What Company Secretaries and Compliance Officers Need to Know

On 24 October 2025, South Africa officially exited the Financial Action Task Force (FATF) grey list after just under three years of intensive reform. For those of us working in corporate governance and compliance, this milestone represents both a victory and the beginning of a longer journey toward sustained vigilance.

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From Greylisting to Delisting - and Beyond

South Africa was placed on the FATF grey list in February 2023 due to deficiencies in the enforcement of its anti-money-laundering and counter-terrorist-financing (AML/CFT) laws. The challenge was not weak legislation but weak implementation - a legacy of the state-capture era that eroded institutional capacity and accountability.

Over the past two years, government departments, regulators, and the private sector collaborated to close all 22 action items in the FATF remediation plan. Key reforms included:

• Legislative amendments to six major laws, including the Financial Intelligence Centre Act and the Companies Act
• A marked increase in money-laundering investigations and prosecutions
• Improved beneficial-ownership transparency via the CIPC and Masters’ Offices
• Strengthened supervisory frameworks for financial and non-financial institutions
• Expanded regulatory oversight for crypto service providers, estate agents, and other previously under-regulated sectors

This coordinated response has restored South Africa’s standing in the global financial system and, for now, removed the reputational drag of greylisting.

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Lessons from Other Jurisdictions

South Africa’s swift turnaround - under three years - compares favourably with the global average of roughly five. According to FATF, 86 jurisdictions have successfully exited enhanced monitoring after implementing required reforms.

However, the record also shows that exiting the grey list is not the same as staying off it. Some countries have later been re-examined after enforcement momentum slowed or political commitment waned.

The experience of nations such as Pakistan and Turkey underscores that delisting brings ongoing scrutiny. FATF continues to monitor jurisdictions post-exit, and complacency can lead to re-evaluation. The jurisdictions that remain off the list tend to share three traits: Continuous enforcement outcomes, resilient institutions, and political stability around anti-corruption policy.

For company secretaries and compliance officers, these global lessons are directly relevant - the sustainability of reform depends as much on private-sector compliance as on state capacity.

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What delisting means for your practice

Smoother cross-border transactions: Foreign banks can now ease the enhanced due diligence requirements applied to South African transactions during the greylisting period. The result is faster payments, lower transaction costs, and fewer compliance-related delays for clients engaged in trade, investment or fund transfers.

Renewed investor confidence: Delisting signals that South Africa meets global standards for financial transparency and accountability, improving access to foreign direct investment and correspondent banking services.

Reduced compliance friction, not fewer obligations: While international scrutiny will ease, regulators at home - notably the FSCA and FIC - have increased enforcement activity and penalties for FICA-related breaches. The local compliance burden may, in fact, rise as authorities entrench a culture of zero tolerance.

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Staying the course: Key considerations

1. Stricter enforcement is here to stay. Expect continued regulatory focus on beneficial ownership, politically exposed persons, and record-keeping obligations
2. Crypto and virtual assets are now mainstream regulatory concerns. Exchanges and intermediaries fall under both FAIS and FIC Acts - advise clients accordingly
3. The next FATF mutual evaluation looms. Preliminary assessments begin in 2026, with conclusions expected in 2027. Performance during this period will determine whether South Africa remains in good standing
4. Sustained evidence matters. FATF’s follow-up process looks for measurable outcomes - not just legal compliance, but actual prosecutions, convictions, and asset recoveries.

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Guidance for Company Secretaries

As gatekeepers of corporate governance, consider the following actions:

• Revisit your AML/CFT risk assessments to align with post-greylist realities
• Verify that beneficial-ownership information is current and accurately reflected at the CIPC
• Brief directors and senior management on continuing FICA and Companies Act obligations
• Maintain detailed compliance documentation; FATF reviews focus on evidence of consistent implementation
• Monitor circulars and guidance from the FIC, FSCA, and CIPC for evolving expectations
• Arrange periodic refresher training to ensure teams can identify and report suspicious activity
• Where possible, commission independent “AML health-checks” to test the strength of your internal systems

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A word of caution

Delisting removes a layer of international risk but not the underlying threat of financial crime. As FATF itself warns, exit from monitoring “does not shield a country from scrutiny.” Criminal methodologies evolve, and so must compliance frameworks.

For professionals in company secretarial and compliance roles, this means embedding the culture of reform into daily practice - not because regulators demand it, but because clients, investors, and counterparties expect it.

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Conclusion

South Africa’s rapid exit from the FATF grey list is both a regional benchmark and a reminder of what consistent collaboration can achieve. It demonstrates that when government, regulators, and the private sector align around shared accountability, meaningful reform follows.

The challenge now is endurance. The next two years, leading to the 2026 FATF evaluation, will determine whether the systems built to achieve delisting can withstand complacency and political drift.

If we maintain our current momentum, South Africa can join the ranks of jurisdictions that not only earned removal from the grey list but have stayed off it - setting a standard for corporate integrity that others look to emulate.