Is it working?

Yes, all 22 FATF action items are now completed, including the most challenging, demonstrating a sustained increase in complex money laundering and terror financing prosecutions. The FATF has confirmed substantial completion and made an on-site assessment as the final step before delisting. This is a major turnaround from 2023, when enforcement and prosecution were the weakest areas. The reforms are not only technical but have led to real improvements in the effectiveness of South Africa’s AML/CFT regime. The process has also strengthened the country’s justice and supervisory systems, helping to restore international confidence. More time is needed to assess if enforcement is adequate. Peer review processes are now in place and field-tested for sustained regulatory improvement.

Actions

Passed/amended key laws (General Laws Amendment Act, POCDATARA, FIC Act), Established/strengthened beneficial ownership registries, upgraded capacity and resources at FSCA, FIC, SAPS, NPA, DPCI, and sectoral supervisors, implemented risk-based supervision and effective, proportionate sanctions. Enhanced international cooperation, mutual legal assistance and cross-border enforcement. Dramatically increased the number and complexity of ML/TF investigations and prosecutions. Ongoing training, outreach, and sector engagement. National CFT strategy updated and implemented. Asset seizures and confiscations increased. Regular progress reports to FATF and high-level political oversight. MLA remediation measures have reduced bottlenecks and ensured compliance with all key international benchmarks.

Are there plans?

Government adopted a detailed action plan with strict deadlines, regular reporting to FATF and full inter-agency coordination. Planning and reporting for remediation cycles integrated into MLA system updates and sectoral peer review standards.
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Is it on the agenda?

This has been a national priority since grey listing in Feb 2023, driven by NT. Sustained as an explicit deliverable in National Treasury and Justice multi-year planning, with updates due every six months for reporting accuracy.

Goals

A comprehensive overhaul of South Africa’s anti-money laundering, counter-terrorism financing and anti-proliferation regime to address all 22 FATF action items. This includes legislative reforms, improved risk-based supervision, beneficial ownership transparency, effective sanctions, increased asset confiscations and a sustained increase in complex money laundering and terror financing investigations and prosecutions. Enhance global crime cooperation, accelerate legal response. Proactive multi-agency MLA requests, in volume and effect, are now tracked and peer-reviewed, supporting continued FATF compliance and transparency in international crime reporting and asset recovery.

Departments / Govt Institutions

Department of Justice and Constitutional Development Financial Intelligence Centre (FIC) Financial Sector Conduct Authority (FSCA) National Treasury South African Reserve Bank (SARB)

Is it working?

The increase in MLA requests has been recognised by the FATF, contributing to the recent upgrade in South Africa’s action plan compliance. This indicates that the government’s strategies have effectively strengthened South Africa’s AML/CFT regime through enhanced international collaboration. Continued effectiveness will depend on maintaining a high volume and quality of MLA requests and ensuring that South African authorities engage constructively with international counterparts. The FATF’s recognition of progress in this area suggests that current efforts are making a positive impact, and FATF upgraded this item in Feb 2025. Regular reporting and cooperation is ongoing. Cross-border cooperation meets benchmarks and supports rapid global response mechanisms.

Actions

The government has committed to regularly submitting mutual legal assistance (MLA) requests to enhance international cooperation in investigations, especially for complex, cross-border financial crimes. Enhanced MLA practices are supported by specific measures to improve coordination with foreign counterparts, sharing intelligence and pursuing joint investigations or prosecutions when needed. This commitment includes bolstering resources and developing a framework for efficient, timely and consistent MLA requests as per FATF recommendations. MLA process has set demonstrable best-practices, evidenced by FATF/peer benchmarking and continued case cycle improvements.

Are there plans?

Aligned with International Cooperation on the Criminal Matters Act. South Africa is party to various international conventions and agreements that emphasise the importance of mutual legal assistance in combating transnational crime. These agreements include the United Nations Convention against Transnational Organised Crime (UNTOC) and its protocols, as well as regional agreements within the African Union and Southern African Development Community (SADC). Six-monthly reporting, benchmarking and update protocols now feature in multi-agency plans and reviews.
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Is it on the agenda?

Officially through the required FATF reforms but even before SA's grey listing, the government had been raising concerns about the need to improve international cooperation and MLA processes in its efforts to combat transnational crime. Outbound MLA reporting is an ongoing agenda item within Cabinet and cross-border justice initiatives, with compliance milestones assigned per fiscal cycle.

Goals

Enhance global crime cooperation, accelerate legal response.

Departments / Govt Institutions

Department of Justice and Constitutional Development National Treasury