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SA Removed from the FATF Greylist

October 28, 2025 by Sam Strand

Johannesburg — 28 October 2025. South Africa has been removed from the Financial Action Task Force’s (FATF) “grey list,” ending nearly three years of enhanced monitoring and marking a pivotal moment for the country’s financial system and global standing. The decision, taken at the FATF Plenary held in Paris from 22–24 October 2025, follows the completion of a 22-point remedial action plan and an on-site assessment earlier this year. FATF simultaneously delisted Nigeria, Mozambique and Burkina Faso.

The delisting is widely expected to ease cross-border flows, reduce compliance frictions for South African counterparties, and bolster investor confidence—early market reactions have already reflected cautious optimism. International coverage highlighted the macro-level importance of the move for Africa’s most industrialised economy and for banks that had faced elevated due-diligence hurdles since 2023.

Government agencies welcomed the outcome as validation of a multi-year, whole-of-government campaign to repair anti-money laundering and counter-terrorist financing (AML/CFT) controls. The South African Revenue Service (SARS) called the decision “a significant moment” and emphasised continued vigilance to avoid any backsliding. 


Why South Africa was Greylisted 

The FATF grey-listed South Africa in February 2023 after identifying “strategic deficiencies” in the country’s AML/CFT regime. The decision followed the fourth-round Mutual Evaluation that assessed South Africa’s technical compliance and effectiveness against the FATF’s 40 Recommendations, finding major shortcomings—including weak outcomes on investigations, prosecutions and asset recovery, as well as gaps in beneficial ownership transparency and risk-based supervision of non-financial sectors. 

Legal and civil society analyses at the time underscored the breadth of the issues. Commentaries pointed to governance erosion during the “state capture” era, capacity constraints across enforcement agencies, and thin supervision of designated non-financial businesses and professions (DNFBPs). Corruption Watch, summarising the FATF Action Plan, highlighted required improvements such as sustained mutual legal assistance (MLA) activity, stronger risk-based supervision, effective sanctions for non-compliance, and demonstrable increases in money-laundering investigations and confiscations.


The Impact of Greylisting: Costs, Frictions, and Reputational Risk

Greylisting is not a sanction, but it raises the risk profile of domestic transactions for foreign counterparties. Banks and investors typically apply enhanced due diligence, which increases costs and delays and can narrow access to cross-border services such as trade finance and correspondent banking. South Africa experienced these headwinds after February 2023; central bank officials repeatedly flagged the macro-financial costs and set the political tone for a 2025 exit—now achieved.

Beyond financial markets, greylisting strained already pressured public-sector capacity as agencies scrambled to implement reforms while coping with energy, logistics and fiscal challenges. The delisting eases one of those constraints and may catalyse further improvements in government-to-government cooperation on financial crime.


The Remedial Plan: 22 Actions Across Law, Supervision, and Enforcement

In the face of the greylisting threat, South Africa embarked on an intensive legislative and institutional overhaul since late 2022. The cornerstone was the General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act, 22 of 2022—a sweeping statute signed on 22 December 2022 and gazetted on 31 December—amending five statutes, including the Companies Act, Trust Property Control Act, Non-Profit Organisations Act, the Financial Intelligence Centre Act (FIC Act), and the Financial Sector Regulation Act. The reforms inserted clear definitions of “beneficial owner,” imposed new obligations on trustees and accountable institutions, and expanded supervisory and enforcement powers.

On 1 April 2023, the Companies and Intellectual Property Commission (CIPC) launched a national Beneficial Ownership Register, requiring companies and close corporations to file and update beneficial ownership information. This measure directly targeted FATF findings on transparency of legal persons and has become a central plank of South Africa’s AML architecture. Filing is mandatory and forms part of routine corporate compliance. 

Regulators reinforced these legal changes with guidance and supervisory action. The Financial Intelligence Centre published updated materials and ran consultations to clarify beneficial ownership obligations—especially the duty of accountable institutions to establish ownership and control structures of clients under section 21B of the FIC Act. Industry advisories stressed that beneficial owners are not always the same as legal owners and that firms must evidence robust due diligence. 

By mid-2025, National Treasury reported that all 22 action items in the FATF Plan had been “addressed or largely addressed,” setting the stage for the FATF’s on-site review in July and the October Plenary decision. FATF’s own follow-up assessments in 2024 and 2025 showed steady upgrades in South Africa’s technical compliance ratings, with the country ultimately “compliant” or “largely compliant” on the overwhelming majority of the 40 Recommendations. 


SA is Delisted - What Happens Now?

The FATF Plenary announced on 24 October 2025 that South Africa had completed its Action Plan and was no longer subject to increased monitoring. In the same communiqué, FATF introduced broader guidance on asset recovery, signalling the global body’s intent to maintain pressure on countries to turn legal frameworks into operational results.

Newswires and financial media framed the decision as a tailwind for South Africa’s economic outlook. Analysts expect a reduction in transaction frictions, improved risk-weighting by global correspondent banks, and potential lower funding costs for corporates and the sovereign—benefits that often accompany removal from FATF’s list. Early reporting noted a modest rand appreciation and expressed optimism about cross-border payments, trade finance, and investment flows. 

Domestically, revenue and law-enforcement agencies cautioned that delisting is not the finish line. SARS’ statement emphasised that the same inter-agency coordination that secured delisting—spanning tax enforcement, financial intelligence, policing, and prosecutorial authorities—will be needed to sustain progress and to rebuild public trust after years of institutional strain. 


What Changed: from Statutes to Supervision to Outcomes

Corporate transparency: The beneficial ownership regime is now embedded in company law and regulatory practice. CIPC’s register, coupled with amended Companies Act Regulations and FIC guidance, addresses a critical FATF concern: making it harder to hide behind opaque corporate structures. Companies must disclose natural persons who ultimately own or control them, keep records current, and expect regulator scrutiny; accountable institutions must verify this information as part of customer due diligence.

Non-profit oversight: Revisions to the Non-Profit Organisations Act improved transparency and risk-based oversight of NPOs—another area flagged in the evaluation—while trust law amendments tightened trustees’ duties and introduced clearer disqualification grounds. These changes reduce the risk of misuse of legal arrangements for illicit finance.

Supervision and sanctions: Supervisors across the financial and non-financial sectors upgraded their risk-based frameworks, intensified inspections, and sharpened sanctioning tools. FATF’s technical follow-up recorded upgrades across multiple Recommendations (including R.2, R.6 and R.15 in 2024), indicating stronger national coordination and higher alignment with standards on targeted financial sanctions and new-technology risks.

Law-Enforcement Outcomes: FATF required evidence that South Africa could convert statutes into casework: more investigations, prosecutions, confiscations, and MLA activity aligned with risk. Treasury’s 2025 updates reported material progress across these metrics, a crucial factor in convincing FATF assessors during the on-site visit that reforms were working in practice, not just on paper.


The road ahead: delisted, but under expectation

Delisting does not mean the end of FATF scrutiny. South Africa now transitions to routine follow-up in the 5th-roundmutual evaluation cycle, where assessors will expect sustained results, particularly on high-risk typologies and complex cases. FATF’s October note on asset recovery is a reminder that international focus is shifting from legal frameworks to recovering criminal proceeds at scale. Maintaining momentum on inter-agency tasking, data-sharing, and court throughput will be essential.

From a policy perspective, the reforms have created a more transparent and enforceable system, but they will require day-to-day operational discipline:

  • For Companies: keep beneficial ownership filings up to date with CIPC and maintain internal records that align with public filings and banking KYC questionnaires.
  • For Accountable Institutions: ensure client due diligence procedures fully capture ownership/control structures, including complex trusts and layered corporate chains, as required by the FIC Act. 
  • For NPOs and Trusts: understand new governance obligations and be prepared for risk-based supervisory reviews. 


What this Means for South African Businesses and Financial Institutions

With greylisting lifted, transaction counterparties abroad are less likely to apply blanket high-risk treatments to South African exposures. That should translate into smoother cross-border payments, friendlier correspondent-banking relationships, and lower frictional costs for exporters and investors. Several market commentators have already linked delisting to improved sentiment, with implications for capital costs and deal pipelines. 

However, firms should avoid complacency. International partners will watch real-world enforcement closely. Demonstrable compliance—particularly around beneficial ownership, sanctions screening (including proliferation financing risks), and monitoring of higher-risk customer segments—will remain decisive in onboarding decisions. FATF’s follow-up track record shows that countries can regress if momentum stalls; South Africa’s institutions are signalling that they intend to keep pressure on illicit finance networks.


Timeline: From Greylisting to Delisting

  • June–December 2022: Parliament fast-tracks omnibus reforms via the General Laws (AML/CTF) Amendment Act, signed on 22 December and gazetted on 31 December. 
  • 24 February 2023: FATF places South Africa under increased monitoring (“grey list”).
  • 1 April 2023: CIPC launches the Beneficial Ownership Register.
  • 2024: FATF upgrades multiple technical ratings; South Africa “compliant” or “largely compliant” on the vast majority of Recommendations.
  • 13 June 2025: Treasury announces the Action Plan is substantially complete (all 22 items addressed or largely addressed); FATF determines South Africa warrants an on-site. 
  • July 2025: FATF conducts on-site assessment in South Africa.
  • 24 October 2025: FATF Plenary removes South Africa from the grey list.


Bottom Line

South Africa’s delisting is earned, not gifted. It reflects extensive statutory reform, sharper supervision, and early operational gains across investigations and asset recovery. The payoff is tangible—lighter frictions with international counterparties and a reputational reset. But the system will only stay resilient if institutions maintain the tempo of enforcement and if the private sector embraces the spirit—not just the letter—of AML/CFT obligations.

For compliance leaders, now is the time to consolidate policies and controls, retrain on beneficial ownership and sanctions obligations, and test monitoring programmes against current risk typologies. For the economy, the message to the world is simple: South Africa has rebuilt the guardrails. The task now is to keep traffic moving safely within them.