and directives with the same force as the Act itself. Dealers often fail to conduct proper sanctions screening or check for political exposure. Where screening is done, it may only be performed once - despite requirements to rescreen whenever sanctions lists are updated. Another recurring weakness is failing to understand what a suspicious transaction looks like within their specific business context. “If you’ve never had to think about this before, how do you know what untoward looks like?” McEwan asks. Practical steps to mitigate risk For equipment suppliers, the starting point is straightforward: verify customers properly for every transaction involving a single item priced at R100 000 or more. This includes collecting and verifying identity documents, CIPC registration details and proof of address. Importantly, documents must be verified against reliable sources - such as Home Affairs or credit databases - rather than simply copied. Dealers should also assess the source of funds,check for sanctions and political exposure, train staff to recognise red flags, appoint an internal compliance officer
more destructive. Public association with money laundering can prompt banks to close accounts, customers to withdraw, and manufacturers to terminate supply agreements. Directors may also face personal liability. “Your assets and your freedom are ultimately on the line,” McEwan warns. Balancing compliance with deal velocity In a market where speed matters, many dealers fear compliance will slow sales. McEwan disagrees. When embedded early in the sales cycle - during lead qualification, site visits and demos - customer due diligence becomes part of normal business practice rather than a last-minute hurdle. Technology, he adds, is a critical enabler. Automated identity verification, biometric checks, digital record-keeping and real- time sanctions screening can all occur in the background while sales teams focus on closing deals. “Compliance done properly doesn’t have to slow you down,” he concludes. “In fact, when it’s built into your processes from the start, it can make your business stronger, safer and more efficient.” b
with authority to halt transactions where necessary, and maintain robust record- keeping and reporting processes. “You can’t just do one thing and be compliant,” McEwan emphasises. “It has to be holistic.” The danger of complex payment struc- tures Third-party payments, overpayments followed by refunds, and split invoicing across entities or jurisdictions can all expose dealers to regulatory risk. These structures are frequently used in laundering schemes. If a dealer cannot reasonably explain why a Mauritian company is paying for equipment purchased by a Johannesburg contractor, the Financial Intelligence Centre may view the transaction as facilitated laundering or inadequate due diligence. The risk is far from theoretical. Financial and reputational fallout Non-compliance carries severe consequences. Administrative penalties can reach millions of rand. In serious cases, criminal prosecution may result in fines of up to R100-million or imprisonment. Yet reputational damage can be even
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