FATF Greylist (South Africa)
The Financial Action Task Force (FATF) placed South Africa on its “greylist” — officially, the list of Jurisdictions Under Increased Monitoring — in February 2023, following a mutual evaluation that found the country had failed on 20 of FATF’s 40 recommendations and failed all 11 immediate-outcome measures on implementation. FATF explicitly cited state capture and high-level corruption as having “significantly weakened institutions tasked with fighting financial crimes.” South Africa was removed from the greylist on 24 October 2025 after completing all 22 required action items.
Why it matters for this vault: The greylist is the direct institutional consequence of the state capture era recorded in every other note in this vault. The AML/CFT failures that caused the listing — weak prosecution of financial crimes, under-resourced Hawks and NPA, inadequate beneficial ownership transparency, and poor coordination — were not accidental. They were the product of the systematic institutional capture documented across the Zondo Commission, the NPA NDPP succession, the SARS/Bain demolition, and the EMPD/Big Five infiltration. The greylist therefore functions as the international community’s verdict on state capture’s lasting institutional damage.
22 action items and removal: South Africa agreed to 22 action items in its Action Plan with FATF. Progress was slow in 2023–2024 but accelerated following NPA and DPCI reforms. By June 2025, FATF confirmed South Africa had “substantially completed” all 22 items and authorised an on-site assessment (29–30 July 2025). At the October 2025 Plenary in Strasbourg, France, FATF officially removed South Africa from the greylist. Key drivers of removal: sustained increase in prosecutions of serious and complex money laundering cases; NPA quarterly reporting regime on state capture prosecutions; and improved SARS/FIC beneficial ownership systems. The NPA’s December 2024 McKinsey settlement (achieved in co-operation with the US DOJ) and increased Zondo-referred prosecutions were cited as demonstrating the “sustained increase” in enforcement that FATF required.
Connections
- National Prosecuting Authority (NPA) — IDAC’s permanent establishment (2024) and quarterly reporting on complex ML cases were central to satisfying FATF action items
- Zondo Commission — state capture findings are the root cause of FATF listing; NPA Zondo implementation was monitored as a greylist metric
- Eskom / Transnet — money laundering through SOE contracts (McKinsey/Trillian, Gupta network) directly caused FATF’s AML deficiency findings
- Bain & Company / McKinsey & Company — FCPA settlements ($122m McKinsey December 2024) cited as evidence of improving SA enforcement, assisting delisting
- Gupta Family — UAE asset recovery and international co-operation on Gupta laundering tracked by FATF as a metric
- Special Investigating Unit (SIU) — SIU’s civil recovery record (R10.6bn under restraint by 2025) contributed to FATF’s assessment of SA’s effective implementation