In November 2022, 3Cube Property Solutions reported that South Africa was at grave risk of being greylisted in early 2023. That came to fruition and as of April 2025, we have not joined the likes of Senegal and The Philippines in being removed from the greylist. Let's unpack the reasons for this and break down what still needs to be done.
First things first: what is greylisting and what does it mean?
Greylisting is when a country is flagged by international financial watchdogs for not doing enough to prevent money laundering and the financing of terrorism. The greylist analyses the level of risk associated with companies and individuals in every country.
The Financial Action Task Force (FATF) has compiled a list of 40 recommendations for protocols to be used in the fight against financial crime. When we were placed on the greylist, South Africa was in contravention of about half these recommendations.
Being on the greylist has assorted negative implications. Foreign investors are likely to be sceptical about investing due to the risk of financial crimes. Extra checks and delays are often put into place when dealing with a greylisted nation and the country suffers general reputational damage.
Significant progress over the past two years
The good news in 2025 is that South Africa is on track to be considered for delisting from the greylist, with just two issues left to be addressed. The outstanding action items are investigations and prosecutions of serious and complex money laundering and terror-financing activities. National Treasury has released a statement stating that these two items will be addressed in the current reporting period, which runs from March to June 2025. If this is accomplished, South Africa will be considered for delisting in October 2025.
Of course, being removed from the greylist is not the only advantage of investigating and prosecuting those responsible for financial crimes. The actions being undertaken also aid the fight against crime and corruption.
One of the FATF's conditions for lifting South Africa's greylisted status was the establishment of a beneficial ownership register. Essentially, this register requires companies (including non-profits and close corporations) are required to keep and submit a record of the natural persons who own or control the company.
South Africa's beneficial ownership registry came into existence on 1 April 2023. Thanks to this register, there is now a source of accurate and verified beneficial ownership information available to authorities when needed. This in turn makes it possible for the Companies and Intellectual Property Commission (CIPC) to impose sanctions and penalties in cases of non-compliance. In short, law enforcement authorities and regulatory bodies can now quickly identify who is responsible for an entity and who reaps the benefits of its success.
Clampdown on non-compliant businesses
In November 2024, the CIPC dealt a heavy blow to non-compliant businesses, announcing that over 500 000 such companies were to be deregistered. Companies that had not filed their annual returns and beneficial ownership declarations were to be axed. This followed a formal notification that was sent out in September 2024 notifying companies that the wheels had been set in motion for deregistration. In this communication, they were advised of the steps that needed to be taken to ensure compliance and prevent deregistration.
According to the release issued by the CIPC, the deregistration process assists in the maintenance of an up-to-date register of companies. This in turn contributes to improved decision-making capabilities and efficient allocation of funds to those in need. This action also helps to curb money launderers and terror financiers - both of which target active and dormant entities alike.
Are real estate agencies holding us back?
In August 2024, it was reported that property practitioners were being accused of holding up South Africa's removal from the greylist. Reports at that time showed that just 66% of estate agents had submitted the required risk and compliance reports.
However, Crux Compliance noted that these figures may be unfair to the real estate industry. The article quotes Jan le Roux, chief executive of the Real Estate Business Owners of South Africa (REBOSA) who explained that many estate agencies have stopped trading without notifying the Financial Intelligence Committee (FIC).
Businesses, investors and stakeholders are united in their hope that October 2025 will see South Africa removed from the greylist. As the tide hopefully turns, your business may find itself in need of new premises in Gauteng or the Western Cape. Get in touch with 3Cube Property Solutions if you need help finding a new home for your business.