South Africa AML After the FATF Grey List Exit: What Accountants Need to Know

South Africa was removed from the Financial Action Task Force (FATF) grey list on 24 October 2025, after almost three years of reform. For accountants, auditors and other professionals, the exit does not mean the pressure is off. The country now has to show that its new controls work, and a further FATF mutual evaluation is expected in the next couple of years. This guide explains what happened, which reforms matter in practice, and how to keep your own anti-money laundering (AML) controls ready. If you are new to the FATF and its lists, start with our explainer on the FATF, the 40 Recommendations and the grey and black lists.

What happened and when

According to Baker McKenzie, South Africa was placed on the grey list in February 2023 after the FATF found serious gaps in its AML and counter-terrorist financing framework. The weaknesses included limited enforcement, limited transparency around beneficial ownership and gaps in asset recovery. The South African Institute of Chartered Accountants (SAICA) confirms the February 2023 listing and says the country completed all 22 actions in the FATF Action Plan. SAICA's statement, dated 24 October 2025, welcomed the removal. Baker McKenzie reports that the decision followed a successful on-site review in July 2025.

The reforms behind the exit

Baker McKenzie lists the main legislative and enforcement changes as follows.

• Financial Intelligence Centre Act (FIC Act). Schedule 1 was amended to bring crypto-asset service providers and high-value goods dealers under regulation.
• Companies Act. It was amended and the Companies and Intellectual Property Commission (CIPC) beneficial ownership register was launched. Interests of 5% or more must be disclosed, and annual returns are blocked without prior beneficial ownership filings.
• Enforcement. Funding was increased for the Hawks and the National Prosecuting Authority.
• Reporting. Obligations under sections 28 and 29 of the FIC Act, covering cash threshold and suspicious transaction reporting, were made stricter.
• Anti-corruption. The Prevention and Combating of Corrupt Activities Act gained a new offence of failing to prevent corrupt activities by private companies and state-owned entities.

SAICA adds that it contributed to the reform process, including the General Laws (AML/CFT) Amendment Act of 2022 and amendments to the Financial Intelligence Centre Act (often shortened to FICA).

What stays the same for accountable institutions

Baker McKenzie's reading is that accountable institutions must keep running robust, risk-based compliance programmes, ensure beneficial ownership disclosures are accurate, apply enhanced due diligence to high-risk transactions and expect heightened supervision of high-risk sectors. Delisting is therefore best treated as a reason to keep standards up rather than relax them.

Why beneficial ownership matters most to accountants

SAICA says that accountants and auditors who act as trust and company service providers must help clients collect, verify and submit accurate and up-to-date beneficial ownership information to the CIPC and the Master of the High Court, and it urges members to meet these enhanced requirements. In practical terms, the beneficial ownership register is now a place where your work can be seen. A mismatch between what you hold on file and what the client has filed is a red flag.

Our guides on ultimate beneficial ownership for accountants and trust and company service provider obligations cover the underlying concepts. The rules differ by country, so use them for the principles and rely on South African law and SAICA guidance for the detail.

A practical checklist for South African practices

1. Review your risk management and compliance programme. SAICA has published guidance and tools on these programmes and on the expanded definition of accountable institutions. Check that yours reflects the current law.
2. Reconcile beneficial ownership. Compare your client files with the CIPC register for each company you serve, and resolve any difference before the next filing.
3. Check your reporting routes. Make sure staff know how to escalate a suspicion and who files under section 29.
4. Look at clients in newly covered sectors. Crypto-asset service providers and high-value goods dealers now fall within the Act, so treat them as a distinct risk category.
5. Keep training current. SAICA has run monthly Compliance in Practice webinars since November 2023, which is a useful low-cost option alongside your own induction.
6. Document your reasoning. Supervisors will want to see why you rated clients as you did, not just the rating.

What comes next

Baker McKenzie notes that South Africa needs to keep political commitment and enforcement consistent, improve continuous monitoring, real-time data sharing and inter-agency coordination, and prepare for its next FATF mutual evaluation, which it expects in 2026 to 2027, in order to avoid being listed again. For professionals, that suggests supervisory attention will focus on whether the new rules are applied in practice, not only on whether they exist.

Frequently asked questions

When did South Africa leave the FATF grey list?

The removal is dated 24 October 2025. South Africa had been listed since February 2023.

Does leaving the grey list reduce my compliance duties?

No. The sources point to continued risk-based compliance, accurate beneficial ownership and heightened supervision of high-risk sectors.

What is the beneficial ownership threshold on the CIPC register?

Baker McKenzie reports that interests of 5% or more must be disclosed. Check the current wording of the law and CIPC guidance before relying on it.

Who regulates accountants for AML in South Africa?

This guide does not cover supervisory detail. Check the Financial Intelligence Centre and SAICA for the current position on your category of registration.

Next steps

Work through the checklist above, starting with beneficial ownership reconciliation. If you are building wider AML skills for a global career, explore Learnsignal's CPD courses. This article is general information, not legal advice, and you should confirm the detail with South African legislation and your supervisor.