--- title: "One year after the grey list: what the FIC’s numbers are telling us" description: "The FIC’s 2025/26 Annual Report one year after the grey list: rising registrations, stretched capacity and firmer enforcement. 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Read on its own, it reads as a solid year about an organisation that threw everything at getting South Africa off the FATF grey list, succeeded, and is now working out what the new "normal" looks like. ``` Put against the previous two reports, the picture shows that along with the successes came some tough challenges. South Africa's removal from the FATF grey list in October 2025 in under three years was no mean feat and both the Minister and the new Director treat it as a genuine national achievement. The sobering ‘morning after’ is that the next joint FATF and ESAAMLG mutual evaluation has already started and runs to October 2027. This time they’re here to check if the fixes are real and are lasting, and perhaps more importantly, effective in terms of actual prosecutions. If we look at some of the key metrics, we can see a little insight into the reality of the FIC over the last year. To the FIC's credit, it doesn't hide the challenges. Here are some key headlines: | Measure | 2023/24 | 2024/25 | 2025/26 | | --- | --- | --- | --- | | Registered institutions | 51 020 | 55 262 | 60 115 | | Regulatory reports received | ~7.4m | ~13.5m | ~10.8m | | Financial intelligence reports produced | ~3 663 | 4 196 | 4 194 | | Risk-based inspections | 558 | 556 | 549 | | Sanction issued | 9 | 25 | 28 | | Criminal proceeds recovered (with FIC intelligence) | R98.5m | ~R144m | ~R37.5m | | Funds blocked under section 34 | R295.9m | R157.5m | R34.2m | | Staff at year-end | 257 | 275 | 273 | ## **Registrations keep climbing, but capacity is not keeping up** The number of registered Accountable Institutions rose to 60,115, an 18% rise over the last three years. More businesses are on the radar, and the FIC now directly supervises more than 80% of all them. However, whilst the base grew by almost 9,000 in the same period, the total FIC headcount stayed effectively the same. That does not hold for long without some serious efficiencies being made. With FIC inspections hovering consistently at around 550 a year, getting to every registered institution once would take about a century. Thankfully, Inspections are risk-based, so nobody expects full coverage, and with other supervisors such as the FSCA, the FIC’s number is only part of the picture. At least for now the sample size is comfortably valid but with the ratio shrinking, which perhaps sits uncomfortably with the message that supervision is tightening, if that ratio starts to head toward the 0.8% mark, the picture they see (and make decisions on) might not be representative of what's really happening on the ground. | | 2023/24 | 2024/25 | 2025/26 | | --- | --- | --- | --- | | Inspections as % of registered institutions | 1.09% | 1.01% | 0.91% | ## **The spotlight continues to shine on two key categories** Law firms and Estate Agents continue to be the flavours of the year when it comes to inspections, though interestingly they were the most responsive in submitting their Risk and Compliance Returns at 76%. The weakest RCR responders were High Value Goods Dealers, so I would expect them to potentially be on the radar soon. ## **Enforcement has grown real teeth.** In the latest year the FIC issued 361 "admission of non-compliance" notices, aimed overwhelmingly at businesses that hadn't submitted their Risk and Compliance Return (RCR). The RCR gives the FIC deep insight into Accountable Institutions, to help them assess risk within sectors and individual businesses. This helps with their focus on identifying higher-risk institutions. Non-return of RCR’s is an indicator of compliance to the FIC – so if you haven't responded to Directives 6,7 or 11 – now is not the time to be complacent. Total FIC financial penalties for the year came to R2 125 000. This is up from R1.3m in 2023/4. The supervisory bodies piled on too: the SARB's Prudential Authority imposed R37 million in sanctions, its Financial Surveillance department just under R1.5 million, and the FSCA R16.56 million. The pattern across the three years is consistent, and the direction of travel is firmer, not softer. This re-iterated the message that Compliance is getting serious. ## **The audit has stayed clean all three years** For a public entity this matters, let alone one that heads up the country's fight against financial related crimes! Kudos to the FIC for their governance, avoiding the headlines and setting an example. ## **The FIC showed up for the big corruption work** The FIC fed key financial intelligence into the Madlanga Commission and closed out the last of the State Capture (Zondo) Commission recommendations. But the report also highlights key cases throughout that the FIC has contributed to, from abalone poaching and Ponzi schemes to drugs trafficked with links to Colombia. Sadly, most state to be ‘under investigation’ by authorities, which is out of the hands of the FIC, but one thing the FATF will likely be looking for during their trip to South Africa is actual consistent and sustained asset forfeiture and prosecution of these kinds of crimes and not just that Institutions on the front line are identifying the UBO. ## **Recovered and Blocked figures have fallen sharply.** Recovered numbers depend entirely on the cases, law enforcement and the asset forfeiture unit. The FIC produces intelligence; others need to act on it, so there is limited data in the report that we can draw insight from. Blocked funds (under s34) are also down, and whilst being a vital tool for interventions, the why is also not clear. Is the FIC being more selective? Or were there fewer large cases last year? Again, we can't make any assumptions. ## **The volume of regulatory reports is fluctuating.** Reports jumped from 7.4m in 2024 to 13.8m in 2025, before dropping back to 10.8m last year. There is no explanation given, and with so many potential explanations, it’s difficult to know why. ## **There's also new leadership at the helm** Thabiso Thiti took over as Director in April 2026, after Pieter Smit's long run as Acting Director through the grey-listing period. With a Master's in Public and Development Management and a BA in International Relations and Political Studies, Mr. Thiti comes with over 20 years' experience, with his most recent role as Director General for Institutional Development at the Department of Justice and Constitutional Development. On behalf of everyone at nCino KYC, we thank Pieter for his sterling work and engagement with us over the past three years and offer Mr. Thiti our full support. ### My final thoughts... It has been a roller coaster ride for the FIC over the last three years, but their achievements can’t be ignored. Combined with the challenges of staffing, this seems more impressive. But the law of unintended consequence plays a part here. The FIC’s own push for better, more widespread compliance on the front line has led to a bidding war on skilled talent. They created a competitive environment, where they, alongside the smaller Accountable Institutions, are arguably unable to compete. As the FIC continue their work through initiatives such as Directive 11 to gain further insight into the national compliance levels, there are still some thoughts I had about the future. If we can shorten the path from intelligence to recovery and publish the conversion rate from intelligence products to investigations, prosecutions and recoveries that would perhaps tell us more than the raw rand figures. Where can we focus next to really move the needle of fighting financial crime in South Africa? Outside of that on the ground, not submitting an RCR seems to be the fastest surefire way to an administrative sanction – so get typing! South Africa threw a huge collective effort at the very specific problem of greylisting, passed, and is now in the harder, less glamorous phase of keeping the standard up while the people and resources that got it there come under strain. *For your business, the honest implication is that the pressure doesn't ease after the grey-list win, it just changes shape.* ![Hawken McEwan](https://blog.kycafrica.ncino.com/hubfs/Hawken.png) ### About the author: ### Hawken McEwan Hawken has over 25 years’ experience in financial crime compliance, regulatory operations, banking operations, risk and change. Specialising in FICA and Anti-Money Laundering, Hawken holds a Masters from the Edinburgh University, the AMLCPrac(SA) designation, and is a Certified Anti Money Laundering Specialist, Member of the Association of International Financial Crime Investigators and South African Board member for ACAMs ## Related Articles - ### [RMCP Compliance: What Directive 10, 12 and GN 7B Require](https://blog.kycafrica.ncino.com/rmcp-compliance-what-directive-10-12-and-gn-7b-require) ![RMCP Compliance: What Directive 10, 12 and GN 7B Require](https://blog.kycafrica.ncino.com/hubfs/RMCP%20Compliance_%20What%20Directive%2010%2c%2012%20and%20GN%207B%20Require.jpg) - ### [Important FIC Regulatory Updates: Directive 10, Draft Directive 12 & Guidance Note 7B](https://blog.kycafrica.ncino.com/fic-updates-directive-10-draft-directive-12-guidance-note-7b) ![Important FIC Regulatory Updates: Directive 10, Draft Directive 12 & Guidance Note 7B](https://blog.kycafrica.ncino.com/hubfs/Important%20FIC%20Regulatory%20Updates_%20Directive%2010%2c%20Draft%20Directive%2012%20%26%20Guidance%20Note%207B.jpg) - ### [What Are The Key Requirements That Need to be Met in Order to be FICA Compliant?](https://blog.kycafrica.ncino.com/the-key-requirements-that-need-to-be-met-in-order-to-be-fica-compliant) ![What Are The Key Requirements That Need to be Met in Order to be FICA Compliant?](https://blog.kycafrica.ncino.com/hubfs/The%20Key%20Requirements%20That%20Need%20to%20be%20Met%20in%20Order%20to%20be%20FICA%20Compliant.jpg) - ### [What is the Complete list of Accountable Institutions Under FICA?](https://blog.kycafrica.ncino.com/accountable-institutions-under-fica-complete-list-and-compliance-obligations) ![What is the Complete list of Accountable Institutions Under FICA?](https://blog.kycafrica.ncino.com/hubfs/nCino-KYC-Accountable-Institutions-Under-FICA-Complete-List-and-Compliance-Obligations-1.jpg) - ### [Everything You Need to Know About Ultimate Beneficial Owners \[Part 1\]](https://blog.kycafrica.ncino.com/everything-you-need-to-know-about-ultimate-beneficial-owners) ![Everything You Need to Know About Ultimate Beneficial Owners \[Part 1\]](https://blog.kycafrica.ncino.com/hubfs/Business%20man%20looking%20through%20a%20filling%20cabinet%20with%20illustrated%20diagram%20of%20UBO%20structure.png) ![nCino Full colour Logo](https://blog.kycafrica.ncino.com/hubfs/nCino%20Full%20colour%20Logo.svg) Subscribe to our newsletter [Subscribe](https://share-eu1.hsforms.com/1EGe3layITCaXlgtYEX6fSwetu2j) - - - - ### Solutions - [Client Onboarding](https://kycafrica.ncino.com/solutions/customer-onboarding/) - [Watchlist](https://kycafrica.ncino.com/solutions/watchlist-screening/) - [Risk Rating](https://kycafrica.ncino.com/solutions/risk-rating/) - [Bank Account Verification](https://kycafrica.ncino.com/solutions/account-verification/) - [Compliance Services](https://kycafrica.ncino.com/solutions/compliance-services/) - [Training and Webinars](https://kycafrica.ncino.com/solutions/training-and-webinars/) ### Industries - [nCino for Banks](https://www.ncino.com/) - [High Value Goods Dealers](https://kycafrica.ncino.com/industries/high-value-goods-dealers/) - [Law Firms](https://kycafrica.ncino.com/industries/law-firms/) - [Real Estate Industry](https://kycafrica.ncino.com/industries/real-estate-industry/) - [Stock Brokers](https://kycafrica.ncino.com/industries/stock-brokerage/) - [Forex Traders](https://kycafrica.ncino.com/industries/forex-traders/) - [Financial Service Providers](https://kycafrica.ncino.com/industries/financial-advisors/) - [Credit and Lending](https://kycafrica.ncino.com/industries/credit-and-lending/) - [Motor Vehicle Dealers](https://kycafrica.ncino.com/industries/motor-vehicle-dealers/) - [Other Accountable Institutions](https://kycafrica.ncino.com/industries/other-accountable-institutions/) ### Company - [About](https://kycafrica.ncino.com/about/) - [Press Releases](https://kycafrica.ncino.com/press/) - [Careers](https://www.ncino.com/our-company/careers) - [Contact](https://kycafrica.ncino.com/contact/) - [Partner with us](https://kycafrica.ncino.com/industries/our-partners/) - [FICA FAQ's](https://kycafrica.ncino.com/fica-faqs/) ### Legal & Compliance - [Terms and Conditions](https://kycafrica.ncino.com/terms-and-conditions/) - [Privacy Statement](https://kycafrica.ncino.com/privacy-policy/) - [PAIA Manual](https://kycafrica.ncino.com/wp-content/uploads/2025/03/nCino-SA-PAIA-Manual-March-2025-2.pdf) - Cookie Settings © 2016 – 2026 nCino. 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