
Draft amendments aim to remedy gaps in AML framework
The Bill largely clarifies and strengthens existing AML/CFT expectations rather than introducing a new regulatory philosophy.

The Bill largely clarifies and strengthens existing AML/CFT expectations rather than introducing a new regulatory philosophy.

The Bill proposes that arrangements yielding outcomes similar to traditional financial products be treated as financial services.

Accountable institutions will have to provide comprehensive information on the location of their operations when registering with the Financial Intelligence Centre.

Accountable institutions should adopt practical, risk-based RMCPs tailored to their operations, rather than relying on lengthy templates.

A 2021 inspection found late submission of suspicious activity reports, inadequate staff training, delayed monitoring responses, and shortcomings in the bank’s RMCP.

The authorities say that supervision, prosecutions, and measurable outcomes must continue to avoid re-listing as the next mutual evaluation starts in 2026.

While submissions of the mandatory Risk and Compliance Return improved over the past year, 30% of institutions targeted by the FIC’s directives had not complied by March 2025

Requests for reports from the FIC rose by 17% in 2024/25, reflecting the FATF’s pressure on South Africa to strengthen its anti-money laundering efforts.

New criteria require closer supervisory scrutiny of DNFBPs on market entry, ongoing oversight, and high-quality suspicious-transaction reporting.

The updated guidance gives concrete examples of compliance failures and explicitly states that poorly documented RMCPs may be treated as non-compliant.

Ensure registrations and filings are finalised by 5pm on 8 September and back up all records – the old system will be retired after the upgrade.

The sessions will cover institutions’ regulatory reporting obligations and establishing beneficial ownership.

Institutions that are wrongly registered as ‘business entities with a reporting obligation’ face being sanctioned by the FIC.

An RMCP must set out the processes for identifying, investigating, and reporting suspicious transactions, and for screening clients against the sanctions lists.

The Centre, through inspections and compliance monitoring, will test an RMCP against the legislative requirements.

Financial institutions that proactively embed governance, technology, and culture to meet evolving regulatory standards will not only avoid penalties but also strengthen credibility, build resilience, and drive long term value.

The Financial Intelligence Centre issues a stern reminder to designated non-financial entities – particularly legal practitioners and estate agents – to file their overdue risk and compliance returns.