By James George, Compli-Serve

Among the African countries currently under increased monitoring by the FATF—South Africa, Namibia, Nigeria, Mozambique, and South Sudan—South Africa is the most likely to exit the greylist first, followed by Namibia. Below is a comparative analysis of their progress based on the complexity of outstanding deficiencies and demonstrated improvements.

1. South Africa – Most Likely to Exit First
On Greylist Since: February 2023
Progress: South Africa has made significant improvements, including ensuring effective sanctions by supervisors, increasing beneficial ownership (BO) transparency, and applying sanctions for BO violations.
Outstanding Deficiencies: The only remaining issue is demonstrating a sustained increase in investigations and prosecutions of serious and complex money laundering and terrorist financing (TF) cases.
Likelihood of Exit: High With only one remaining issue and a strong regulatory framework, South Africa is on track to exit by October 2025, pending FATF’s next review.

2. Namibia – Second Most Likely to Exit
On Greylist Since: February 2024
Progress: Namibia has strengthened its Financial Intelligence Unit (FIU) and increased resources for law enforcement agencies (LEAs) in terrorist financing (TF) investigations.
Outstanding Deficiencies: Strengthening AML/CFT risk-based supervision with onsite/offsite inspections.
Enhancing preventive measures for FIs and DNFBPs.
Improving beneficial ownership data collection and enforcement.
Boosting cooperation between the FIU and LEAs for integrating financial intelligence.
Enhancing prosecution capabilities and training authorities.
Likelihood of Exit: Moderate to High Namibia still has multiple outstanding issues but is making good progress.
If it continues at this pace, it could be delisted in late 2025 or early 2026.

3. Nigeria – Needs More Work
On Greylist Since: February 2023
Progress: Nigeria has improved AML/CFT risk-based supervision and BO transparency and demonstrated a sustained increase in ML/TF investigations.
Outstanding Deficiencies: Strengthening preventive measures for high-risk sectors.
Enhancing detection and enforcement of currency declaration violations.
Likelihood of Exit: Moderate Nigeria has made solid progress, but the FATF requires more evidence of enforcement and prosecution.
If it accelerates reforms, it may exit by mid-2026.

4. Mozambique – Still at Risk
On Greylist Since: October 2022
Progress: Mozambique has implemented a risk-based supervision plan and enhanced TF case identification.
Outstanding Deficiencies:Conducting a risk assessment for non-profit organizations (NPOs) in line with FATF standards.
Likelihood of Exit: Low to Moderate While Mozambique has shown improvements, risk assessments for NPOs are crucial for delisting.
Likely remains on the greylist until at least 2026.

5. South Sudan – Least Likely to Exit Soon
On Greylist Since: June 2021
Progress: South Sudan has finalized a comprehensive review of its AML/CFT Act.
Outstanding Deficiencies: Full implementation of key international conventions (Vienna, Palermo, Terrorist Financing).
Structuring authorities for risk-based AML/CFT supervision.
Developing a framework for BO data collection.
Operationalizing a functional, independent FIU.
Establishing legal and institutional frameworks for UN sanctions compliance.
Implementing risk-based monitoring of NPOs at risk of TF abuse.
Likelihood of Exit: Very Low The FATF noted “limited progress” with all deadlines expired.
South Sudan is at risk of being blacklisted unless urgent steps are taken.
Exit unlikely before 2027 or later.

Final Ranking: Who Will Exit the Greylist First?
South Africa – Most likely (Oct 2025)
Namibia – Likely (Late 2025 – Early 2026)
Nigeria – Possible (Mid 2026)
Mozambique – Unlikely before 2026
South Sudan – Very unlikely (2027 or later)

South Africa has the highest chance of exiting first due to only one remaining deficiency and strong political commitment. Namibia follows closely but has more complex issues to resolve. Nigeria is progressing but needs enforcement improvements, while Mozambique and South Sudan still face substantial challenges.