Is it working?

Yes , in 2025, FATF confirmed that South Africa has fully addressed this action item. All elements of the strategy are in place and operational, there is clear evidence of a sustained increase in TF investigations, prosecutions and asset freezes. FATF approved the on-site assessment, which was the final step before the delisting This reform was among the most difficult, requiring not just new laws but ongoing, effective enforcement and inter-agency coordination. The reform has now significantly strengthened SA’s CFT regime and international reputation. The system is functioning well and has received peer recognition as among the region’s most robust for intelligence-led anti-terror finance.

Actions

TF Risk Assessment updated (May 2024), comprehensive CFT strategy adopted and implemented (Sept 2024), capacity-building and training for SAPS, NPA, FIC, and others. Protection of Constitutional Democracy against Terrorist and Related Activities Amendment Act (POCDATARA) amendments fully integrated into agency SOPs. Asset freezes and prosecutions: first court-ordered TF asset freezes in Feb 2025; increased TF investigations and prosecutions, regular progress reporting to FATF and high-level political oversight. There is publication and updating of national TF strategy, rollout of enhanced reporting and legislative amendments to address risk typologies and prosecution gaps.

Are there plans?

Yes - The multi-phase plan based on the following. Review and update TF risk assessment (Jan–May 2024), update and implement comprehensive national CFT strategy (May–Sept 2024), enhance capacity and training for SAPS, NPA, and other agencies (May–Sept 2024), incorporate POCDATARA amendments into agency procedures (Sept 2024), demonstrate sustained increase in identification, investigation, and prosecution of TF activities (Jan–June 2025). Since the greylist removal, multi-year anti-terror finance policy plans include rolling intelligence, prosecution and policy refreshes, with milestones attached to legislative and institutional capacity cycles.

Is it on the agenda?

It was top national priority since grey listing in Feb 2023 and a core FATF action item. As of October 2025, National TF and counter-terrorism policy remains a standing item in the agendas of Ministry of Police, National Treasury and FIC, linked to Cabinet performance audits.

Goals

For effective combatting of terrorism, there should be improvement in the proactive identification of TF activities with the amendment of the policy to pursue domestic designations as a tool to counter terrorism or terrorist financing.

Departments / Govt Institutions

Department of Justice and Constitutional Development Financial Intelligence Centre (FIC) National Treasury

Is it working?

The actions taken by South Africa to implement its legal framework for sanctions have been completed and are largely aligned with the FATF recommendations. The national risk framework is robust and effective for FATF compliance, yet continuing vigilance is needed for NPO onboarding and dynamic risk mapping.

Actions

The government is conducting a comprehensive risk assessment of the NPO sector to identify and mitigate terrorism financing (TF) vulnerabilities. This assessment includes evaluating the types of NPOs at highest risk, understanding the sector’s overall exposure to TF activities and identifying areas requiring stricter regulatory control. New regulatory guidelines are being developed to help NPOs understand their AML/CFT obligations, including requirements for due diligence, record-keeping and reporting of suspicious transactions. The government is also working on outreach programmes to raise awareness among NPOs about TF risks and the importance of compliance. To enhance monitoring and enforcement, the government is creating a framework for regular risk assessments and audits within the NPO sector, focusing on high-risk organisations. This framework includes collaboration between the Financial Intelligence Centre and relevant regulatory bodies to ensure proper oversight. Regular publication of sectoral risk reviews, cross-agency workshops and terrorism financing prosecution training are delivered each year; all actions receive central oversight.

Are there plans?

The SA NPO task team was established on 10 December 2018 consisting of the following departments - FIC; Department of Social Development's (DSD); Non-profit Organisation Directorate; SARS; SAPS; Directorate for Priority Crime Investigation (DPCI); National Intelligence Co-ordinating Committee (NICOC); SARB; Prudential Authority and Companies and Intellectual Property Commission (CIPC). Its purpose is to meet regularly to discuss ML and TF risks to the South African NPO sector. Structured plans enable annual risk assessment cycles for terrorism financing, sector refresh, and ongoing process improvement, with milestones tracked into the mutual evaluation cycle.

Is it on the agenda?

Government raised AML/CFT as an agenda in the mid-2000s with the objective of strengthening measures to align with global standards. With regards to NPOs, this pertains to the ongoing campaign against terrorist financing where terrorist organisations exploit the NPO sector. This is a top recurring priority in Cabinet’s security, finance and justice cluster meetings, explicitly referenced in National Treasury and Ministry of Police agendas.

Goals

The goal of South Africa's response to terrorism financing is to comprehensively identify, assess and mitigate the risks of terrorist financing to the country and its financial and non-financial sectors, including banks, businesses, and non-profit organisations. Close NPO and systemic terrorist financing risks; deliver robust sector risk management and prosecution.