Anti-Money Laundering (AML)

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Anti-Money Laundering (AML)
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55 documents
Title
Jurisdiction
Date
Reported
Whether the trial judge misapplied law, prompting the applicant’s challenge to the respondents’ acquittals.
Criminal procedure — s 319(1) reservation of questions of law; s 174 discharge at close of State case; doctrine of common purpose; documentary evidence and best evidence rule; s 204 witness indemnity; PFMA, fraud and money‑laundering charges; retrial permitted.
Judgment 12 June 2025
Communications and Media · Infrastructure and Transportation
Act 8 May 2024
 Zambia Judgment 22 December 2023
Research Report 1 October 2023
Business, Trade and Industry · Energy and Natural Resources · Environment, Climate and Wildlife · Finance and Money
Act 18 August 2023
Reported
Court declared seized bulk cash forfeited as proceeds of unlawful activities and rejected the respondent's claim of lawful ownership.
POCA — Civil forfeiture under Chapter 6 — Proceeds of unlawful activities and instrumentality of offence — Locus standi under s 39(3)/(5) — s 52 exclusion (acquired legally and for consideration; knowledge) — Customs and Exchange Control contraventions; bulk cash smuggling; money laundering.
Gauteng Judgment 26 July 2023
Reported
NDPP authorisations to prosecute for racketeering satisfied the rationality requirement; application dismissed with costs.
Criminal procedure – POCA s 2(4) – NDPP’s written authorisation – principle of legality and rationality review. Racketeering – pattern requires at least two Schedule 1 offences – corruption and money laundering can be distinct predicate offences. Money laundering – concept broad; concealment/disguise of payments may constitute proceeds-of-unlawful-activities. Standard of review – deference to prosecutorial discretion but requirement of rational connection between material and decision.
KwaZulu-Natal Judgment 22 January 2021
 United States Judgment 31 July 2019
 United States Judgment 5 April 2019
 India Judgment 2 February 2018
 United States Judgment 25 September 2017
 India Judgment 9 August 2017
The accused were convicted of coordinated VAT refund fraud, related forgery/uttering and money‑laundering based on documentary and electronic evidence.
Criminal law – VAT refund fraud using shell entities; documentary and electronic evidence – admissibility and authentication under the ECT Act; Tax Administration Act and state privilege – limits and court discretion; witness legal representation while testifying; common purpose liability; forgery, uttering and money‑laundering (POCA) via intercompany "cheque swops".
Gauteng Judgment 4 August 2017
Judgment 1 June 2017
 Zimbabwe Judgment 3 October 2016
 United States Judgment 12 August 2016
 Tanzania Judgment 11 August 2016
Peace and Security
Act 1 June 2016
Reported
Accomplice evidence corroborated by documents established VAT fraud, forgery and uttering; money laundering and POCA acquisition convictions not proved.
Criminal law – VAT refund fraud – forgery and uttering – admissibility of electronic SARS records (s15(4) ECT Act) – accomplice evidence and corroboration – money laundering (s4 POCA) requires concealment/disguising; mere receipt and spending of proceeds insufficient – s6 POCA acquisition/possession inapplicable where accused is principal.
Gauteng Judgment 27 May 2016
 Malawi Judgment 1 March 2016
Reported
POCA liability upheld: s2(1)(f) can be satisfied by culpa; s2(1)(e) needs no extra mens rea beyond predicate offences.
Criminal law; organised crime – POCA ss 2(1)(e),(f),(b) – elements and mens rea (dolus or culpa for s2(1)(f); s2(1)(e) requires participation via predicate offences only); money‑laundering (s4); receiving/retaining proceeds (s2(1)(b)); duplication of convictions (single offence where statute criminalises carrying‑on of business/practice); Banks Act, Insolvency Act, Companies/Close Corporations Act and Income Tax Act liabilities feeding into POCA; appellate interference with sentence.
Judgment 4 December 2015
 United States Judgment 23 November 2015
 Zambia Judgment 1 June 2015
 Malawi Judgment 16 April 2015
Reported
Applicant’s pre-existing right to seek a second appeal to the SCA was preserved, but leave to appeal was refused for lack of prospects.
* Criminal appeals – second appeals to the Supreme Court of Appeal – effect of repeal of Supreme Court Act by Superior Courts Act – definition of 'appeal' excludes matters under Criminal Procedure Act. Transitional provisions and Interpretation Act – protection of rights in pending proceedings preserves pre-existing appeal rights. Jurisdiction – SCA has no inherent jurisdiction; leave required and may be refused for lack of prospects of success
Western Cape Judgment 3 April 2014
Reported
Applicants’ constitutional challenges to POCA’s definitions, evidentiary provision and retrospectivity dismissed; High Court’s severance not confirmed.
Criminal law – Prevention of Organised Crime Act – Definitions: "pattern of racketeering activity" and "enterprise" – vagueness and overbreadth challenge dismissed; Evidence – s 2(2) POCA permits otherwise inadmissible hearsay, similar-fact and previous-conviction evidence subject to proviso preserving fair trial – admissibility assessed case-by-case; Retrospectivity – Chapter 2 not retrospective as conviction requires post-enactment pattern; Fault element – phrase "ought reasonably to have known" denotes negligence standard and is constitutionally valid; Standing and abstract challenges – permissible but carry heavy burden
Judgment 20 March 2014
Conviction for money laundering upheld on circumstantial proof of knowledge; sentence reduced for consistency.
Criminal law – Money laundering (POCA s 4) – Knowledge element may be proven by specific proof of unlawful conduct or by circumstances giving an irresistible inference of criminal provenance – Hearsay inadmissible to prove original crime – Sentencing: principle of consistency required reduction.
Western Cape Judgment 19 December 2013
Reported
Facial challenge to POCA mostly dismissed; only the phrase “ought reasonably to have known” in certain s 2(1) subsections was severed and invalidated.
Constitutional law – criminal law – Prevention of Organised Crime Act (POCA) – challenge to definitions of “pattern of racketeering activity” and “enterprise” – vagueness and overbreadth – principle of legality. Constitutional law – standing – facial challenge to criminal statute by accused persons charged under the statute. Criminal law – POCA Chapter 2 – retrospectivity/ex post facto challenge – requirement of a predicate act after commencement avoids retrospective criminalisation. Evidence – s 2(2) POCA – admission of hearsay/similar fact/previous convictions subject to judicial fairness discretion – compatible with s 35 constitutional rights. Mens rea – severance of words “ought reasonably to have known” from specified subsections to avoid convicting on negligence rather than intent.
KwaZulu-Natal Judgment 17 May 2013
Reported
Automatism rejected; subjective foresight found but no reconciliation — murder convictions replaced with culpable homicide; sentence reduced to eight years.
Criminal law — Automatism — onus on State to prove voluntariness; accused must adduce factual/medical foundation. Dolus eventualis — twofold test: subjective foresight and reconciliation; foresight may exist without volitional consent. Traffic deaths — gross negligence (culpable homicide) vs dolus (murder); multiple deaths from single negligent act permit multiple counts. Sentence — seriousness of negligence, abuse of trust and personal circumstances relevant; substitution of convictions requires resentencing.
Judgment 22 March 2013
 Namibia Judgment 20 February 2012
 Mauritius Judgment 20 December 2011
Reported
POCA racketeering, theft and money‑laundering convictions upheld; NDPP authorisation and combined charging of predicate offences held valid.
Criminal law & procedure; POCA s 2(1)(e) (racketeering) and s 4 (money laundering); validity and timing of NDPP s 2(4) authorisation; centralisation certificate s 111; accomplice evidence and corroboration; charging umbrella (POCA) and predicate offences together; splitting of charges/duplication of convictions.
Judgment 28 September 2011
 United States Judgment 11 July 2011
 United States Judgment 14 December 2010
 United Kingdom Judgment 27 June 2008
 United States Judgment 24 June 2008
Reported
Section 205 subpoenas improperly authorised — cellphone records excluded; searches after arrest admissible despite defective warrants.
Criminal procedure – s 205 subpoenas – issuing magistrate’s duty to exercise judicial discretion – subpoenas issued as rubber‑stamp unlawful; resulting records inadmissible. Standing – accused may object to third‑party production of call records where records implicate accused’s privacy/interests. Arrest warrants – territorial jurisdiction – warrants issued outside proper magisterial district technically defective. Searches and seizures – ss 22 & 23 CPA – consent and urgency exceptions; searches admitted under s 22(a). Constitutional exclusion – s 35(5) – evidence unlawfully obtained need not be excluded where defect is technical, no mala fides, evidence is objective real evidence and admission would not render trial unfair.
Western Cape Judgment 11 June 2008
Reported
Upon proof that benefits flowed from corrupt conduct, POCA permits confiscation of both shares and dividends as proceeds.
POCA (chapter 5) – confiscation of proceeds after conviction – broad definition of "proceeds of unlawful activities" – indirect proceeds and corporate holdings – causal link between corrupt payment and resulting benefit – appellate review of section 18 discretion analogous to sentencing review – "double counting"/double recovery argument rejected
Judgment 29 May 2008
Reported
Non-joinder and alleged prosecutorial misconduct did not render the trial unfair; POCA confiscation appeal granted leave.
Criminal procedure – fair trial – non-joinder of suspected co-perpetrators does not, without prejudice, render trial unfair; Prosecutorial conduct – NPA Act contemplates investigative-prosecutorial overlap; Late evidence – Rules 30/31 and s22 Supreme Court Act require exceptional, incontrovertible evidence; Sentencing – minimum sentence legislation applies to ongoing offences committed before and after commencement; POCA – confiscation orders raise constitutional property and proportionality issues, leave to appeal granted
Judgment 2 October 2007
Reported
Payments and accounting manipulations to influence a public official constituted corruption, fraud and POCA offences; hearsay fax admissible; convictions and sentences upheld.
Corruption Act s 1(1)(a)(i)/(ii) – 'duty' includes constitutional and other duties, not confined to 'function'. Admissibility of hearsay – encrypted corporate fax admissible under s 3 of Law of Evidence Amendment Act where probative value high and prejudice limited. Fraud – irregular accounting write‑offs can constitute fraud where misrepresentations are knowingly made and communicated to accounting staff. POCA – service agreements and transfers can constitute dealing with proceeds of unlawful activity. Sentencing – prescribed minimum sentences apply; absence of substantial and compelling reasons justifies minimums.
Judgment 6 November 2006
Reported
Forfeiture upheld: property was an instrumentality of drug manufacture and forfeiture was not an arbitrary deprivation.
• Asset forfeiture – POCA Chapter 6 – civil forfeiture of property used for drug manufacture – instrumentality test – property must play a reasonably direct, functional role in the commission of the offence. • Property rights – section 25(1) – arbitrariness and proportionality – application of FNB factors; forfeiture must not be disproportionate to public purpose. • Evidence – late adduction on appeal – rule 31 and section 22 standards – condonation may be granted but admissibility requires stringent criteria. • Procedural – constitutional challenges must be properly pleaded and pursued in earlier courts and necessary parties joined before direct access sought
Judgment 29 September 2006
Reported
Whether property is forfeitable depends on a reasonably direct, functional link to the commission or the proceeds of unlawful activity.
Interpretation of Prevention of Organised Crime Act ch 6 – 'instrumentality of an offence' requires a reasonably direct, functional link to the commission of a scheduled offence; mere location insufficient. Owner's culpability is not relevant at first-stage inquiry; it is considered at second-stage exclusion under s 52. 'Proceeds of unlawful activities' broadly defined but requires that benefits be derived 'in connection with or as a result of' unlawful activity. Application to facts: venues where crimes occurred (house, hotel) are not automatically instrumentalities; investments/interest not proceeds where unlawful act was false representation.
Judgment 13 May 2004
Reported
Preparatory investigations under the NPA Act require suspicion of a specified offence; overbroad warrants violating privacy are void.
Constitutional principle of legality; NPA Act s 28(13)/s 29(5) — preparatory investigations require suspicion of an offence capable of being a ‘specified offence’; designations under s 28(2) invalid if based on overbroad inquiry; ex parte warrant applications demand full, adequate and objective disclosure; search warrants must be specific and not authorize general ransacking; vagueness/overbreadth of warrants invalidates seizures.
Judgment 1 April 2004
Reported
Property used as a clandestine drug laboratory can be forfeited civilly where it is an instrumentality on a balance of probabilities.
Civil forfeiture – Prevention of Organised Crime Act (POCA) s48 and s50 – civil proceedings to forfeit instrumentalities and proceeds of crime. Stay of civil forfeiture pending criminal proceedings – not granted absent legal compulsion to self-incriminate; accused’s choice to respond relevant. Expert forensic evidence in civil forfeiture proceedings – admissible under civil standards; unchallenged forensic analysis accepted. Instrumentality test – nexus/proximity between property and offence; balance of probabilities suffices. Relief – order forfeiting property to State; vesting and sale by curator bonis; proceeds to Criminal Recovery Account subject to bondholder’s claim; costs awarded to applicant.
Western Cape Judgment 22 May 2003
Reported
Section 38 allows ex parte preservation applications but does not exclude rule nisi or interim orders; audi rights preserved.
* Prevention of Organised Crime Act, Chapter 6 — preservation of property orders (s38) — ex parte applications — rule nisi and interim preservation/seizure orders — audi alteram partem — section 34 fair hearing right — constitutional construction and reading-down — inherent judicial powers (s173) — justification under s36
Judgment 3 April 2003
 United States Judgment 29 January 2003
Reported
Whether a single eyewitness identification, despite parade irregularities and the accused's silence, proved guilt beyond reasonable doubt.
Corruption offence — identity of alleged extorting policeman — eyewitness identification; identification parade irregularities; parade form not proved; corroboration by name tag. Single‑witness identification — assessed holistically against parade defects. Accused’s failure to testify — uncontradicted prima facie case strengthens prosecution.
Judgment 26 September 2002
 United States Judgment 27 May 1999
 United States Judgment 1 June 1998
Reported
Reverse onus rules in sections 245 and 332(5) breach the constitutional presumption of innocence and are invalid.
Criminal procedure – reverse onus presumptions – sections 245 and 332(5) Criminal Procedure Act – presumption of innocence (s25(3)(c)) – limitation analysis under s33(1) – vicarious/criminal liability of company directors – severance and reading-down – interplay with s90 (exceptions/exemptions) of Act – retrospective effect to pending appeals/reviews
Judgment 6 March 1997