While South Africa exited the Financial Action Task Force (FATF) greylist in October 2025, the country can’t afford to rest on its laurels. More work must be done. And the frontline against financial crime – accountable institutions such as law firms, property practitioners, financial institutions and high-value goods dealers – should be taking KYC, FICA and anti-money laundering (AML) seriously.
This is according to Hawk McEwan, Director of Risk and Compliance at nCino KYC Africa, who says the Financial Intelligence Centre (FIC) is cracking down on non-compliant businesses and individuals.
He notes that South Africa is currently rated compliant or largely compliant on 37 of the 39 FATF recommendations: “There are two that are currently partially compliant, so we're not completely failing. However, getting off the greylist in 2025 involved quite a technical and structural review. When we come to the next evaluation, which is starting next month, it's going to be completely different. It's going to look at effectiveness – whether or not those laws that we've implemented are actually working. Are we investigating these money laundering scandals? Are we prosecuting? Are we getting convictions? Have we recovered proceeds? Historically, that's always where South Africa's weaknesses have always been.”
McEwan says South Africa’s private sector plays a key role in providing the alerts and evidence needed to successfully prosecute financial crimes. He says: “They're dealing directly with customers and they can confirm identities and look for suspicious things there. They're dealing with the transactions. If they come across something they think is suspicious, they can report it to the FIC, whose analyst team will investigate and cross-check reports and build together a much bigger and more detailed picture of what's actually happening through the transaction flows using data they can get from banks on request.
“Some businesses, particularly the smaller and mid-sized organisations, might feel that they can relax now that South Africa is off the greylist,” he says. “But the FIC and the Financial Sector Conduct Authority (FSCA), which both carry out audits and inspections, have made it clear and have issued public notices indicating that supervision is absolutely not standing down. The focus is on the frontline – making sure they are screening against sanctions lists and politically exposed persons (PEP) and finding out who the beneficial owners are of complex entities and companies. Inspections are happening all the time. We're probably helping about two clients a week who are going through inspections.”
McEwan says many smaller and mid-sized businesses may neglect compliance, or might even become complicit in financial crime and money laundering. “If you look at the SME market, there are businesses just trying to survive: if someone comes along with an amazing deal to channel funds through their business and take a 10% cut, there is a real risk they will do so.”
He says: “If you are found to be non-compliant, there are a number of options. They can either instruct you to address the issue within a certain amount of time. You don't get very long – perhaps 14 to 30 days. They'll assess whether the organisation will potentially go forward for an administrative sanction, which is basically a fine. However, if the findings are serious, they might issue a fine without remediation. These might be as high as R50 million or R100 million, and there aren't many firms that can absorb such a huge fine. And if we look at the FIC risk and compliance return questionnaires sent out to all accountable institutions, many automatically got a R10 000 or greater fine for failing to submit theirs.”
Leveraging smart technology to combat financial crime
Thoroughly vetting millions of customers and transactions manually would prove near impossible, however. “That’s where software comes in,” he says. “Advanced KYC solutions with biometrics and liveness detection makes the collection and analysis of customer information and documents simpler, and eliminates human error, while ongoing, comprehensive screening of customers against a range of international lists ensures compliance.”
nCino KYC South Africa will host a conference at The Forum in Johannesburg on 24 June, giving businesses insights into the latest AML and FICA trends, with practical insights on topics like new risks and controls, crime patterns in South Africa, how FRAML, AI, Crypto and Quantum are redrawing the financial crime battlefield, and how human traffickers channel funds and exploit the system. Attendees will also have an opportunity to pose questions to guest speakers from the FIC.
For more information, and to buy tickets for this event, go to https://kycafrica.ncino.com/fighting-financial-crime-conference-2026/#tickets.
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