Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

19cases from 1 jurisdiction
€12.4mTotal of monetary amounts (16 cases with an amount)
€2.17mLargest single case: an international major bank
€666,957Median per case with an amount

Click a bar to drill down one level.

When?

per year, by date of decision
Trend
PeriodCasesTotal
20233€3.65m
20246€3.9m
20258€3.32m
20262€1.49m

19 cases

11 Sep 2026 Capitec Bank LimitedCapitec Bank: ZAR 28m for failings in customer due diligence and training South AfricaCustomer due diligence €1.49m

Following a 2023 inspection, the supervisor found inadequate customer due diligence and inadequate enhanced and ongoing due diligence in sampled files, no ongoing training for sampled employees and gaps in the risk management and compliance programme, such as name and payment screening manuals that had not been approved by management before being implemented, and inadequately documented arrangements for terrorist property reporting and financial sanctions. Five cautions and penalties of 28 million ZAR were imposed, of which 5.5 million ZAR is suspended for 36 months from 13 October 2025; the bank had already been sanctioned with 56.25 million ZAR in December 2024. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

A bank that has already been sanctioned will be judged at the next inspection on full implementation – due diligence and training must demonstrably be in place.

Relevance to training and awareness

Ongoing due diligence and regular anti-money laundering training

Missing or inadequate training played a role in the decision.

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 21, 21A und 21C i. V. m. 42(1), 42(2)(d), (e), (g) sowie Sections 42 und 43 Financial Intelligence Centre Act 38 of 2001
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Cooperation in remedying the deficiencies; 5.5 million ZAR suspended for 36 months.
Published
11 Sep 2026

Original amount 28,000,000 ZAR, converted at the ECB reference rate of 11 Sep 2026.

Checked against the official source on 4 Oct 2026 · Direct link

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17 Jul 2026 80 Eight South Africa (Pty) Ltd (vormals Ela Asset Management (Pty) Ltd)80 Eight South Africa: failing to protect clients against fraud South AfricaOrganisational requirements Fine

The financial services provider had not made sure that its clients were protected against losses from theft, fraud or other dishonest acts by its employees; one individual's misconduct caused clients substantial losses. The company was directed to introduce, within two months, a policy protecting against such risks. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Financial services providers need effective controls against fraud by their own employees – even contraventions they discover and report themselves can lead to a penalty and directives.

Relevance to training and awareness

Insider fraud and internal controls

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Sections 2 und 11 General Code of Conduct for Authorised Financial Services Providers and Representatives (2003); Section 13(3)(a) Financial Advisory and Intermediary Services Act 37 of 2002; Section 42(1) Determination of Fit and Proper Requirements for Financial Services Providers (2017)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
According to the authority's update of 22 July 2026, the company had itself discovered and reported the contraventions, which occurred in 2021.
Liability of senior managers
Measures against individuals are not set out here.
Published
17 Jul 2026

Checked against the official source on 4 Oct 2026 · Direct link

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9 Dec 2025 Banxso (Pty) LtdBanxso: penalties for misuse of client funds South AfricaCapital markets and financial supervision Fine

The investigation found that the financial services provider had, among other things, misused client funds, supplied false or misleading information to clients and the regulator, promised unrealistic returns and not acted in the interests of clients. The amount and the facts have not been confirmed against the primary source.

Relevance to training and awareness

Segregation and protection of client funds; no promises of returns

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Capital markets and financial supervision
Legal basis
Financial Sector Regulation Act 9 of 2017; Financial Advisory and Intermediary Services Act 37 of 2002; General Code of Conduct for Authorised Financial Services Providers and Representatives (2003); Financial Institutions (Protection of Funds) Act 28 of 2001; Determination of Fit and Proper Requirements for FSPs (2017); Financial Markets Act Regulations (2018)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
9 Dec 2025
Sources

Checked against the official source on 4 Oct 2026 · Direct link

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17 Oct 2025 Access Forex (Pty) LimitedAccess Forex: ZAR 162,500 on foreign exchange dealer for AML failings South AfricaInternal controls €8,005

The authorised dealer in foreign exchange with limited authority (ADLA, a category that includes bureaux de change) had not incorporated key requirements of the FIC Act into its risk management and compliance programme, had failed to identify and verify some customers and had not given its staff adequate training. The penalties amount to 100,000 ZAR (section 42(1)), 37,500 ZAR (section 20) and 25,000 ZAR (section 43), 162,500 ZAR in total. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Foreign exchange dealers and bureaux de change, too, must align their compliance programme with all statutory duties and train their staff regularly.

Relevance to training and awareness

Customer identification and mandatory training at foreign exchange dealers

Missing or inadequate training played a role in the decision.

Authority / court
South African Reserve Bank (SARB)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Sections 20, 42(1) und 43 Financial Intelligence Centre Act 38 of 2001
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
17 Oct 2025

Original amount 162,500 ZAR, converted at the ECB reference rate of 17 Oct 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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13 Oct 2025 Sanlam Collective Investments (RF) (Pty) LtdSanlam Collective Investments: ZAR 10.6m for breaches of anti-money laundering duties South AfricaCustomer due diligence €527,691

An inspection in March 2024 showed that the manager of collective investment schemes was not applying its risk management and compliance programme (RMCP) effectively, particularly when risk-rating clients, that the programme had substantive gaps, that some clients and their beneficial owners had not been adequately identified and verified, and that the required ongoing and enhanced due diligence was missing. Alongside a directive to remediate and a caution, a penalty of 10.6 million ZAR was imposed, of which 3.6 million ZAR is conditionally suspended for two years; earlier contraventions of other laws were taken into account, including an enforceable undertaking and a penalty under the Collective Investment Schemes Control Act (CISCA). The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Large group companies are held to higher standards – a documented programme without risk rating in practice does not protect against substantial penalties.

Relevance to training and awareness

Client risk rating and ongoing and enhanced due diligence

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 42(1), 42(2), 20A, 21, 21A, 21B, 21C, 21E und 21F–21H Financial Intelligence Centre Act 38 of 2001 (FIC Act)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Remedial action taken to date; 3.6 million ZAR suspended for two years, provided the deficiencies are fully remedied and the obligations are complied with on a sustained basis.
Published
13 Oct 2025

Original amount 10,600,000 ZAR, converted at the ECB reference rate of 13 Oct 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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25 Aug 2025 FirstRand Bank Ltd (WesBank); Toyota Financial Services South Africa Ltd; Toyota Motor Corporation u. a. (6 Unternehmen)Competition Tribunal: WesBank and Toyota companies allegedly pay ZAR 30m over non-compete clause South AfricaCartels and collusion €1.46m

According to the Competition Commission, a non-compete clause in the 2000 shareholders' agreement of Toyota Financial Services South Africa (TFSSA), in which WesBank holds a one-third stake, obliged the parties not to compete with each other in financing Toyota vehicles; WesBank therefore referred customers' finance requests to TFSSA (market division). In a settlement without admission of liability, the restraint is relaxed so that WesBank may provide finance quotes to retail customers and dealers at their request, and the six parties (FirstRand Bank, its division WesBank, TFSSA, Toyota Motor Corporation, Toyota Financial Services (UK), Toyota South Africa) allegedly pay ZAR 30m jointly or severally. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Non-compete clauses in joint venture shareholders' agreements should be reviewed regularly, as they can deprive customers of a choice between providers.

Relevance to training and awareness

Non-compete clauses in joint ventures and customer freedom of choice

Authority / court
Competition Tribunal of South Africa (auf Antrag der Competition Commission)
Area of law
Competition law · Cartels and collusion
Legal basis
Competition Act 89 of 1998, s. 4(1)(b)(ii); ss. 49D, 58(1)(b)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Settlement without admission of liability to end protracted proceedings.
Published
25 Aug 2025

Original amount 30,000,000 ZAR, converted at the ECB reference rate of 25 Aug 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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8 May 2025 Ninety One Fund Managers SA (RF) (Pty) LtdFSCA: allegedly ZAR 3m against Ninety One Fund Managers over flaws in its anti-money laundering programme South AfricaInternal controls €146,313

An inspection in September 2023 showed that the fund manager had not effectively implemented its risk management and compliance programme, particularly the risk rating of clients, and had not adequately identified and monitored some clients and beneficial owners on an ongoing basis. In November 2024 the FSCA allegedly imposed a penalty of ZAR 3m, a remediation directive and a caution; following a settlement confirmed by the FIC Act Appeal Board in April 2025, the appeal was withdrawn and ZAR 500,000 was conditionally suspended for three years. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

A written anti-money laundering programme is not enough if client risk rating is not carried out in line with it in day-to-day practice.

Relevance to training and awareness

Risk rating of clients and beneficial owners

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21, 21B, 21C, 42(1), 42(2); Vergleich nach s. 45D(7)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Remedial action; ZAR 500,000 conditionally suspended.
Published
8 May 2025

Original amount 3,000,000 ZAR, converted at the ECB reference rate of 8 May 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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25 Apr 2025 Absa Bank LimitedPA: ZAR 10m against Absa over deficient checks on politically exposed clients South AfricaCustomer due diligence €468,147

Following an inspection in 2022, the supervisor objected to inadequate customer due diligence and enhanced due diligence on foreign and domestic politically exposed clients, and to more than 8,500 monitoring alerts not handled within 48 hours. It imposed two cautions, a reprimand and financial penalties of ZAR 10m (7m for customer due diligence, 3m for breaches of Directive 5). The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Politically exposed clients require documented enhanced due diligence, even where only a few files are concerned.

Relevance to training and awareness

Enhanced due diligence on politically exposed persons

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21(1), 21A; FIC Directive 5 of 2019; Regulation 24(3)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
The bank's cooperation and remedial action.
Published
25 Apr 2025

Original amount 10,000,000 ZAR, converted at the ECB reference rate of 25 Apr 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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22 Apr 2025 African Bank LimitedAfrican Bank: ZAR 700,000 for social-media loan advert presented as an 'investment' South AfricaMisleading advertising and pricing €32,753

A social-media campaign by the bank in December 2023 (#KeFestive), featuring a well-known public figure, presented personal loans as an investment; the authority found this factually incorrect and misleading and also identified weaknesses in the approval process for advertising. Of the 700,000 ZAR penalty, 200,000 ZAR was suspended for two years; the bank has paid 500,000 ZAR. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Advertising for credit products – including with well-known personalities – needs a competent, documented approval that describes the nature of the product correctly.

Relevance to training and awareness

Advert approval and influencer marketing for financial products

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Sections 6(1), 6(3)(a), 6(3)(b) und 6(9) Conduct Standard 3 of 2020 (Banks)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation during the investigation and prompt remedial action; 200,000 ZAR suspended for two years, provided the bank complies with the Conduct Standard.
Published
22 Apr 2025

Original amount 700,000 ZAR, converted at the ECB reference rate of 22 Apr 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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24 Jan 2025 The Standard Bank of South Africa LimitedPA: ZAR 13m against Standard Bank over late reports to the FIC South AfricaSuspicious activity reports €675,255

Following an inspection in 2022, the supervisor found that the bank had filed 17,259 suspicious transaction reports and 1,466 cash transaction reports late and failed to file one suspicious report at all, had not recorded the submission dates of 43 suspicious reports, omitted ongoing due diligence on two clients and not handled some 75,700 monitoring alerts on time. Sanction: six cautions and financial penalties totalling ZAR 13m (4m for late suspicious reports, 1m for the missing report, 8m for breaches of Directive 5). The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Identifying suspicious cases but not reporting them on time breaches the reporting duty just as not reporting at all does; reporting processes need capacity and deadline control.

Relevance to training and awareness

Timely suspicious and cash transaction reporting

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21C, 23(c), 28, 29; FIC Directive 5 of 2019; Regulation 24(3)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
The bank's cooperation and remedial action.
Published
24 Jan 2025

Original amount 13,000,000 ZAR, converted at the ECB reference rate of 24 Jan 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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21 Nov 2024 Tana Africa Capital Managers (Pty) LtdFSCA: ZAR 2.9m against Tana Africa Capital Managers, upheld by the Appeal Board South AfricaInternal controls €152,404

An inspection showed that the asset manager's risk management and compliance programme was deficient and not effectively implemented, and that client data was not screened against the UN Security Council targeted financial sanctions lists. The FSCA imposed ZAR 2.9m, of which ZAR 1m is conditionally suspended for three years; on 6 November 2024 the FIC Act Appeal Board dismissed the appeal against the amount and held that reliance on an external compliance adviser does not relieve an institution of responsibility. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

A firm that outsources compliance to an external provider remains responsible for meeting its anti-money laundering duties itself, even with just a single client.

Relevance to training and awareness

Sanctions list screening and accountability despite external compliance advice

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 42(1), 42(2) i. V. m. s. 21(1); s. 28A i. V. m. ss. 26A–26C
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
ZAR 1m conditionally suspended for three years.
Published
21 Nov 2024

Original amount 2,900,000 ZAR, converted at the ECB reference rate of 21 Nov 2024.

Checked against the official source on 4 Oct 2026 · Direct link

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27 Sep 2024 a South African life insurerLife insurer: ZAR 15.9m for breaches of anti-money laundering duties South AfricaCustomer due diligenceanonymised €832,060

A 2020 inspection found that the life insurer had not carried out adequate customer due diligence on sampled relationships (including address verification and identification of beneficial owners), had reported cash transactions above the threshold and suspicious transactions late, and had not adequately developed and implemented its risk management and compliance programme. Four cautions and penalties totalling 15.9 million ZAR were imposed, of which 5.9 million ZAR is conditionally suspended for 36 months from 23 July 2024.

What organisations can take from it

Life insurers, too, must risk-rate clients before onboarding and meet the reporting deadlines towards the financial intelligence unit.

Relevance to training and awareness

Customer due diligence and reporting deadlines in insurance distribution

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 21, 21A–21H, 28 (i. V. m. Regulations 22B, 22C, 24(4)), 29 (i. V. m. Regulation 24(3)) und 42 Financial Intelligence Centre Act 38 of 2001
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation throughout the process and remedial action; 5.9 million ZAR suspended for 36 months.
Published
27 Sep 2024

Original amount 15,900,000 ZAR, converted at the ECB reference rate of 27 Sep 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 27 Sep 2026 · Direct link

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5 Jul 2024 a South African insurerPA: ZAR 13m against an insurer over flaws in its anti-money laundering programme South AfricaCustomer due diligenceanonymised €658,658

Following a FIC Act inspection in 2020, the insurer was sanctioned for inadequate customer due diligence (including on domestic prominent influential persons), missing records for client files and an inadequately developed risk management and compliance programme. It received three cautions and financial penalties of ZAR 13m (10m for customer due diligence, 3m for the RMCP), of which ZAR 6m is conditionally suspended for 36 months.

What organisations can take from it

Insurers, too, must assess money laundering risks using a documented method and keep client files complete.

Relevance to training and awareness

Risk-based customer checks and record-keeping at insurers

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21(1), 21A–21H, 22, 23, 42
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation and remediation of the deficiencies; ZAR 6m conditionally suspended.
Published
5 Jul 2024

Original amount 13,000,000 ZAR, converted at the ECB reference rate of 5 Jul 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 5 Jul 2026 · Direct link

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7 Jun 2024 a South African branch of a foreign bankPA: ZAR 30.5m against a foreign bank's branch over customer due diligence failures South AfricaCustomer due diligenceanonymised €1.49m

Following a FIC Act inspection in 2021 (samples from 2016–2020), the supervisor sanctioned the South African branch for failing to carry out (enhanced) customer due diligence, late suspicious transaction reports, monitoring alerts not handled on time and an inadequate risk management and compliance programme. It imposed four cautions, a reprimand and financial penalties totalling ZAR 30.5m (20m for due diligence, 0.5m for alert handling, 10m for the RMCP), of which ZAR 15.25m is conditionally suspended for 36 months. According to the supervisor, the sanctions do not stem from any involvement of the branch in money laundering or terrorist financing transactions.

What organisations can take from it

Foreign branches also need their own anti-money laundering programme, approved by the governing body, that actually drives customer due diligence and alert handling.

Relevance to training and awareness

Customer due diligence and timely handling of monitoring alerts

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21(1), 21A, 29 i. V. m. Regulation 24(3), s. 42; FIC Directive 5 of 2019
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the supervisor and remedial action; half of the penalty was conditionally suspended.
Liability of senior managers
The programme had not been approved by the Board of Directors and was not tailored to the branch.
Published
7 Jun 2024

Original amount 30,500,000 ZAR, converted at the ECB reference rate of 7 Jun 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 7 Jun 2026 · Direct link

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26 Mar 2024 a South African credit bureauInformation Regulator: order against a credit bureau over inadequate access control South AfricaData breaches and data securityanonymised Order

Following a security compromise reported in March 2022, the Information Regulator found that the credit bureau had failed to secure the confidentiality of the data, had not implemented its own access policies and had allowed unauthorised actors in through compromised credentials and a weak password. By enforcement notice it was ordered to put security measures in place, have a qualified auditor check all user accounts against its SFTP user creation policy and carry out a personal information impact assessment; the deadline for proof was 26 May 2024.

What organisations can take from it

User creation and access management policies only protect if compliance with them is monitored technically; compromised credentials and weak passwords are a way in.

Relevance to training and awareness

Access management and password security

Authority / court
Information Regulator (South Africa)
Area of law
Data protection · Data breaches and data security
Legal basis
Protection of Personal Information Act 4 of 2013 (POPIA), Bedingungen für die rechtmäßige Verarbeitung (Sicherheitsmaßnahmen); Enforcement Notice
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
26 Mar 2024

Checked against the official source on 8 Oct 2026 · Company name anonymised since 26 Mar 2026 · Direct link

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28 Feb 2024 a South African fund managerSouth African fund manager: ZAR 16m for failings in anti-money laundering controls South AfricaInternal controlsanonymised €769,760

An inspection in October and November 2022 found that the risk management and compliance programme (RMCP) of the fund manager, a subsidiary of a banking group, was deficient, that some clients and beneficial owners had not been identified and verified, and that clients had not been screened against the UN targeted financial sanctions lists. A penalty of 16 million ZAR was imposed, of which 6 million ZAR was suspended for three years; 10 million ZAR was payable by 28 February 2024, together with a directive to remedy the remaining deficiencies.

What organisations can take from it

An anti-money laundering programme must not merely exist but must specifically cover client identification, beneficial owners and screening against sanctions lists.

Relevance to training and awareness

Customer due diligence, beneficial owners and sanctions-list screening

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Sections 42(1), 42(2), 21(1), 21B und 28A i. V. m. 26A–26C Financial Intelligence Centre Act 38 of 2001 (FIC Act)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Remedial action already taken; 6 million ZAR suspended for three years, provided the directive is fully implemented and the relevant obligations are complied with.
Published
28 Feb 2024

Original amount 16,000,000 ZAR, converted at the ECB reference rate of 28 Feb 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 28 Feb 2026 · Direct link

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8 Dec 2023 a South African bankPA: ZAR 10.73m against a bank over weak controls and agent-sourced clients South AfricaInternal controlsanonymised €526,866

Following an inspection in 2020, the supervisor found deficiencies in the risk management and compliance programme (including identification of beneficial owners, clients onboarded by agents and shared clients), in customer due diligence and record-keeping, in the calibration of transaction monitoring and in governance. It imposed reprimands, cautions and financial penalties totalling ZAR 10.73m (1.5m, 4m, 5m and 0.23m), of which ZAR 5m is conditionally suspended for 24 months.

What organisations can take from it

A bank that acquires clients through agents or outsources due diligence to third parties remains responsible for oversight and monitoring itself.

Relevance to training and awareness

Oversight of agents and outsourcing of due diligence duties

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21–21H, 22–24, 42(1), 42(2), 42(2A), 42A(2), 42A(3), 45C(3); FIC Directive 5/2019
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation and remedial action; ZAR 5m conditionally suspended.
Liability of senior managers
Governance duties were also criticised, including oversight of agent relationships and remediation of known deficiencies.
Published
8 Dec 2023

Original amount 10,730,000 ZAR, converted at the ECB reference rate of 8 Dec 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 8 Dec 2025 · Direct link

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30 Nov 2023 a bank in South AfricaBank in South Africa: ZAR 19.75m for failings in customer due diligence and reporting South AfricaCustomer due diligenceanonymised €960,122

Following a 2020 inspection, the supervisor identified failings at the bank in customer due diligence, cash threshold reporting, late and incomplete suspicious transaction reports, the handling of automated transaction monitoring alerts, staff training and the governance of anti-money laundering compliance. By a notice of sanction dated 30 November 2023 it imposed cautions, reprimands and penalties totalling 19.75 million ZAR, of which 9.25 million ZAR is conditionally suspended for 36 months.

What organisations can take from it

Automated transaction monitoring only helps if alerts are dealt with on time and suspicious transaction reports are filed in full.

Relevance to training and awareness

Filing suspicious transaction reports on time and in full

Missing or inadequate training played a role in the decision.

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 21, 21A–21H, 28, 29 (i. V. m. Regulation 24(3)), 42, 42A und 43 Financial Intelligence Centre Act 38 of 2001; FIC Directive 5 of 2019; Sanktion nach Section 45C(3) FIC Act
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the supervisor and remedial action; 9.25 million ZAR suspended for 36 months. The supervisor stresses that no involvement in money laundering or terrorist financing was found.
Published
8 Dec 2023

Original amount 19,750,000 ZAR, converted at the ECB reference rate of 30 Nov 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 30 Nov 2025 · Direct link

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15 Nov 2023 an international major bankUSD/ZAR forex cartel: international major bank pays ZAR 42.7m and cooperates South AfricaCartels and collusionanonymised €2.17m

On 15 November 2023 the Competition Tribunal (South Africa's competition adjudicator) confirmed a settlement in which an international major bank admitted taking part between 2007 and 2013 in price fixing and market allocation in spot trading of the USD/ZAR currency pair, for example by coordinating bids and offers via chat platforms. The bank pays an administrative penalty of 42,715,880 ZAR, will continue its compliance programme and will provide evidence to the Competition Commission (competition authority) in its prosecution of the other banks among the 28 accused.

What organisations can take from it

Chats between traders at competing banks about prices and spreads carry a high competition law risk and belong in trading-floor surveillance and training.

Relevance to training and awareness

Competition law on trading desks: contacts between traders at competing banks

Authority / court
Competition Tribunal of South Africa (auf Antrag der Competition Commission)
Area of law
Competition law · Cartels and collusion
Legal basis
Section 4(1)(b)(i) und (ii) Competition Act 89 of 1998
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
15 Nov 2023

Original amount 42,715,880 ZAR, converted at the ECB reference rate of 15 Nov 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 15 Nov 2025 · Direct link

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