High risk. Medium risk. Low risk. For many financial institutions and accountable institutions, these three categories have become so familiar that they can feel like a regulatory requirement. But are they? The risk-based approach requires institutions to identify, assess, monitor,…
As 2026 draws to a close, one message has become increasingly clear across financial crime regulation, supervision and enforcement: having the right policies and frameworks is no longer enough. Institutions are increasingly expected to demonstrate that their financial crime controls…
South Africa’s financial crime compliance environment is entering a different phase. Following the country’s removal from FATF increased monitoring, the immediate focus on grey-list remediation is giving way to a more demanding question: can institutions demonstrate that their financial crime…
Double-Hatting in Financial Crime Compliance: Practical Reality or Governance Risk? In South Africa’s financial crime compliance environment, many accountable institutions are trying to answer a practical question: how do we meet our Financial Intelligence Centre Act obligations when the same…
The lines of defence model is familiar to most governance, risk and compliance professionals. In financial crime compliance, however, the model is often quoted more than it is understood. The weakness usually starts when the model is treated as an…
Financial crime risk is often described as a compliance responsibility. In the South African context, that description is too narrow. The Financial Intelligence Centre Act places obligations on accountable institutions, but the risks that those obligations seek to control arise…
This article is adapted from FCRMC’s Q2 2026 newsletter and highlights key financial crime risk developments, regulatory themes and Board-level priorities across South Africa and Namibia. Financial crime risk remains a priority governance issue for Boards, executive management and senior…
Why compliance still feels harder than it should and what’s actually driving it For most Designated Non-Financial Businesses and Professions (DNFBPs), anti-money laundering compliance does not fail because firms are unwilling to comply. It fails because the system they are…
Recently, our company has experienced a wave of CEO fraud emails. None of our team members were caught by them, but the experience was still a sharp reminder of how persistent and convincing these scams have become. It also reinforced…
Does your operating model still function when pressure increases? Many anti-financial crime (AFC) operating models appear robust in steady conditions. Governance forums meet regularly. Risk appetite is documented. Decision rights are defined. Escalation pathways exist. Under normal operating circumstances, the…