The Financial Intelligence Centre (FIC) has released its annual report covering the key period of April 2024 to March 2025. With South Africa's removal from the FATF greylist on 24 October, this year's release carries particular significance as it provides insight into the progress that led to this milestone achievement.
Acknowledging Key Achievements
The impressive achievements highlighted in this report deserve recognition for key stakeholders, including Pieter Smit (Acting Director), Christopher Malan (Compliance and Prevention), Priya Biseswar (Monitoring and Analysis), and Pieter Alberts (Shared Forensics). The dedication and commitment of the leadership at the FIC over the last year have been evident across the sector.
Capacity challenges in terms of understaffing and lack of skills at the FIC as well as other key partners in our financial crimefighting ecosystem has been widely reports and had a tangible impact in our country’s ability to detect, analyse, investigate and ultimately prosecute financial and terrorist related crime, but despite this, capacity at the FIC grew by 22 to a total of 275 employees. That represents a nearly 9% increase in headcount, and with this bolstered capacity, it managed to achieve eighteen of its twenty annual performance targets.
Strategic Focus Areas:
The FIC is focused on efficiencies and actively involved in:
- Enhancing technology capabilities including, the continued deployment of AI and machine learning
- Building institutional competencies to improve organisational performance
- Analysis and re-skilling of roles requiring forensic accounting, data management, and data analytics competencies
- Ongoing employee retention strategies
Key achievements and outcomes for the year:
- The FIC contributed to the recovery of close to R144 million in criminal proceeds by providing 4,196 financial intelligence reports and 51 reports on illicit financial flows to law enforcement for their investigations, prosecutions, and applications for asset forfeiture.
- They also blocked more than R157.5 million as suspected proceeds of crime, issuing 164 section 34 directives that instructed financial institutions not to proceed with transactions while investigations were conducted.
- The Asset Recovery Hub launched 11 investigations, recovering over R33 million in proceeds of crime using a non-conviction-based confiscation approach, enabling asset seizure without a prior criminal conviction by converting FIC intelligence into admissible court evidence for civil forfeiture.
Report for the FIC – the driving force
The 13.52m intelligence reports submitted by the front line are the vital starting point for driving prosecution.
- These included 3.16 million cash threshold reports, outside of Banks, the lions share were submitted by gambling institutions and foreign exchange firms.
- Of the 570,000 suspicious transaction reports, excluding Banks, were driven by cross-border money/transfer providers and high-value goods dealers.
- 10 terrorist property reports were submitted, with 40% from Estate Agents and the remainder from legal practitioners and cross-border money/transfer providers.
Oversight & Remediation
The FIC undertook 46 FICA awareness initiatives, from webinars to in-person event and there has been great attendance and a clear pull from Accountable Institutions for greater insight and support from the FIC.
The FIC undertook 46 FICA awareness initiatives, from webinars to in-person events – there has been great attendance and a clear pull from Accountable Institutions for greater insight and support from the FIC.
This could partly be due to the increased monitoring and oversight in the period, with 556 inspections, including 340 thematic reviews on Risk Compliance Return (RCR) submissions and RMCP compliance, and 157 full audits.
There were 55,626 registered Accountable Institutions at the end of the period (up by 4,242), so this represents around one in every 78 institutions receiving a knock on the door.
Legal practitioners received the most inspection reports (242), followed by estate agents (165) and high-value goods dealers (70).
Sadly, inspections revealed widespread non-compliance among DNFBPs, particularly in business risk assessments, implementation of RMCPs, timely FIC registration, risk-based customer due diligence, sanctions screening, and identifying beneficial ownership and politically exposed persons.
The percentage of RCR compliance sat at 70% overall, with legal practitioners and estate agents continuing to lag behind.
Remedial actions were prescribed for 330 non-compliant institutions and those who did not remediate their non-compliance received either admissions of non-compliance fines or are awaiting the FIC’s adjudication panel for sanctioning.
Sanctions imposed by the FIC totalled R782,000, with an additional R1.18m paid as part of admission of non-compliance process.
The Prudential Authority undertook 22 inspections and issued R146.65m in sanctions, and the Financial Surveillance department imposed sanctions of R1.22m from 32 inspections undertaken.
The Financial Service Conduct Authority inspected 132 institutions and imposed R4.5m in sanctions, and received an additional R2.9m from a dismissed appeal.
- The largest fine in the period handed to Capitec Bank (Retail) at R38m (R6m conditionally suspected) for, amongst other elements, failures in client due diligence, failures in cash reporting, failure to submit timely suspicious reports.
- The second largest fine was handed to Capitec Bank (Business) at R18.25m (R2.5m conditionally suspected) for, amongst other elements, failures in client due diligence.
- The third largest was Old Mutual Life Assurance at R15.9m (R5.9m conditionally suspended) for amongst other elements, failures in client due diligence, failures in cash reporting, failure to submit timely suspicious reports.
Supporting Guidance
It wasn't all enforcement action. The FIC published key guidance to support Accountable Institutions, including:
- Directive 3A (31 March 2025) - Dealt with the requirement for notification to the FIC of failure to report.
- PCC 50A (31 March 2025) - Dealt with the requirement for notification to the FIC of failure to report.
- Draft PCC 118A (31 March 2025) - Published for consultation on the money and value transfer service providers sector. Guidance Note 7A (13 February 2025) - Replaced
- Guidance Note 7 by including an update to Chapter 4 on the risk management and compliance programme.
- Draft PCC 23A (18 December 2024) - Published for consultation on the interpretation of credit providers.
- Directive 9 (15 November 2024) - Prescribed information to be submitted as part of transactions involving crypto asset service providers.
- PCC 59 (8 August 2024) - Provided guidance on beneficial ownership, including risk factors and alerts relating to the identification of beneficial owners and strongly recommended the use of 5% shareholding threshold. This PCC replaced draft PCC 121 and draft PCC 121A, previously published for consultation.
- Terrorist Financing Risk Assessment for the non-profit sector
The Road Ahead: Compliance Cannot Be Complacent
It has been a busy year all round for the FIC and Accountable Institutions.
The temptation will be to view October's greylisting delisting as "mission accomplished" and sit back admiring our shiny new RMCP on the shelf.
Financial crime is like a game of cat and mouse. As criminals up their game and become ever more creative in their schemes, FATF standards will continue to evolve and to strengthen. This means countries need to constantly improve in order to keep up.
Cambodia, Nicaragua, Panama and Pakistan, have been greylisted multiple times, showing that delisting isn't permanent protection against future listing.
Taking FICA and compliance seriously must be the new normal.
If you haven’t done so already, we encourage you to review the Financial Intelligence Centre’s detailed Annual Report for further insights.
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