South Africa's General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Bill has moved through successive drafts since 2024 and, as of early October 2026, was before Parliament's Standing Committee on Finance, which had held public hearings, received National Treasury's response to submissions on 26 August 2026 and completed clause-by-clause deliberations on 23 September 2026 without formally adopting the Bill. Alongside it, the Financial Intelligence Centre has finalised Directive 10 on geographic location reporting, which took effect on 31 July 2026. Both are part of preparing South Africa for its next FATF Mutual Evaluation, due to begin in mid-2026 and conclude in October 2027. This article sets out what each instrument proposes and what accountable institutions should be doing now, noting that the Bill is still moving through Parliament while Directive 10 is already in force.
What the Amendment Bill proposes
The Bill amends four pieces of legislation: the Financial Intelligence Centre Act, the Financial Sector Regulation Act, the Companies Act and the Nonprofit Organisations Act. Its most discussed provision expands the Financial Intelligence Centre's powers to conduct lifestyle audits, assessing whether an individual's standard of living is consistent with income from legitimate, declared sources, and to share audit outcomes with other organs of state, public entities or municipalities on request.
As of National Treasury's response to public submissions on 26 August 2026, the Bill's drafters had indicated they would clarify the legal basis on which the FIC could conduct a lifestyle audit at another public body's request and make a further technical amendment to the FICA provisions, while holding firm on the proposed changes to the Financial Sector Regulation Act. The Bill also extends FICA record-keeping obligations, commonly cited as moving from 5 to 7 years, and strengthens Risk Management and Compliance Programme obligations, and transforms the NPO Directorate into a more active supervisor with powers to issue compliance notices and administrative sanctions.
Directive 10 on geographic location reporting
The FIC published draft Directive 10 on 19 December 2025 and, after considering comments, finalised it. Directive 10 of 2026 took effect when it was gazetted on 31 July 2026. It requires specified accountable institutions to provide and maintain detailed records of their geographic locations, including domestic and international branches and subsidiaries, and to update them within 90 days of any change. The final directive is narrower than the draft: sources describe it as confined to designated non-financial businesses and professions, with the FIC indicating that a further directive may follow for the financial institutions sector. Registered institutions had until late October 2026 for their initial update.
The Bill remains in progress, so its detail reflects the best understanding from the sources available, and firms should confirm the final enacted text before building compliance processes around specific provisions. Directive 10, by contrast, is final and in force.
Why lifestyle audits matter for transaction monitoring
A lifestyle audit power sitting with the FIC is a different tool from an institution's own transaction monitoring, but the two are related. Monitoring is how an accountable institution detects that a customer's transaction activity looks inconsistent with their stated occupation, income or business profile in the first place. A well-evidenced monitoring and escalation trail, including the reasoning behind why an institution did or did not file a suspicious transaction report, becomes more valuable to an institution's own defensibility if that customer later becomes the subject of an FIC lifestyle audit or an information request from another organ of state.
This is a reason to strengthen internal documentation now rather than wait for the Bill's final form, since the underlying discipline (linking observed transaction behaviour to declared customer information, and recording why a decision was made) is good monitoring practice regardless of the exact powers the Bill ultimately grants the FIC.
Preparing for the FATF Mutual Evaluation
South Africa's next FATF Mutual Evaluation begins in mid-2026 and concludes in October 2027, and the reforms above are explicitly framed as preparation for it, alongside the country's earlier exit from the FATF grey list in October 2025. For accountable institutions, that means monitoring and reporting practices adopted now are likely to be tested against a higher effectiveness bar than in the previous evaluation cycle, not just a technical-compliance checklist.
Extended record retention (if enacted as proposed) also has a direct monitoring implication: institutions should confirm their case-management and transaction-history systems can support the longer retention period before it becomes a legal requirement, rather than discovering a systems gap after the Bill is enacted.
