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AML and CFT registration and reporting

Any business moving customer value across a border, in every SADC member

Instrument not yet established. The obligation almost certainly exists — this is what has not been named.

Every SADC member is an ESAAMLG member and is assessed against FATF standards. The institution and the statute differ by country; the obligation does not.

Typically evidenced by — Registration with the financial intelligence unit; a risk management and compliance programme; customer due diligence records; suspicious transaction reporting; travel rule data on transfers

Data protection

Any business processing customer identity data, which is every payments business

Instrument not yet established. The obligation almost certainly exists — this is what has not been named.

KYC creates a large identity dataset by design. Several members have enacted protection statutes with registration and cross-border transfer conditions attached.

Typically evidenced by — Registration with the data protection authority where required; lawful basis; cross-border transfer conditions

Exchange control approval

Any outbound cross-border transfer from a jurisdiction operating controls

Instrument not yet established. The obligation almost certainly exists — this is what has not been named.

South Africa operates exchange control through SARB Financial Surveillance, and the Common Monetary Area extends related arrangements to Lesotho, Namibia and Eswatini. Several other members operate their own. This governs whether a transfer is permitted at all, before anyone asks what it costs.

Typically evidenced by — Authorised dealer relationship; purpose-of-payment classification; reporting per transaction above threshold

Payment service authorisation or licensing

Any business providing payment services rather than using someone else's licence

Instrument not yet established. The obligation almost certainly exists — this is what has not been named.

Most SADC members operate a national payment systems statute under which providers are designated or licensed by the central bank. This is the obligation that most often blocks an entrant, because it cannot be satisfied by growing.

Typically evidenced by — A payment service provider licence or designation; system participation approval; capital and governance requirements

Tax registration and transaction reporting

Any business with local presence or local-source revenue

Instrument not yet established. The obligation almost certainly exists — this is what has not been named.

Separate from financial regulation and commonly overlooked in market-entry planning until after a structure is chosen.

Typically evidenced by — Tax registration; withholding obligations; transaction reporting where imposed