Off the grey list, still under the microscope

On 24 October 2025 the Financial Action Task Force removed South Africa from its list of jurisdictions under increased monitoring. The twenty-two action items agreed after the February 2023 listing had been addressed, and an on-site assessment in July 2025 confirmed the reforms were being sustained.

One reading since has been that the pressure is off. The record says otherwise, and the record is short.

What was said on the day

The task force’s own delisting text discharges nothing. It says South Africa “should continue to work with the FATF and ESAAMLG to sustain its improvements in its AML/CFT system”. That is an instruction to keep going, written into the decision that let us stop.

Advocate Pieter Smit, then acting director of the Financial Intelligence Centre, said that exiting the grey list is half the battle won and one that must continue. National Treasury, in the same statement that announced the exit, said neither government agencies nor regulated entities in the private sector can afford to become complacent and stop improving. Edward Kieswetter, then commissioner of the South African Revenue Service: “This delisting is a vote of confidence in South Africa’s progress, but it is not an end to our vigilance.”

Nobody who had done the work described it as finished.

What has happened since

Less than three months after the exit, on 15 January 2026, National Treasury published a draft General Laws Amendment Bill to address, in its own words, the remaining deficiencies identified in the 2021 mutual evaluation report. It was introduced in Parliament as B15-2026 on 27 May 2026 and is still before the portfolio committee.

Then the Centre’s own calendar. Directive 11 took effect on 1 April 2026 and required the risk and compliance return through goAML. Directive 10, effective 31 July 2026, requires institutions to file the geographic particulars of their business. Guidance Note 7B replaced Guidance Notes 7, 7A and Revised 7A on 3 August 2026, running proliferation financing through the whole document and tightening what is expected before a new product launches. Directive 12, gazetted on 4 September 2026, turns the risk management and compliance programme into an annual submission.

Count the deadlines in October 2026. Programme submission on 9 October for one set of sectors. Geographic particulars on 31 October. Programme submission on 31 October for estate agents, dealers in high-value goods, the Postbank, the Mint and crypto asset service providers. Three filings in one month, from four instruments issued in five months, all landing on the accountable institutions that are not banks.

Worth noting what did not happen. Schedule 1 has not been widened since the exit; its last expansion took effect on 19 December 2022. The extra work has come from directives and guidance applied to businesses already in scope. The Centre has also said further directives may follow, requiring all other accountable institutions, including authorised dealers and financial institutions, to file in the same way.

The next assessment is harder than the last one

South Africa’s next mutual evaluation falls in the fifth round, under the 2022 methodology, assessed jointly by the task force and the Eastern and Southern Africa Anti-Money Laundering Group. Treasury says it commences in 2026 and concludes in October 2027, and the task force’s assessment calendar gives a possible on-site in February 2027.

Three features of the fifth round matter more than the timing. It weights effectiveness more heavily, which means whether the laws are used rather than whether they exist. It scopes to the highest risks rather than covering everything evenly. And the cycle is six years against an average of about ten in earlier rounds, with a timebound roadmap of actions and automatic consequences for a country that has not delivered inside three years.

Then remember which action item was the last to clear. At the February 2025 plenary one strategic deficiency remained: demonstrating a sustained increase in investigations and prosecutions of serious and complex money laundering and the full range of terrorist financing activity. That is the hardest capability in the system to build, the easiest to lose, and precisely what an assessment weighted towards effectiveness will go looking for.

Nothing switched off for your counterparties

South Africa also came off the European Union list of high-risk third countries with effect from 29 January 2026, and does not appear on the United Kingdom’s list. Treasury said the useful thing about the European decision: removing the legislative requirement for enhanced due diligence does not compel financial institutions to change their own risk assessment policies. If your bank or your foreign buyer is still asking the questions it asked in 2024, that is the reason.

Two things I cannot tell you

Whether enforcement volumes have risen since the exit is not answerable from published data. The Centre’s most recently reported figures, 556 inspections and 25 administrative sanctions worth R2.228 million, cover the year to 31 March 2025 and therefore describe the period before delisting. Anyone presenting them as post-exit enforcement has misread the financial year.

Whether the economic benefit has landed is also open. The Trade Law Centre’s assessment in November 2025 was that neither the bond market nor the currency reacted meaningfully to the announcement, and attributed the rally around that period to easing local inflation, falling United States yields and higher metals prices. The friction was removed at the level of regulation. Behaviour follows later, if it follows.

What to do with this

If the grey list was the reason you were doing the work, the next eighteen months will be uncomfortable, because the reason has gone and the work has grown. If it was a deadline, you have another one: a possible on-site in February 2027, and it arrives as an assessment of whether any of this is real.

What this is not

Nothing here is legal advice, and the dates above should be checked against the published notices before you rely on them.