Financial Flows and Key Indicators Associated With Illicit Financial Flows and Trade-Based Money Laundering in South Africa

Publication Date: 05/10/2026

South Africa’s exposure to illicit financial flows (IFF) via trade and payments is material, cross-border, and multi-channel. External evidence highlights commodity-centric risks – especially gold – and persistent partner country discrepancies characteristic of trade mis-invoicing. Supervisory insights, aggregated from anonymised bank returns, show how value moves through the regulated sector on high-velocity retail rails, via cards and E F Ts, and along trade payment practices such as advance payments and document light transactions. Triangulated together, these lenses point to a consistent picture of South Africa’s IFF and TBML exposure – concentrated in commodity corridors (notably gold), retail payment rails (cards and EFTs), and multi-hop correspondent chains – and support a focused set of joint public–private actions to address IFF and TBML more effectively. 

Mirror trade analyses identify signicant discrepancies in South Africa’s commodity trade statistics, particularly in gold that may be consistent with trade misinvoicing and warrants further investigation.  

These patterns align with global (TBML typologies: over or under-invoicing, multiple invoicing, phantom shipments, and harmonised system (HS) code abuse, often facilitated by weak documentation and opaque intermediaries. At the same time, bank-reported data indicate three recurring payment vectors: Cash-in followed by foreign cash-out on cards; card-to-crypto or retail-foreign exchange (“FX/Forex ” ) spend; and EFT pass-throughs or third-party payments (including via non-resident foreign currency accounts). Across correspondent banking chains, risk concentrates where originator and beneciary data degrade across multi-hop routes, or nested relationships obscure the true parties. 

This assessment is presented in the context of South Africa’s removal from the FATF list of Jurisdictions under Increased Monitoring on 24 October 2025, and is intended to support the sustainability commitments given by South Africa to the FATF. 

Financial Flows and Key Indicators Associated With IFF and TBML in SA