South Africa edges towards delisting: A compliance call to action for accountable institutions

Exiting the grey list is more than a technical formality. It marks a return to international confidence, facilitates reduced compliance costs, and reopens doors for foreign investment and correspondent banking relationships. However, this final FATF review will not be based on legal frameworks alone, it will assess the practical implementation of those frameworks across both the public and private sectors to ensure South Africa qualifies for delisting.

On 13 June 2025, the Financial Action Task Force (FATF) acknowledged that South Africa has substantially completed all 22 action items from its 2023 grey-list Action Plan. This pivotal milestone now moves us into the next and final phase: a scheduled on-site visit by the FATF Africa Joint Group, expected before the October 2025 plenary.

This moment places renewed accountability on all Accountable Institutions to ensure they are not only compliant on paper but operationally resilient. Regulators and oversight bodies will be scrutinizing whether compliance has been institutionalized – from risk frameworks to actual staff vetting, ongoing monitoring, and reporting.

Regulatory shifts are raising the bar

Recent legislative and regulatory updates have introduced a more demanding compliance environment:

• Directive 8 & Guidance Note 7A (Feb–Apr 2025): Emphasize the need for competent, vetted staff and robust RMCPs (Risk Management and Compliance Programmes) with a focus on proactive monitoring and reporting.
• PCC 44A (Feb 2024): Requires all Accountable Institutions to ensure strict adherence to targeted financial sanctions under relevant UN Security Council Resolutions.
• PCC 57 and recent updates to the FIC Act: Bring Crypto-Asset Service Providers (CASPs) under the AML/CFT compliance net, introducing new complexities in digital finance that many institutions are still grappling with.

How MIE enables practical compliance

At this critical inflection point, Managed Integrity Evaluation (MIE) is uniquely positioned to support institutions seeking to close implementation gaps ahead of the FATF on-site review.

1. Employee and PEP screening

Aligned with Directive 8 and Guidance Note 7A, MIE offers seamless solutions for:

• Criminal background checks
• PEP (Politically Exposed Persons) identification
• Sanctions screening

This helps institutions ensure that staff, especially in high-risk roles, are properly vetted and continuously monitored.

2. AML screening for CASPs and RMCP integration

CASPs and other Accountable Institutions can directly integrate MIE’s screening services into their RMCPs, ensuring compliance with evolving FATF-aligned regulations, especially relevant under PCC 57.

3. Real-time monitoring and alerts

With MIE’s automated systems, institutions can receive real-time sanction list refreshes, monitoring alerts, and track shifts in individual risk status – essential for ongoing compliance and audit readiness.

4. Holistic, sustainable compliance support

MIE’s services span:

• Qualification and criminal history verifications
• Identity and sanctions list checks
• POPIA-aligned due diligence workflows

These not only ensure compliance but reinforce data protection, an increasingly important parallel obligation.

Embracing strategic compliance

South Africa’s potential delisting will be shaped not just by governmental progress, but by the demonstrable commitment of Accountable Institutions to maintain FATF-level standards. As an industry leader, MIE stands ready to assist institutions in embedding sustainable, evidence-based compliance practices.

Consider taking these steps today:

• Book a product demo to explore how MIE’s tools map directly to Directive 8 and FATF obligations.
• Schedule a compliance review to assess operational readiness and identify any last-mile gaps before the on-site review.
• Engage with our team for tailored solutions, especially if you’re a DNFBP, CASP, or institution newly regulated under recent guidance.

By Diyuti Mohanlal – Mettus Head of Legal, Risk and Compliance