Practical Implication Of The Revised FIC Guidance Note 7A

In line with South Africa's attempts to get off the Financial Action Task Force's (FATF) greylist, the Financial Intelligence Centre (FIC) issued the Revised Guidance Note 7A (revised GN 7A) on 1 September 2025. This replaces the previous Guidance Notes 7 and 7A to better align with recent legislative developments. Key among these are the General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act and Public Compliance Communication (PCC) 59 (PCC 59).

Some of the key revisions in Revised GN 7A include:

• Beneficial ownership guidance now refers to FIC PCC 59, with the previous paragraph referencing 25% as an indicator of controlling ownership interest in a legal person removed entirely.