around the mid-2010s. The issue gained momentum as government wanted to improve the effectiveness of enforcement actions in combating financial crimes.

Goals

Enforcement action for the SAPS through increased information requests should ensure that more police officers and other crime experts are provided with and have access to the relevant (and adequate) information to tackle all crimes. This should be carried out by providing the adequate resources and level of authority which would enable them to increasingly gather information to aid them in combating crimes. Over time with increased numbers and depth of investigations, effectiveness will increase as the SAPS accumulates more information to conclude investigations.

Departments / Govt Institutions

Financial Intelligence Centre (FIC) National Treasury South African Police Service

Summary

Historically, the SAPS has been too slow to take on more staff, particularly financial investigators and forensic accountants. Because of this, the SAPS has been too ineffective in utilising financial intelligence in money laundering cases.

Canvas not supported.

Is it working?

The FATF’s recent upgrades signal that South Africa’s increased enforcement activities are having a positive impact, with enhanced regulatory scrutiny and sanctions application leading to higher compliance levels. To meet the FATF’s requirements fully, South Africa will need to maintain and demonstrate a pattern of strong enforcement actions, particularly in high-risk and non-compliant sectors. A sustained increase in enforcement actions is critical to building credibility with the FATF and proving the effectiveness of South Africa’s AML/CFT regime. The FATF has emphasised the need for consistent sanctions; therefore, South Africa’s authorities will need to focus on applying enforcement measures uniformly and transparently across all regulated entities leading into the February 2025 evaluation.

Actions

Enforcement actions focus on demonstrating a sustained increase in investigations and prosecutions of serious and complex money laundering and terror financing cases. This includes tackling both domestic and cross-border financial crime, with specific measures targeting unlicensed MVTS operators and other high-risk entities.The government has directed anti-money laundering/terrorism supervisors and law enforcement agencies to apply sanctions consistently for non-compliance, including financial penalties, licence revocations and legal prosecution where necessary. Plans also include the development of guidelines to ensure that sanctions are applied proportionally, effectively and consistently across sectors, especially in cases involving designated non-financial businesses and professions .

Are there plans?

Led by the FIC (under the auspices of the Anti-Corruption Task Team) (ACTI), the NPA, DPCI and SARS are collaborating on a joint project to confiscate criminal proceeds. The law enforcement agencies will use existing asset recovery legislation to secure appropriate orders issued by the courts. SAPS faces several challenges in implementing FATF reforms for anti-money laundering and counter-terrorist financing. These include insufficient training and capacity in handling financial intelligence, weak inter-agency coordination and resource constraints, particularly in accessing advanced technology for financial crime investigation. To address these challenges, targeted training is being implemented to enhance officers' capacity in financial intelligence, alongside improved inter-agency collaboration.

Is it on the agenda?

Government began raising the issue around the mid-2010s. The issue gained momentum as government wanted to improve the effectiveness of enforcement actions in combating financial crimes.

Goals

Enforcement action for the SAPS through increased information requests should ensure that more police officers and other crime experts are provided with and have access to the relevant (and adequate) information to tackle all crimes. This should be carried out by providing the adequate resources and level of authority which would enable them to increasingly gather information to aid them in combating crimes. Over time with increased numbers and depth of investigations, effectiveness will increase as the SAPS accumulates more information to conclude investigations.

Departments / Govt Institutions

Financial Intelligence Centre (FIC) National Treasury South African Police Service

Summary

Historically, the SAPS has been too slow to take on more staff, particularly financial investigators and forensic accountants. Because of this, the SAPS has been ineffective in utilising financial intelligence in money laundering cases. COMPLETE: We stopped tracking this specific reform at end-June 2025 as it is complete and in effect.

Canvas not supported.

Is it working?

The FATF’s recent upgrades signal that South Africa’s increased enforcement activities are having a positive impact, with enhanced regulatory scrutiny and sanctions application leading to higher compliance levels. This was achieved in February 2025 with FIC intelligence being actively used as more suspicious transaction reports (STRs) are being used in investigations.

Actions

Enforcement actions focus on demonstrating a sustained increase in investigations and prosecutions of serious and complex money laundering and terror financing cases. This includes tackling both domestic and cross-border financial crime, with specific measures targeting unlicensed MVTS operators and other high-risk entities. The government has directed anti-money laundering/terrorism supervisors and law enforcement agencies to apply sanctions consistently for non-compliance, including financial penalties, licence revocations and legal prosecution where necessary.

Are there plans?

Led by the FIC, under the auspices of the Anti-Corruption Task Team (ACTI), the NPA, DPCI and SARS are collaborating on a joint project to confiscate proceeds of crime. The law enforcement agencies will use existing asset recovery legislation to secure appropriate orders issued by the courts. SAPS faces several challenges in implementing FATF reforms for anti-money laundering and counter-terrorist financing. These include insufficient training and capacity in handling financial intelligence, weak inter-agency coordination and resource constraints, particularly in accessing advanced technology for financial crime investigation. To address these challenges, targeted training is being implemented to enhance officers' capacity in financial intelligence, alongside improved inter-agency collaboration. Plans also include the development of guidelines to ensure that sanctions are applied proportionally, effectively and consistently across sectors, especially in cases involving designated non-financial businesses and professions .

Is it on the agenda?

Government began raising the issue around the mid-2010s. The issue gained momentum as government wanted to improve the effectiveness of enforcement actions in combating financial crimes.

Goals

Enforcement action for the SAPS through increased information requests should ensure that more police officers and other crime experts are provided with and have access to the relevant (and adequate) information to tackle all crimes. This should be carried out by providing the adequate resources and level of authority which would enable them to increasingly gather information to aid them in combating crimes. Over time, the aim is that with increased numbers and depth of investigations, effectiveness will increase as the SAPS accumulates more information to conclude investigations.

Departments / Govt Institutions

Financial Intelligence Centre (FIC) National Treasury South African Police Service

Summary

Historically, the SAPS has been too slow to take on more staff, particularly financial investigators and forensic accountants. Because of this, the SAPS has been ineffective in utilising financial intelligence in money laundering cases. COMPLETE: We stopped tracking this specific reform at end-June 2025 as it is complete and in effect. SAPS has improved money laundering and terrorism financing (ML/TF) case investigation, streamlined information requests, and has increased capacity for evidence gathering and reporting. These are now publicly tracked for compliance.
rn

Canvas not supported.

Is it working?

The FATF’s recent upgrades signal that South Africa’s increased enforcement activities are having a positive impact, with enhanced regulatory scrutiny and sanctions application leading to higher compliance levels. This was achieved in February 2025 with FIC intelligence being actively used as more suspicious transaction reports (STRs) are being used in investigations. FATF benchmarks and crime reporting standards now fully met, with real-time case tracking supporting ongoing compliance.

Actions

Enforcement actions focus on demonstrating a sustained increase in investigations and prosecutions of serious and complex money laundering and terror financing cases. This includes tackling both domestic and cross-border financial crime, with specific measures targeting unlicensed MVTS operators and other high-risk entities. The government has directed anti-money laundering/terrorism supervisors and law enforcement agencies to apply sanctions consistently for non-compliance, including financial penalties, licence revocations and legal prosecution where necessary. SAPS has rolled out new incident tracking and reporting systems, with enhanced transparency and operational capacity.

Are there plans?

Led by the FIC, under the auspices of the Anti-Corruption Task Team (ACTI), the NPA, DPCI and SARS are collaborating on a joint project to confiscate proceeds of crime. The law enforcement agencies will use existing asset recovery legislation to secure appropriate orders issued by the courts. SAPS faces several challenges in implementing FATF reforms for anti-money laundering and counter-terrorist financing. These include insufficient training and capacity in handling financial intelligence, weak inter-agency coordination and resource constraints, particularly in accessing advanced technology for financial crime investigation. To address these challenges, targeted training is being implemented to enhance officers' capacity in financial intelligence, alongside improved inter-agency collaboration. Plans also include the development of guidelines to ensure that sanctions are applied proportionally, effectively and consistently across sectors, especially in cases involving designated non-financial businesses and professions. Plans are now scheduled for quarterly and annual crime sector milestones, process improvements and public case disclosures along with ongoing resource upgrades included for SAPS.
rn

Is it on the agenda?

Government began raising the issue around the mid-2010s. The issue gained momentum as government wanted to improve the effectiveness of enforcement actions in combating financial crimes. Regular updates in law enforcement agenda; public reporting milestones included in Cabinet reviews.

Goals

Enforcement action for the SAPS through increased information requests should ensure that more police officers and other crime experts are provided with and have access to the relevant (and adequate) information to tackle all crimes. This should be carried out by providing the adequate resources and level of authority which would enable them to increasingly gather information to aid them in combating crimes. Over time, the aim is that with increased numbers and depth of investigations, effectiveness will increase as the SAPS accumulates more information to conclude investigations.

Departments / Govt Institutions

Financial Intelligence Centre (FIC) National Treasury South African Police Service

Summary

Historically, the SAPS has been too slow to take on more staff, particularly financial investigators and forensic accountants. Because of this, the SAPS has been ineffective in utilising financial intelligence in money laundering cases. COMPLETE: We stopped tracking this specific reform at end-June 2025 as it is complete and in effect. SAPS has improved money laundering and terrorism financing (ML/TF) case investigation, streamlined information requests, and has increased capacity for evidence gathering and reporting. These are now publicly tracked for compliance.

Canvas not supported.

Is it working?

The FATF’s recent upgrades signal that South Africa’s increased enforcement activities are having a positive impact, with enhanced regulatory scrutiny and sanctions application leading to higher compliance levels. This was achieved in February 2025 with FIC intelligence being actively used as more suspicious transaction reports (STRs) are being processed in investigations. FATF benchmarks and crime reporting standards now fully met, with real-time case tracking supporting ongoing compliance.

Actions

Enforcement actions focus on demonstrating a sustained increase in investigations and prosecutions of serious and complex money laundering and terror financing cases. This includes tackling both domestic and cross-border financial crime, with specific measures targeting unlicensed MVTS operators and other high-risk entities. The government has directed anti-money laundering/terrorism supervisors and law enforcement agencies to apply sanctions consistently for non-compliance, including financial penalties, licence revocations and legal prosecution where necessary. SAPS has rolled out new incident tracking and reporting systems, with enhanced transparency and operational capacity.

Are there plans?

Led by the FIC, under the auspices of the Anti-Corruption Task Team (ACTI), the NPA, DPCI and SARS are collaborating on a joint project to confiscate proceeds of crime. The law enforcement agencies will use existing asset recovery legislation to secure appropriate orders issued by the courts. SAPS faces several challenges in implementing FATF reforms for anti-money laundering and counter-terrorist financing. These include insufficient training and capacity in handling financial intelligence, weak inter-agency coordination and resource constraints, particularly in accessing advanced technology for financial crime investigation. To address these challenges, targeted training is being implemented to enhance officers' capacity in financial intelligence, alongside improved inter-agency collaboration. Plans also include the development of guidelines to ensure that sanctions are applied proportionally, effectively and consistently across sectors, especially in cases involving designated non-financial businesses and professions. Plans are now scheduled for quarterly and annual crime sector milestones, process improvements and public case disclosures along with ongoing resource upgrades included for SAPS.
rn

Is it on the agenda?

Government began raising the issue around the mid-2010s. The issue gained momentum as government wanted to improve the effectiveness of enforcement actions in combating financial crimes. Regular updates in law enforcement agenda; public reporting milestones included in Cabinet reviews.

Goals

Enforcement action for the SAPS through increased information requests should ensure that more police officers and other crime experts are provided with and have access to the relevant (and adequate) information to tackle all crimes. This should be carried out by providing the adequate resources and level of authority which would enable them to increasingly gather information to aid them in combating crimes. Over time, the aim is that with increased numbers and depth of investigations, effectiveness will increase as the SAPS accumulates more information to conclude investigations.

Departments / Govt Institutions

Financial Intelligence Centre (FIC) National Treasury South African Police Service

Summary

Historically, the SAPS has been too slow to take on more staff, particularly financial investigators and forensic accountants. Because of this, the SAPS has been ineffective in utilising financial intelligence in money laundering cases. COMPLETE: We stopped tracking this specific reform at end-June 2025 as it is complete and in effect. SAPS has improved money laundering and terrorism financing (ML/TF) case investigation, streamlined information requests, and has increased capacity for evidence gathering and reporting. These are now publicly tracked for compliance.

Canvas not supported.

Is it working?

The FATF’s recent upgrades signal that South Africa’s increased enforcement activities are having a positive impact, with enhanced regulatory scrutiny and sanctions application leading to higher compliance levels. This was achieved in February 2025 with FIC intelligence being actively used as more suspicious transaction reports (STRs) are being processed in investigations. FATF benchmarks and crime reporting standards now fully met, with real-time case tracking supporting ongoing compliance.

Actions

Enforcement actions focus on demonstrating a sustained increase in investigations and prosecutions of serious and complex money laundering and terror financing cases. This includes tackling both domestic and cross-border financial crime, with specific measures targeting unlicensed MVTS operators and other high-risk entities. The government has directed anti-money laundering/terrorism supervisors and law enforcement agencies to apply sanctions consistently for non-compliance, including financial penalties, licence revocations and legal prosecution where necessary. SAPS has rolled out new incident tracking and reporting systems, with enhanced transparency and operational capacity.

Are there plans?

Led by the FIC, under the auspices of the Anti-Corruption Task Team (ACTI), the NPA, DPCI and SARS are collaborating on a joint project to confiscate proceeds of crime. The law enforcement agencies will use existing asset recovery legislation to secure appropriate orders issued by the courts. SAPS faces several challenges in implementing FATF reforms for anti-money laundering and counter-terrorist financing. These include insufficient training and capacity in handling financial intelligence, weak inter-agency coordination and resource constraints, particularly in accessing advanced technology for financial crime investigation. To address these challenges, targeted training is being implemented to enhance officers' capacity in financial intelligence, alongside improved inter-agency collaboration. Plans also include the development of guidelines to ensure that sanctions are applied proportionally, effectively and consistently across sectors, especially in cases involving designated non-financial businesses and professions. Plans are now scheduled for quarterly and annual crime sector milestones, process improvements and public case disclosures along with ongoing resource upgrades included for SAPS.
rn

Is it on the agenda?

Government began raising the issue around the mid-2010s. The issue gained momentum as government wanted to improve the effectiveness of enforcement actions in combating financial crimes. Regular updates in law enforcement agenda; public reporting milestones included in Cabinet reviews.

Goals

Enforcement action for the SAPS through increased information requests should ensure that more police officers and other crime experts are provided with and have access to the relevant (and adequate) information to tackle all crimes. This should be carried out by providing the adequate resources and level of authority which would enable them to increasingly gather information to aid them in combating crimes. Over time, the aim is that with increased numbers and depth of investigations, effectiveness will increase as the SAPS accumulates more information to conclude investigations.

Departments / Govt Institutions

Financial Intelligence Centre (FIC) National Treasury South African Police Service

Analyst: Tinashe Kambadza
Status: completed
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