With the New Zealand rugby team back on South African soil, much of the country’s attention is understandably focused on the battles taking place on the rugby field. While the Springboks and All Blacks continue one of sport’s greatest rivalries, our regulators appear determined not to be outdone when it comes to keeping us entertained.
This month has delivered a healthy mix of regulatory developments, consultations, and guidance notes across the financial sector.
We’ve summarised the key developments below so that you can spend less time working through lengthy regulatory publications and more time debating rugby selections and refereeing decisions.
THE FINANCIAL SECTOR CONDUCT AUTHORITY (FSCA)
Warnings
It seems the FSCA is back in its groove and is issuing public warnings on a more regular basis. Here are the latest ones to be aware of.
The FSCA issued a public warning after fraudsters were found to be impersonating GTC (Pty) Ltd on social media platforms, including WhatsApp, to solicit investments from members of the public. GTC has confirmed that it is not associated with these individuals.
Another warning was issued to the public about individuals impersonating GatesFX (Pty) Ltd on online platforms. The impersonators, operating as GatesFX LTD, are using a website and Facebook page to solicit funds for purported forex trading investments. GatesFX (Pty) Ltd has confirmed that it has no association with these platforms, while GatesFX LTD is not authorised under South African financial sector legislation to provide financial services.
The FSCA reminds consumers to remain vigilant against unsolicited investment offers and highlights common warning signs of investment scams, including promises of unrealistic returns, upfront payment requests, pressure to act urgently, and vague investment information. The regulator also encourages the public to verify the authorisation status of financial services providers before investing and to report any suspected fraudulent activity.
The FSCA announced that it is investigating The Grand Trading (Pty) Ltd and its related persons Simon Durdey, Christel Larissa Pretorius, and Boris Atanasov Kodzhov following numerous client complaints. According to the company, it provides intermediary services relating to a platform offering Contracts for Difference. The investigation will determine whether the parties have contravened financial sector legislation, including provisions under the Financial Markets Act relating to over-the-counter derivatives. The FSCA emphasised that the investigation is ongoing and that no findings of wrongdoing have yet been made.
FSCA publishes 2025/2026 Regulatory Actions Report
The FSCA has released its 2025/2026 Regulatory Actions Report, highlighting enforcement action taken during the period 1 April 2025 to 31 March 2026. The report notes that penalties totalling R2.8 billion were imposed on 76 individuals and entities, reflecting a significant increase from the previous reporting period.
The most notable enforcement actions related to serious FAIS Act contraventions, market abuse, and anti-money laundering compliance failures, including the high-profile Banxso matter. The FSCA also noted that it will host enforcement roadshows and media engagements to share key lessons and emerging regulatory trends with the industry.
FINANCIAL INTELLIGENCE CENTRE (FIC)
FIC Directive 10 of 2026 requires expanded location reporting by certain accountable institutions
The FIC issued Directive 10 of 2026, introducing new registration and reporting requirements relating to the geographic locations of operations for certain accountable institutions. The Directive applies to:
- Attorneys and legal practitioners.
- Trust and company service providers.
- Estate agents/property practitioners.
- Gambling institutions.
- Certain credit providers (i.e. excluding banks).
- Dealers in high-value goods.
- Crypto Asset Service Providers (CASPs).
- South African Postbank.
- South African Mint Company.
Under the Directive, affected institutions operating from more than one location must provide the FIC with detailed information regarding their head offices, branch offices, subsidiaries, and subsidiary branches, both within South Africa and abroad. Required information includes business addresses, licence and registration numbers (where applicable), and the contact details of the person responsible for the institution’s compliance function at each location.
Institutions already registered with the FIC must update their registration details within 90 days of the Directive taking effect (so technically by 29 October 2026), while any subsequent changes to these particulars must also be reported within 90 days.
The FIC has warned that non-compliance may result in administrative sanctions under the FIC Act. Directive 10 became effective upon publication in the Government Gazette on 31 July 2026.
FIC issues Draft Directive on submission of RMCPs
The FIC has released Draft Directive 12 of 2026 for consultation, proposing mandatory submission requirements for Risk Management and Compliance Programmes (RMCPs) by specified accountable institutions.
The Directive aims to strengthen the FIC’s ability to monitor compliance with anti-money laundering and counter-terrorist financing obligations. It will apply to:
- Attorneys and legal practitioners.
- Trust and company service providers.
- Estate agents/property practitioners.
- Gambling institutions.
- Credit providers (i.e. excluding banks).
- Dealers in high-value goods.
- Crypto Asset Service Providers (CASPs).
- South African Postbank.
- South African Mint Company.
Under the proposal, affected institutions will be required to submit a copy of their RMCP annually via the FIC’s registration and reporting platform. Initial submission deadlines are 30 September 2026 and 31 October 2026. Newly established accountable institutions will have 90 days from commencing business to submit their RMCPs.
The Draft Directive also requires updated RMCPs to be submitted within 10 business days of approval where changes are made after the annual submission period. Failure to comply may result in administrative sanctions under the FIC Act.
Accountable institutions should review their RMCP governance and document management processes to ensure they can meet the proposed submission and update requirements if the Directive is finalised.
FIC issues revised Guidance Note 7B on AML/CFT compliance
The FIC, in collaboration with National Treasury, the South African Reserve Bank, and the FSCA, has published Guidance Note 7B, replacing previous versions of Guidance Note 7.
The updated guidance took effect from 3 August 2026, and provides direction on implementing key provisions of the Financial Intelligence Centre Act, with particular emphasis on adopting a risk-based approach to managing money laundering, terrorist financing, and proliferation financing risks.
The guidance expands on expectations relating to customer due diligence, record-keeping, RMCPs, beneficial ownership, ongoing monitoring, and sanctions screening. It also reinforces that accountable institutions should tailor their controls to the level of assessed risk, document their methodologies, and regularly review their risk frameworks as products, technologies, and threats evolve.
Institutions should review the updated guidance carefully to ensure their AML/CFT frameworks, policies, and procedures remain aligned with the FIC’s latest expectations.
PRUDENTIAL AUTHORITY (PA)
Proposed new requirements for beneficial owners
The FSCA and PA have released a draft Joint Standard on Beneficial Owners for public comment. This reflects South Africa’s continued efforts to strengthen governance, combat financial crime, and address deficiencies identified through the Financial Action Task Force mutual evaluation process.
The draft Joint Standard seeks to introduce a formal regulatory framework for beneficial owners of financial institutions. In its current format, this includes accountable institutions as defined in the Financial Intelligence Centre Act. Its key objectives include requiring beneficial owners to meet honesty and integrity standards, obliging institutions to identify, verify, and monitor beneficial owners, and enhancing transparency around ownership and control structures.
Under the proposal, financial institutions will be required to establish governance policies and procedures relating to beneficial ownership, maintain accurate records, conduct ongoing reviews at least every two years, and report beneficial owner information to the relevant regulator. New or ceased beneficial owners must be reported within 30 calendar days.
The draft Standard also provides clarity on the concepts of “ultimate ownership” and “effective control”, including thresholds that may trigger beneficial owner status. For example, direct ownership of 5% or more and certain levels of voting rights or influence may result in a person being regarded as a beneficial owner.
The Authorities have highlighted concerns that opaque ownership structures can be used to conceal criminal involvement in financial institutions, facilitate money laundering, sanctions evasion, terrorist financing, and other forms of financial crime. The proposed framework is intended to ensure that only transparent, fit-and-proper individuals are able to own or exercise significant influence over regulated entities.
While the Standard is expected to strengthen trust in the South African financial system and support international AML/CFT objectives, companies should anticipate additional compliance obligations and administrative costs associated with beneficial ownership identification, verification, and monitoring processes.
Stakeholders have until 25 September 2026 to submit comments to the FSCA and Prudential Authority by sending the comments template to FSCA.RFDStandards@fsca.co.za or PA-Standards@resbank.co.za.
Proposed fee increases
The PA proposed updated levies and regulatory fees for the 2027/28 financial year. The proposed levy increase is 3.7% across supervised entities. For non-life insurers and Lloyd’s, the proposed base levy increases from R14,276 to R14,804, while the variable levy rate increases from 0.1770% to 0.1835%, with the maximum levy increasing from R17.13 million to R17.76 million.
The PA is proposing an average increase of approximately 3.7% in application and notification fees for 2027, broadly in line with the proposed annual inflationary adjustment.
SOUTH AFRICAN RESERVE BANK (SARB)
CODI: Single Customer View (SCV) calculations and Data Handbook for member banks
The Corporation for Deposit Insurance (CODI) published the latest versions of the SCV calculations document ‒ the SCV Data Handbook ‒ and the Coverage and Reporting Rules document. Together, these documents provide banks with comprehensive guidance on the compilation of SCV calculations, the reporting and submission of SCV data, and the application of deposit insurance coverage and reporting requirements. The SARB encouraged banks to familiarise themselves with the updated documents and to ensure that their internal processes and reporting practices remain aligned with CODI’s coverage and reporting requirements.
South Africa moves closer to formal regulation of cross-border crypto asset transactions
The SARB’s Financial Surveillance Department (FinSurv) has released a draft Crypto Asset Manual for Cross-Border Activities for public comment, marking a significant step towards the formal regulation of crypto asset flows into and out of South Africa. Comments on the draft are due by 30 September 2026 and should be submitted to SARB-FinSurvDocuments@resbank.co.za using the prescribed annexure.
The proposed framework would formally introduce a new category of regulated entities known as Authorised Crypto Asset Service Providers (CASPs). These providers would require specific authorisation from National Treasury, administered through FinSurv, to facilitate crypto asset transactions that are deemed cross-border. The framework is aligned with the draft Capital Flow Management Regulations and follows industry testing conducted through several regulatory sandbox initiatives.
Of particular interest to financial institutions, compliance officers, and crypto service providers are the proposed requirements relating to governance, capital adequacy, customer due diligence, transaction monitoring, record-keeping, and detailed reporting to the FinSurv Reporting System. The draft also introduces specific rules governing the movement of crypto assets under South Africa’s existing exchange control allowances, including the R2 million Single Discretionary Allowance and R10 million Foreign Capital Allowance for qualifying individuals.
The framework proposes that cross-border crypto asset transfers between South African authorised providers and offshore wallets or offshore CASPs be classified as imports or exports of capital and become reportable to FinSurv. Resident entities would generally be prohibited from undertaking crypto asset transactions that constitute imports or exports of capital, while authorised providers would be subject to extensive supervisory and reporting obligations.
Firms involved in crypto asset services, payments, remittances, or compliance should carefully review the proposals and consider submitting comments before the consultation period closes.
Transition of national payment system management functions
The SARB has commenced the withdrawal of the Payments Association of South Africa’s (PASA) recognition as a payment system management body, as part of broader reforms to modernise and strengthen South Africa’s National Payment System (NPS).
The transition will see selected regulatory, authorisation, standards, and risk-management functions transferred to the SARB, while remaining payment clearing and operational functions will transition to PayInc.
The changes are being implemented from 11 August 2026, with the full transfer expected to be completed by 2 September 2026. Importantly, the SARB has confirmed that the transition is intended to have minimal impact on consumers and businesses, with existing payment services such as card payments, EFTs, debit orders, ATM withdrawals, DebiCheck, and PayShap continuing to operate as normal.
The reforms will effectively move the NPS away from PASA’s previous self-regulatory model towards a framework in which the SARB assumes greater responsibility for regulation, authorisation, standards, interoperability, risk, and resilience, while PayInc assumes responsibility for key payment clearing and operational functions.
COUNCIL FOR MEDICAL SCHEMES (CMS)
CMS issues guidance on contribution increases
The CMS issued Circular 20 of 2026, providing guidance to medical schemes on contribution increases and benefit changes for the 2027 benefit year. The CMS recommends that contribution increases and non-healthcare expenditure be limited to 3.8%, in line with projected CPI inflation, to protect affordability amid ongoing economic pressures.
Schemes seeking higher increases will be required to provide robust actuarial and financial justification and may be asked to obtain an independent actuarial opinion. The Circular also places renewed emphasis on trustees’ fiduciary duties, cost containment, fraud prevention, value-for-money procurement, and maintaining sustainable benefit designs, while setting out the statutory requirements and submission deadlines for 2027 rule amendments.
A-PROOFED
I’ve just returned from the UK, the supposed home of the English language. After two weeks there, I have to say I’m not entirely convinced that everyone got the memo about grammar.
You’d think that travelling around an English-speaking country, where English is, rather obviously, the first language, would mean that basic spelling, punctuation, and grammar would be fairly safe territory. Apparently not. I found myself noticing signs everywhere, and not because I was particularly interested in what they had to say. I was looking at the apostrophes. And once I started noticing them, I couldn’t stop. It’s a curse.
There were apostrophes where they shouldn’t have been, apostrophes missing where they were needed, and the occasional apostrophe that seemed to have been added simply because someone felt that a word looked a little lonely without one. Plurals seemed to be particularly vulnerable. If someone wasn’t sure whether a word needs an apostrophe, the safest option seemed to be to put one in anyway.
It reminded me of Bristol’s grammar vigilante, known as the “Banksy of punctuation”, who goes out at night correcting rogue apostrophes on signs. He even invented an eight-foot-long device called the “Apostrophiser” to reach the high ones. I’ve always thought this was rather brilliant, although I’m not sure whether he’s a hero or simply someone who needs a hobby. After two weeks in the UK, I could understand the temptation. I didn’t have an Apostrophiser, but I did find myself wondering whether carrying a permanent marker through London would be taking things a little too far.
What amused me most was seeing these mistakes on professionally produced signs. I can understand a handwritten sign outside a small shop having the odd typo. Someone may have written it in five minutes, stuck it up, and got on with running the business. Fair enough. But when a sign has clearly been designed, printed, installed, and presumably approved by several people, and there’s an apostrophe sitting there looking completely out of place, I do start wondering who was checking it.
And then I thought about it from the other side. A restaurateur knows how to run a restaurant. A chef knows how to cook. Neither necessarily knows the finer points of English grammar, nor should they. Their skills lie elsewhere. I can proofread a document, but ask me to cook dinner, and you may want to have a backup plan. I don’t particularly enjoy cooking, either, so I’m certainly not about to criticise a chef for not knowing where to put an apostrophe.
We all have different skills. Just because we’re good at what we do doesn’t mean we should automatically be good at everything else.
You may know your industry inside out. You may be an expert in financial services, compliance, risk, investments, or insurance. You may know exactly what you want to say. But that doesn’t mean you’ll spot the missing comma, duplicated word, inconsistent terminology, or sentence that made perfect sense when you wrote it but now makes you wonder what on earth you were thinking.
That’s where I come in. You know your business. You know your clients. You know your industry. Let me worry about the apostrophes, the spelling, the grammar, the consistency, and all those little things that are surprisingly easy to miss when you’re too close to the document.
Just please don’t ask me to cook anything!
Kim Hatchuel
083 657 3377 | kim@a-proofed.co.za
www.a-proofed.co.za
