Practical implication of the Revised FIC Guidance Note 7A

By Lenee Green, Partner, Mateen Memon, Associate and Christopher Williamson, Associate at Webber Wentzel

In line with South Africa's attempts to get off the Financial Action Task Force's (FATF) greylist, the Financial Intelligence Centre (FIC) issued the Revised Guidance Note 7A (revised GN 7A) on 1 September 2025. This replaces the previous Guidance Notes 7 and 7A to better align with recent legislative developments. Key among these are the General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act and Public Compliance Communication (PCC) 59 (PCC 59).

Some of the key revisions in Revised GN 7A include:

• Beneficial ownership guidance now refers to FIC PCC 59, with the previous paragraph referencing 25% as an indicator of controlling ownership interest in a legal person removed entirely.
• Politically exposed persons terminology has been standardised to "foreign politically exposed persons" (FPEP), "domestic politically exposed persons" (DPEP), and "prominent influential persons" (PIP), with references to FICA Schedules 3A, 3B, and 3C, respectively. Importantly, it has now been clarified that business relationships with DPEPs or PIPs are not 'inherently high risk' and must instead be considered on their own merits.
• Asset freezing obligations under UN Security Council resolutions and ministerial notices are reaffirmed, with reference to FIC PCC 44A for targeted financial sanctions guidance.

Implementation priorities for accountable institutions

For accountable institutions, these revisions are not simply technical updates; they represent a call to refine internal systems, elevate governance practices, and adopt a more dynamic risk-based approach. To respond effectively, institutions should consider the following priorities:

• Update RMCPs to reflect expanded risk indicators and enhanced requirements.
• Strengthen sanctions screening frameworks for governance purposes.
• Conduct a thorough risk reassessment considering enhanced requirements.
• Perform gap analysis against Revised GN 7A requirements.

Taken together, these priorities move the sector beyond mere compliance and toward embedding resilience, transparency, and credibility in financial crime controls.

Revised GN 7A signals the FIC's push for a mature, dynamic, and internationally harmonised compliance culture in South Africa's financial sector. Institutions retain discretion in applying risk-based approaches, but this discretion is now coupled with heightened expectations for documentation, evidence, and proactive oversight.

The ultimate objective remains creating a financial system that is both accessible to legitimate users and resistant to criminal exploitation. Revised GN 7A provides the framework for achieving this goal, but success depends on sustained commitment from all stakeholders in South Africa's financial sector to integrate these enhanced standards into day-to-day operations, not only to satisfy FATF expectations but also to reinforce long-term sector integrity.

This exercise will continue despite a possible exit from the FATF greylist. In a media statement issued on 13 June 2025, the National Treasury noted that the FATF had announced South Africa had substantially completed all 22 action items that were contained in the Action Plan adopted when the country was greylisted in February 2023. The statement highlighted that South Africa's progress warranted an on-site assessment to verify that critical AML/CFT reforms have been implemented and that the necessary political commitment remains in place to sustain progress.

On 31 July 2025, the National Treasury issued another media statement confirming that the onsite visit had taken place at the end of July 2025. A report of the assessment will be submitted at the next FATF Plenary session, scheduled between 20 October and 24 October 2025. If the outcome of the assessment is positive, the FATF is expected to delist South Africa from the greylist during this visit.

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