Over the past two years, regulators in South Africa have stepped up enforcement efforts in response to deficiencies identified by international oversight bodies. As part of broader measures to improve anti-money laundering (AML), counter-terrorism financing (CTF), and proliferation financing (PF) compliance—and ultimately restore the country’s global standing—several banks, fund managers, and other accountable institutions have come under scrutiny.

Key themes from recent regulatory findings include:

Nature of Failure	Entity Type Affected	Regulatory Findings
Inadequate Customer Due Diligence (CDD)	Commercial and Investment Banks	Failure to adequately identify and verify high-risk clients including politically exposed persons and foreign officials.
Weaknesses in Enhanced Due Diligence (EDD)	Asset Managers and Investment Firms	Insufficient risk assessment and monitoring of prominent influential persons.
Transaction Monitoring Lapses	Retail Banks and Payment Operators	Delayed or unaddressed transaction alerts and untimely submission of suspicious activity reports.
Non-existent or Deficient RMCPs	Wealth Managers and Niche Financial Services Firms	Absence of formal risk management and compliance programmes or outdated procedures.
Screening Failures	Financial Service Providers	Insufficient or ineffective screening of clients, employees, and third parties against sanctions and risk databases.
Collusion and Internal Control Breaches	Treasury and Forex Functions	Internal actors bypassing regulatory controls leading to the unlawful movement of funds.

These failings have led to significant monetary penalties, suspended fines subject to remediation, and public warnings—all intended to drive urgent corrective action and set a clear example for the broader industry.

FCRMC: Supporting Institutions to Strengthen Compliance Position

Considering the increased regulatory pressure and reputational risk facing financial institutions, Financial Crime Risk Management Consultants (FCRMC) has strategically expanded its products and services to support entities in addressing these gaps.

What We’ve Delivered Over the Past Six Months:

Service Area	Description
Training & Capacity Building	Launched modular training programmes for compliance teams, executives, and frontline staff—covering RMCPs, CDD/EDD, sanctions compliance, and regulatory inspection readiness.
RMCP Development and Review	Structured methodologies to design, review, and align RMCPs with FICA, FATF recommendations, and Directive/Guidance Note expectations—customised per operating model.
Regulatory Inspection Preparation	Diagnostic reviews and mock interviews to assess inspection readiness, supported by documentation and procedural walkthroughs.
Gap and Maturity Assessments	Detailed gap analyses across governance, people, processes, data, and technology—benchmarking against leading practice and regulatory obligations.
Digital Risk Assessment Tools	Partnership with technology providers to offer cloud-based risk assessment solutions for AML/CTF, sanctions, and fraud, supporting automated risk rating and reporting.
Advisory and Remediation Support	Ongoing advisory support to address audit and regulator findings, helping institutions strengthen controls and demonstrate effective remediation.

Partner with FCRMC

With increasing scrutiny on the adequacy and effectiveness of AML/CFT/CPF frameworks, institutions can no longer rely on static controls or outdated programmes. FCRMC stands ready to help your organisation:

• Build or refresh your RMCP to meet the latest legal and regulatory expectations.
• Train your teams with sector-relevant, practical learning.
• Prepare for regulatory inspections with confidence.
• Implement effective technology-enabled risk assessment tools.
• Avoid regulatory sanctions and strengthen stakeholder confidence.

Let’s work together to build a resilient compliance framework.
Contact Us to schedule a consultation or request our latest service and training catalogues.