AML & Trade Compliance
Protecting your business through robust compliance frameworks
Overview
In an increasingly regulated global economy, anti-money laundering (AML) compliance and trade regulation adherence are not optional — they are essential to business continuity and reputation. Our AML & Trade Compliance practice provides comprehensive advisory and implementation services to ensure your organisation meets its regulatory obligations across all jurisdictions in which it operates.
We work with financial institutions, corporates, fintech companies, and public sector entities to design, implement, and maintain compliance programmes that satisfy regulatory requirements while supporting business objectives. Our approach combines deep legal expertise with practical understanding of operational realities.
Our Services
AML Programme Design & Implementation
- Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) frameworks
- Know Your Customer (KYC) policy development and implementation
- Transaction monitoring systems design and optimisation
- Suspicious Activity Report (SAR) procedures and filing protocols
- AML risk assessment methodologies
- Compliance programme gap analysis and remediation
Sanctions & Trade Controls
- Sanctions screening programme development
- Export control compliance and licensing
- Trade-based money laundering detection
- Sanctions risk assessment and mitigation strategies
- OFAC, EU, and UN sanctions compliance
- Dual-use goods classification and advisory
Regulatory Advisory & Reporting
- FIC Act compliance and reporting obligations
- FICA registration and ongoing compliance
- Regulatory examination preparation and response
- Cross-border regulatory coordination
- Beneficial ownership transparency requirements
- Correspondent banking due diligence
Compliance Training & Culture
- Board and senior management AML awareness programmes
- Staff training on red flags and reporting obligations
- Compliance culture assessments and improvement strategies
- Policy documentation and procedure manuals
- Annual compliance programme reviews and updates
Investigations & Enforcement
- Internal investigation management and reporting
- Regulatory enforcement defence and negotiation
- Voluntary disclosure and self-reporting guidance
- Asset tracing and recovery proceedings
- Cross-border cooperation with regulatory authorities
Need Compliance Guidance?
Our team can help you build and maintain a compliance programme that protects your business and meets regulatory expectations.
Free Resource: AML Compliance Checklist
Download our comprehensive AML Compliance Checklist — a practical, step-by-step guide to help your business meet anti-money laundering requirements with confidence.
FIC Act Obligations
The Financial Intelligence Centre Act 38 of 2001 (FIC Act) is South Africa’s primary anti-money laundering legislation. It establishes the Financial Intelligence Centre (FIC) and imposes a comprehensive framework of obligations on accountable and reporting institutions. We advise clients on their obligations under the FIC Act, including registration with the FIC, appointment of compliance officers, and implementation of Risk Management and Compliance Programmes (RMCPs).
The 2017 amendments to the FIC Act introduced a risk-based approach (RBA), replacing the previous rules-based framework. This shift requires institutions to conduct their own risk assessments and develop proportionate controls. We help clients design and implement RBA-compliant programmes that satisfy regulatory expectations while remaining practical and efficient.
FICA Customer Due Diligence
The Financial Intelligence Centre Act requires accountable institutions to conduct Customer Due Diligence (CDD) on all clients and counterparties. This includes verifying the identity of natural persons and legal entities, identifying beneficial owners, and understanding the nature and purpose of business relationships. We advise on establishing CDD procedures that meet the requirements of sections 21, 21A, and 21B of the FIC Act, including enhanced due diligence for high-risk clients, politically exposed persons (PEPs), and complex ownership structures.
Our advisory services cover the practical challenges of implementing CDD processes, including electronic verification, reliance on third-party verification, and ongoing monitoring of client relationships for changes in risk profile.
Reporting Obligations
Accountable and reporting institutions must file various reports with the FIC, including Suspicious and Unusual Transaction Reports (STRs), Cash Threshold Reports (CTRs) for transactions exceeding R24,999.99, and Terrorist Property Reports (TPRs). We advise on establishing effective reporting systems, training staff to identify suspicious transactions, and maintaining the required records. Non-compliance carries severe penalties including administrative sanctions of up to R50 million for individuals and R150 million for institutions.
Targeted Financial Sanctions
South Africa implements United Nations Security Council targeted financial sanctions through the FIC Act and the Protection of Constitutional Democracy against Terrorist and Related Activities Act (POCDATARA). We advise institutions on their obligations to screen clients and transactions against the FIC’s Targeted Financial Sanctions list, freeze property of designated persons and entities, and report any matches or attempted transactions to the FIC. We also advise on the interaction between South African sanctions obligations and foreign sanctions regimes.
AML Programme Design & Training
An effective AML compliance programme requires more than policies on paper. We work with institutions to build comprehensive Risk Management and Compliance Programmes that include governance structures, risk assessment methodologies, CDD procedures, transaction monitoring systems, reporting workflows, record-keeping protocols, and employee training curricula. Our training programmes are tailored to the specific risk profile and operational context of each client, ensuring that all relevant staff understand their obligations and can fulfil them in practice.