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5 October 2024

Avoiding Hefty Fines: The Need for Effective RMCP Compliance Post-Grey Listing in South Africa

With South Africa being placed on the grey list by the Financial Action Task Force (FATF), it's critical for businesses, especially those in accountable institutions, to tighten compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) laws. President Ramaphosa's legislation on having a working Risk Management and Compliance Programme (RMCP) is part of these enhanced measures.


Accountable institutions, such as financial services providers, lawyers, estate agents, and others dealing with large amounts of money, are now required to establish, implement, and continuously apply RMCPs. This means they must:

  1. Identify and assess risks related to money laundering and terrorist financing.
  2. Develop and implement measures to mitigate these risks, including customer due diligence (CDD) processes, record-keeping, and reporting suspicious transactions.
  3. Regularly monitor compliance with these programs and ensure they are effective.


Failure to comply can indeed lead to severe penalties, including hefty fines or even imprisonment in some cases. This is not just about checking boxes but about actively demonstrating that measures are being applied and adhered to. For businesses, the stakes are high, and the financial and reputational risks of non-compliance are considerable.

Is your organization directly impacted by this requirement, and are you looking to implement or improve a compliance solution?


Contact us for assistance in this process.