Post-greylisting: compliance built - But what comes next?
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South Africa’s removal from the FATF grey list in October 2025 marked a significant turning point in the country’s anti-money laundering and counter-terrorist financing regime.
But with the action plan largely complete, the focus is now shifting.
In this episode of The Legal Lens, Lerato Lamola and Kirsten Wolmarans explore what comes next and how the regulatory conversation is evolving from building compliance frameworks to testing how those frameworks operate in practice.
The discussion unpacks:
• The transition from greylisting to delisting and what it signals for the financial system
• The shift from technical compliance to demonstrable effectiveness
• The emerging gap between policy and real-world decision-making
• Why enforcement outcomes remain slower than expected
• Where even sophisticated organisations are falling short in practice
• The move towards defensible decision-making and institutional resilience
As South Africa enters a new FATF evaluation cycle, the key question is no longer whether frameworks exist, but whether they consistently influence behaviour and withstand scrutiny.
For businesses, compliance is no longer just about systems and controls — it is about how decisions are made, documented, and justified in real time.
But with the action plan largely complete, the focus is now shifting.
In this episode of The Legal Lens, Lerato Lamola and Kirsten Wolmarans explore what comes next and how the regulatory conversation is evolving from building compliance frameworks to testing how those frameworks operate in practice.
The discussion unpacks:
• The transition from greylisting to delisting and what it signals for the financial system
• The shift from technical compliance to demonstrable effectiveness
• The emerging gap between policy and real-world decision-making
• Why enforcement outcomes remain slower than expected
• Where even sophisticated organisations are falling short in practice
• The move towards defensible decision-making and institutional resilience
As South Africa enters a new FATF evaluation cycle, the key question is no longer whether frameworks exist, but whether they consistently influence behaviour and withstand scrutiny.
For businesses, compliance is no longer just about systems and controls — it is about how decisions are made, documented, and justified in real time.
