Two enforcement actions published days apart – including a R2-million administrative penalty – point to the Financial Sector Conduct Authority’s tightening the net around unauthorised investment schemes, where operating outside the licensing framework and marketing to the public is increasingly met with multi-year bans and significant financial penalties.
In the first matter, published on 1 April, the FSCA acted against Khanyazania Holdings (Pty) Ltd and Azania Investors (Pty) Ltd, along with three individuals.
The regulator imposed:
- An administrative penalty of R200 000 on Khanyazania Holdings and its directors, Simiso Anthony Manatha and Nqobi Ephraim Thwala, jointly and severally.
- A further R200 000 penalty on Azania Investors and Manatha.
It also debarred Manatha for 15 years, Thwala for 10 years, and Khwezi Jackson for five years.
The FSCA said its investigation found that Khanyazania Holdings, Azania Investors, Manatha, and Thwala contravened section 7(1) of the Financial Advisory and Intermediariy Services Act by rendering financial services without authorisation.
Jackson was found to have contravened section 13(1)(a) by rendering services on behalf of an unauthorised entity.
Both companies, among other activities, offered investments in shares to members of the public.
A day later, on 2 April, the FSCA announced a second – and more financially significant – action.
It imposed an administrative penalty of R2m on Acqumen Fund (Pty) Ltd and its director, Mohamed Ebrahim Amod, jointly and severally.
Amod was debarred for 12 years, while Junaid Ebrahim Salejee received a seven-year debarment.
In this case, the FSCA found that Acqumen Fund and Amod also contravened section 7(1) of the FAIS Act by operating without authorisation.
It further found that Acqumen Fund, Amod, and Salejee breached section 3(a) of the General Code of Conduct in a material way when they presented, marketed, canvassed for, advertised and/or explained the investment business to clients.
The offering included investments in shares and debentures marketed to the public.
A pattern is becoming clear
Looking at the two matters together, a clear pattern emerges. The FSCA is focusing on:
- unlicensed investment activity;
- active marketing to clients; and
- company structures used to present investment offerings.
This lines up with its latest enforcement data. In the 2024/25 financial year, the FSCA:
- finalised 633 investigations;
- debarred 131 individuals; and
- imposed 51 administrative penalties totalling R119.8m.
At the same time, the pipeline is growing. The FSCA opened 767 new cases, with more than 70% linked to unregistered financial services and insurance activity.
Enforcement is scaling up
The shift becomes clearer when you look at the trend over time.
In 2023/24, the FSCA imposed administrative penalties of just over R943m, up sharply from about R100m the year before.
By 2024/25, the number of investigations and debarments had increased further, even though total penalties were lower.
Put simply: more cases are being pursued, and enforcement remains active and visible.
Recent cases reported by Moonstone show the scale of this shift.
In December 2025, the FSCA imposed a record R2bn administrative penalty on Banxso (Pty) Ltd and its directors, including Harel Adam Sekler and Warwick David Sneider.
Read: FSCA slaps Banxso and directors with record R2bn fine
The regulator found that clients were misled and funds were misused.
Additional penalties were imposed on individuals:
- Manuel de Andrade – R20m.
- Mohammed Bux – R10m.
- Henry James Simpson – R5m.
Several individuals were debarred for up to 30 years, among the longest bans issued to date.
The case also involved regulatory action against Afrimarkets Capital (Pty) Ltd, whose licence was provisionally withdrawn last year.
Read: Authority acts against online trading platforms
Another case saw the FSCA act against the Medbond Group, including:
- Medbond Insurance Brokers (Pty) Ltd
- Medbond Markets (Pty) Ltd
- Medbond Fund Managers (Pty) Ltd
- Masjamplan (Pty) Ltd
Read: Multimillion-rand penalties levied across Medbond Group
The regulator imposed a combined R212m in penalties, including R197m against Medbond Insurance Brokers and its principal, Jacobus Meyer, who was debarred for 30 years.
The FSCA found that client funds were not invested as promised, but misappropriated, with unlicensed entities used in the structure.
Other Moonstone-reported cases follow the same pattern:
- A 6m penalty and 15-year debarment linked to unauthorised insurance activity.
- A R9m penalty and 20-year debarment in a forex-related scheme.
Across these matters, the same elements come up again and again: misrepresentation, unauthorised activity, and long-term bans.
But do the fines get paid?
As the numbers grow, an obvious question follows: how much of these penalties are actually recovered?
In law, administrative penalties can be enforced as civil judgments, meaning the FSCA can pursue recovery through the courts. In practice, it is not always that straightforward.
Decisions can be challenged at the Financial Services Tribunal, penalties may be partially suspended, and some high-profile cases have already signalled plans to contest enforcement action.
The FSCA does not routinely publish recovery rates, so it is not clear how much of the hundreds of millions – and in some cases billions – of rands imposed in penalties are ultimately collected.
What is clear is where the money goes. Administrative penalties are paid into the National Revenue Fund, not to the FSCA, and not directly to affected investors.
No let-up after grey listing
This push on enforcement also links to South Africa’s recent journey through the Financial Action Task Force’s grey listing process.
The country was placed on the grey list in February 2023 and removed in October 2025 after addressing deficiencies in its AML/CFT framework. But regulators have been clear that this is not the end of the process.
The FSCA welcomed the decision, noting that “ongoing vigilance, effective enforcement, and cooperation… remain critical”.
Regulators have emphasised there will be no easing of enforcement, with continued focus on investigations, sanctions, and measurable outcomes.
Read: Exiting the grey list won’t relax oversight – regulators pledge continued enforcement
This is particularly relevant as South Africa prepares for its next FATF mutual evaluation, expected to get under way in 2026, where the emphasis will be on how effective enforcement is in practice. That raises the bar.
It is no longer enough to have the right rules in place. Authorities must demonstrate that:
- misconduct is identified and investigated;
- enforcement action is taken; and
- sanctions are imposed and followed through.
Exiting the grey list was a milestone, but maintaining that position will depend on continued, and demonstrable, regulatory action.
