RSA GVT Gray List Action Plan Progress


On Feb. 29, RSA GVT issued statement regarding FATF's action plan.


  • RSA GVT, RSA FSCA, RSA FIU published a media statement on South Africa's progress against its action plan, following its graylisting at Feb. 2023 FATF plenary meetings.
  • Follows FATF Feb. 2024 updated jurisdictions for increased monitoring, see #202336.
  • Action Plan
  • When FATF gray listed South Africa at the plenary meeting, a jointly agreed action plan was adopted listing 22 action items linked to strategic deficiencies in AML/CFT regime.
  • South Africa is required to address all 22 action items to exit the FATF gray list.
  • The deadlines for addressing the action items fall between Jan. 2024 to Jan. 2025.
  • If South Africa mostly addresses 22 actions by Feb. 2025 FATF will schedule onsite visit Apr./May 2025 to confirm assessment, make recommendation to Jun. 2025 plenary.
  • The Feb. 2024 FATF plenary adopted a report by the Joint Group, confirming that five of the 22 action items are now addressed or largely addressed.
  • FATF considered that two further actions that were previously not addressed have now been partly addressed, confirming 14 of 17 outstanding actions are partly addressed.
  • Three actions still have not been addressed as yet; deadline for South Africa to address, or at least largely address, 4 outstanding action items is May 2024.
  • RSA GVT notes that while South Africa is on track to address outstanding action items, it remains a tough challenge to address all 17 of remaining action items by Feb. 2025.
  • FATF Meeting Outcomes
  • South Africa participated in Feb 2024 FATF meetings where FATF took steps to promote effective implementation of measures against money laundering and the financing of terrorism and proliferation, other threats to integrity of international financial system.
  • Including adoption of new risk-based guidance for implementation of recommendation 25 on the beneficial ownership and transparency of legal arrangements.
  • Jul. 2024 Progress Update
  • On Jul. 2, 2024, RSA GVT, RSA FIU said FATF published the latest update on South Africa's progress in addressing the action items in its action plan as at Jun. 28, 2024.
  • Follows FATF Jun. 2024 released outcomes of the latest FATF plenary, see #217695.
  • Treasury does not expect South Africa to exit greylisting before Jun. 2025.
  • FATF Plenary accepted report of FATF Africa / Middle East Joint Group that South Africa largely addressed 3 further action items; 14 outstanding items left from original 22.
  • Many of the 14 outstanding items due in last two reporting cycles as South Africa has to show improvements made are sustained over successive reporting periods.
  • In the next reporting cycle, South Africa is required to address 9 of the outstanding action items that are due in Sep 2024; final 5 action items are due in Jan. 2025.
  • Oct. 2024 Progress Update
  • On Oct. 25, 2024, RSA GVT, RSA FIU updated on positive progress at FATF Plenary.
  • Follows, FATF Oct. 2024 issued outcomes of the Oct. 2024 FATF plenary, see #230972.
  • Said FATF announced 9 upgrades for RSA from its 22-item action plan, including 8 to largely addressed and one to partly addressed; leaving 6 outstanding to be addressed.
  • Now left with one reporting cycle to address remaining six action items by Feb. 2025.
  • 3 relate to demonstrating a sustained increase in investigation/prosecution of complex money laundering, terror financing, unlicensed cross-border money or value transfer services; the others relating to timely access of beneficial ownership information.
  • Reiterated that it remains a challenge to exit grey list at the conclusion of next cycle.
  • If it is successful, the FATF Plenary will authorize an onsite visit around May 2025.
  • Otherwise RSA will be required to continue to report to FATF every 4 months until all actions are addressed, meaning exit from grey list will be moved to Oct. 2025 or later.
  • Called upon all companies and professional trustee service providers to ensure registration by companies and trusts they engage (or are involved) with before Nov. 30, 2024, to significantly increase the coverage in beneficial ownership registers.

Regulators RSA FIU; RSA FSCA; RSA GVT
Entity Types Bank; BHC; Fiduciary; IA; Ins; Inv Co; MSB; SIFI
Reference PR 10/25/2024; PR 7/2/2024; PR, 2/29/2024;
Functions AML; Compliance; Financial; Legal; Market Conduct; Operations; Registration/Licensing; Reporting; Risk; Treasury
Countries South Africa; Cross-Border
Category
State
Products Banking; Equity; Fund Mgt; Insurance; Payments; Securities
Regions EMEA
Rule Type Final
Rule Date 2/29/2024
Effective Date 11/30/2024
Rule Id 202941
Linked to Rule :202336
Reg. Last Update 10/25/2024
Report Section International

Last substantive update on 10/30/2024