In September, the Financial Intelligence Centre (FIC) released Revised Guidance Note 7A (GN 7A), replacing the earlier versions namely Guidance Note 7A and Guidance Note 7 which were published in February 2025 and October 2017 respectively. This revision is a direct response to South Africa’s evolving regulatory landscape and the need to align local anti-money laundering (AML) and counter-terrorism financing (CTF) practices with international standards. The updated guidance was developed in collaboration with the National Treasury, the South African Reserve Bank and the Financial Sector Conduct Authority.
While the foundational principles of a risk-based approach remain unchanged, the revised guidance introduces several amendments aimed at aligning with recent legislative reforms, enhancing clarity, and improving operational compliance for accountable institutions.
Legal alignment
One of the most notable updates in the Revised GN 7A is its alignment with the General Laws Amendment Act (GLAA) of 2022. The GLAA aimed to strengthen South Africa’s legal and regulatory framework for combating financial crime, particularly in response to deficiencies identified by the Financial Action Task Force (FATF) during its 2021 Mutual Evaluation of the country’s AML/CTF systems. The Revised GN 7A also incorporates references to the FIC’s Public Compliance Communication (PCC) 59, which provides the most current and detailed guidance on beneficial ownership.
These updates ensure that accountable institutions are operating within a legal framework that reflects both domestic regulatory evolution and global best practices.
Terminology for PEPs and PIPs
The Revised GN 7A replaces outdated terminology such as “foreign prominent public official” and “domestic prominent influential person” with more current and legally aligned terms. Institutions are now directed to use the following classifications:
- Domestic Politically Exposed Person (DPEP) – Schedule 3A
- Foreign Politically Exposed Person (FPEP) – Schedule 3B
- Prominent Influential Person (PIP) – Schedule 3C
Instead of listing specific roles under each category, the updated guidance now refers directly to the relevant Schedules in the FIC Act, streamlining compliance and reducing ambiguity.
Beneficial ownership
In a move to reduce duplication and improve clarity, the Revised GN 7A removes several provisions related to beneficial ownership and instead refers accountable institutions to the FIC’s PCC 59. The guidance also expands on the treatment of trusts, emphasising the need to identify the natural person behind any legal structures. This ensures that institutions maintain transparency and accountability in complex ownership arrangements.
Ongoing due diligence and tipping off
An operational update in the Revised GN 7A allows accountable institutions to discontinue the ongoing due diligence process if continuing the process could risk tipping off a client about filing a report related to a suspicious transaction or activity. In such cases, institutions are advised to stop the ongoing due diligence process and assess whether a Section 29 report should be filed under the FIC Act.
Board accountability for RMCP
The revised guidance reinforces the importance of governance in the Risk Management and Compliance programme (RMCP). It clarifies that the RMCP must be approved by the board of directors, or where no board exists, by senior management or the highest authority within the institution. Importantly, this responsibility cannot be delegated.
Targeted financial sanctions
The Revised GN 7A broadens its coverage of targeted financial sanctions to include both FATF Recommendation 6 (related to terrorism and terrorist financing) and FATF Recommendation 7 (related to the proliferation of weapons of mass destruction). Previous versions of the guidance only addressed Recommendation 7.
Additionally, the revised note includes direct references to the FIC’s PCC 44A, which offers detailed guidance on implementing financial sanctions. This expansion ensures that institutions are equipped to respond to a wider range of threats and comply with international obligations.
Conclusion
The Revised Guidance Note 7A represents a significant step forward in South Africa’s AML/CTF regulatory landscape. By aligning with recent legislative changes and international standards, the FIC has provided accountable institutions with a clearer, more robust framework for compliance. Accountable institutions are strongly encouraged to review the full guidance note and ensure that their internal policies, procedures, and RMCPs reflect the latest requirements.
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