General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Bill: Consideration of Comments

Meeting report

The Chairperson welcomed the Select Committee on Finance, National Treasury (NT), and stakeholders to a meeting to consider the comments on the General Laws (Anti-Money Laundering and Combatting Terrorism Financing) Amendment Bill (GLAB).

The Chairperson told the Committee that there was an urgent meeting being called by the programming committee to allow for a special sitting in Parliament on 13 December 2022 to consider this Bill and the Justice Bill on terrorism, both relating to SA’s grey-listing.

Cause for Justice issued an apology for their absence from the meeting.

The Chairperson encouraged stakeholders to raise their issues to NT during this meeting.

Table of Comments on the General Laws Amendment Bill

The Chairperson alerted the Committee to the issues at hand.

These issues included the short period for public consultations, the constitutionality of amendments to the Non-Profit Organisation (NPO) Act, alignment of the NPO Amendment Bill with the GLAB, capacity of the Department of Social Development (DSD) to accommodate the NPO directorate, NPO’s reporting to institutions, compulsory NPO registration and the disclosure of access to beneficial ownership information.

See document attached for full record of comments

The Chairperson said the issues of amendments to the NPO Act and alignment of the NPO Amendment Bill to the GLAB have already been resolved. He asked the Committee and stakeholders whether there were any comments on public participation.

Discussion

COSATU

Mr Matthew Parks, Parliamentary Coordinator, Congress of South African Trade Unions (COSATU), said, on public hearings, that Parliament did what it was able to given the time constraints. He appreciated that the Standing Committee on Finance incorporated some amendments in response to civil society. He said that this afforded stakeholders with greater confidence.

On the constitutionality of the amendments to the NPO Act, the Chairperson felt the matter was discussed in detail in the meeting prior. He said that Parliament had also issued their independent opinion on the matter. He considered the matter resolved as there were no Committee or stakeholder comments.

Ms Jeannine Bednar-Giyose, Director: Fiscal and Intergovernmental Legislation, NT, went through the remainder of the comments on the General Laws (Anti-Money Laundering and Combatting Terrorism Financing) Amendment Bill.

Alignment of the NPO Amendment Bill with the GLAB

On the alignment of the NPO Amendment Bill with the GLAB, NT said that the stakeholders asked for clarity on the relationship between the two envisaged pieces of legislation and how they are expected to be interpreted in relation to each other.

NT responded that the NPO Amendment Bill had been in an ongoing process by the DSD to address issues in the legislation which needed to be strengthened and updated. Considering the Financial Action Task Force (FATF) recommendations, some urgent amendments, in relation to NPOs, were noted in the NPO Act.

It was determined that the most efficient way to address these deficiencies in the GLAB was in consultation with the DSD. NT noted some differences in provisions between the two Bills, however the NPO Bill will be further refined as it was only a draft bill. Once the Bill is tabled it is predicted to align with what was already enacted in relation to the Bill.

Discussion

The Chairperson said that conflicts between bills do not always occur in practice; the issues are ironed out with the other departments and ministries. He asked what guarantees were available to the Committee to ensure that the version of the Bill brought before Parliament is aligned with the Bill being put before the House in the next few weeks.

He used the example of issues conflicting at a municipal level. He remembered when the Structures Act and Municipal Systems Act conflicted with the Municipal Finance Management Act (MFMA). The matter was later sorted out by NT in the MFMA. In light of this, he asked what process had been thus far with the DSD.

Ms Bednar-Giyose said that the work done with the DSD in processing the Bill had been greatly appreciated. NT indicated to the DSD that they would be happy to engage with them further on the development and finalisation of the Bill. NT said they were also happy to engage with the DSD during the finalisation of the GLAB, in relation to the regulations needing to be developed and all other relevant implementation aspects.

The Chairperson asked the Committee Secretary to report this commitment made in the report. He reminded the Committee that they had a presentation from the NPO working group regarding the issues mentioned. He asked whether there was an NPO representative to speak on these issues in the meeting.

NPO Working Group

Ms Jenny Wright, Representative, NPO Working Group, noted that many engagements on the NPO Amendment Bill which had not reflected in the latest version put out for comment. She said that the changes were not being witnessed as quickly as before.

She further noted the large amounts of work required commenting on these issues and felt frustrated as this was not reflected. She shared the concerns that either the amendments would not be reflected or that there would be a massive delay of alignment on the NPO Amendment Bill. The NPO Working Group also found the commitment made to align the two Bills of particular importance.

Helen Suzman Foundation

Ms Chelsea Ramsden, Senior Legal Researcher, Helen Suzman Foundation, said that they were happy with the responses provided and the procedure set out to deal with the inconsistencies of the Bills.

Mr D Ryder (DA, Gauteng) said that the alignment was imperative to achieve. He noted that would become issues when processing the Bills, using the South African Post Bank Bill as an example. He said this pointed to questions asked during public participation which concerned the capacity of the DSD to deal with the volume of tasks at hand.

He felt that there needs to be an alignment between expectations and the capacity of the DSD, as well as considering the expectations of the NPOs. He said that until this occurred, the Bill would be impossible to implement. He said that his biggest issue with the GLAB was that it may be placing responsibilities on the DSD that they are unequipped to deal with. 

He felt that this could also be setting the country up for failure. This was because he felt that the wrong message would be signalled to the FATF, especially considering the backlogs the DSD experiences. He reiterated that alignment was important because if things were not budgeted for and measured, they would not get done. Based on this, he felt it was important to receive confirmation from the DSD that they had the requisite capacity.

Ms Ramsden said that currently, the NPO’s directorate capacity is the primary concern of civil society. She said that the systems did not allow people involved in administration to search for ID numbers of leaders, directors and fiduciaries of NPOs.

She reported on clients who complained of online application systems collapsing or submission emails on reporting that were not sent due to full email inboxes. She said this was a constitutional matter and a matter of ensuring administrative justice.

She felt that if the system could not support the sector, the purpose of the Bill would not be achieved nor would the intended problems be fixed. She said that it was frustrating for the sector to alert government of these issues and under-resourcing, while the required resources were unavailable to allow the 250 000 NPOs who were looking to register. These resources included system upgrades and increased numbers of staff.

NPO Working Group

Ms Wright shared concerns regarding insufficient systems and staffing numbers to have the capacity to execute what was being discussed in the Bill. On the suggestion of the Financial Intelligence Centre (FIC) monitoring the financial aspect of the Bill, she said that this was not seen as a viable solution.

However, she felt there was a misconception that it was monitoring registered NPO compliance. She said that if one department and system were going to assist in this role, it was crucial that these systems had the required security and stability. She said it must also be able to correctly search and flag matters.

She said that these matters were not required before of the systems. The NPO working group felt it was important to have a plan for acquiring funding and staff, rather than a verbal commitment. She acknowledged the amount of time this would take to plan and broadly consult the relevant persons and expertise.

The NPO working group made submissions recommending specific lawyers, auditors and people with forensic financial skills to work in the Department on this. She said it was important to create a plan and get resources as they hoped for a thriving sector. The NPO working group said that the plan must be cognisant of potential future expansion needs to be able to interact with the other relevant systems.

Ms Wright questioned how the Department would be able to handle this shift given that they were already struggling. The NPO Working Group highlighted the importance of consultation to ensure a constructive process.

Helen Suzman Foundation

Mr Anton van Dalsen, Counsellor, Helen Suzman Foundation, said that they would like the DSD to keep the registration requirements as a regulatory or supervisory department. The Helen Suzman Foundation thought the FIC should deal with the investigative aspects of suspicious foreign financial transactions. This would fall under the FIC Act with these NPOs categorised as reporting institutions.

He said that this suggestion was based on the fact that the DSD does not have experience in this area and lacks the financial resources to start up an efficient mechanism from scratch.

Responses

Department of Social Development

Ms Mpho Mngxitama, Acting Chief Director: NPO Directorate, National DSD, agreed that there were issues of capacity for the directorate. She said that the DSD had, thus far, engaged with NT to gain perspective on the matter.

She agreed that increased human resources and greater access to technology would help to administer the new scope of work resulting from the amendments. The DSD said that a case was made to the Director-General to overhaul the NPO system. She acknowledged that the current system had problems due to its age.

The DSD wanted the new system to achieve these new areas of work and integrate with other regulators, such as the Companies and Intellectual Property Commission (CIPC), the South African Revenue Service (SARS) and banks. The DSD believed that working with the FIC and NT in the development process must identify the key development areas in the system that would examine high-risk NPOs on the radar needing consistent monitoring.

On human resources, the DSD felt there must be a change in how business is conducted amongst the current staff. She said this would require training and developing new technical competencies in data, financial analysis, and business process engineering.

The DSD said business process engineering must be linked to other law enforcement agencies and critical stakeholders. She said this would assist the DSD in reporting certain issues to the relevant agencies and stakeholders within a specific timeline.

The DSD hoped to make way with this work as soon as possible. The DSD said they engaged with NT to develop an implementation plan for the new amendments. This included a budget plan to get an idea of costs and areas needing improvement.

The DSD acknowledged that, even if the skills were not present, some departments would have the required skills. The DSD said that they would negotiate deployment of these key skills to assist the Department with immediate activities, while working towards a long-term plan.

On aligning the two pieces of legislation, the DSD said they engaged with the NT Legal Unit to investigate any duplication between them. She said that the FIC and NT offered their support by offering to sit together at the beginning of 2023 to ensure alignment.

On the lack of changes implemented, the DSD said that public comments were republished upon a request for an extension. The DSD captured all comments from the sector and said that the next step was to consolidate these comments into one key document for the legal department to incorporate these changes.

Once the comments are consolidated before the end of the year, the NPO Amendment Bill will be reworked and steps will be made to ensure alignment. The DSD hoped that by the end of the financial year, the legislation would be completed and introduced to Parliament to undergo parliamentary processes.

National Treasury

Ms Bednar-Giyose said that NT reaffirmed their commitment to working with the DSD on further revision of the Bill. NT also committed to looking into further aspects to ensure effective implementation of the legislation. NT said that this was a serious process because there would be future assessments of the success of the implementation of the legislation, including by FATF.

NT noted the inputs made in the meeting and said they would work with the DSD to consider this to ensure effective implementation. Ms Bednar-Giyose asked the FIC to comment on their role going forward concerning investigating issues identified in relation to NPOs.

Financial Intelligence Centre

Mr Pieter Smit, Executive Manager, FIC, responded to the Helen Suzman Foundation’s comment. He said that the method they were exploring was very similar to the one mentioned by the Foundation. The FIC said that the structure of supervision and regulation of the NPOs categorised should have assurance that they are subject to supervision and must comply with basic governance principles through compliance with the NPO Act.

The FIC said that their role would be to make use of the information at their disposal received through reporting and available information. The FIC said that this information held by unregistered NPOs could already be accessed since it was controlled by a public authority.

FIC said that applying their analysis of the information to identify abuse of NPOs requiring further investigation, they would bring this to the attention of investigating and intelligence authorities in the country. The FIC said that they would work with them to find follow-ups to the leads generated.

The FIC said this approach would not benefit from having NPOs classified as reporting institutions. FIC explained that the information likely received from the NPOs from reporting large cash transactions would not contribute significantly to the information that the FIC has available and work within the analysis processes.

The FIC felt it would be more efficient to access the proper accounting records and financial management within NPOs, rather than relying on NPOs to report to FIC when they receive or disperse large amounts of cash.

The FIC explained that the activity of receiving or dispensing cash within our borders was not a concern in the context of NPOs being used or exploited for raising or dispersing funds for terrorist organisations. FIC said that they were working towards providing the legal basis for these amendments currently before the Committee. 

The FIC acknowledged that future work would have to be done for effective implementation. FIC agreed that South Africa must ensure that the system works effectively in the way envisaged by the amendments. The FIC said that this would offer assurance and credibility for the NPO sector to continue functioning, raising funds and working without being subjected to suspicion when engaging with local and foreign financial institutions.

On capacity constraints, the FIC acknowledged the concerns with the current capacity situation and felt it must receive very serious attention in implementing these amendments. The FIC felt there was no alternative solution as the same core issues, of capacity and resourcing, would remain.

Mr E Njadu (ANC, Western Cape) appreciated the steps taken by the DSD thus far and going forward. He felt it was important to ensure that the DSD was being strengthened. On integration, he said that it was key that the Department be efficient. Regarding human resources, he asked what the position of the Department was on filling current vacancies.

Ms Mngxitama confirmed that there were vacancies. The DSD said that they had discussed with HR that the main concern was the budget to allow for recruiting. This was as the budget for compensation had been reduced.

The DSD said that they were negotiating to ensure that at least the critical posts were advertised to allow for recruiting to begin. The DSD said that their priority was to fill the vacant funded posts. They said that they were negotiating with HR to find available funds and they were hoping for NT to assist them in this regard.

The Chairperson said to NT that they could not expect the DSD to do all of this, while not prioritising the funding for it.

Ms Bednar-Giyose said that NT noted concerns relating to capacity. NT said that the Bill had a new subsection 2 which was going to be inserted into Section 5 of the Bill that would enable the directorate to enter into arrangements for cooperation, coordination and other arrangements with organs of state.

NT said that this would enable the directorate to perform its functions in terms of the legislation. NT said that this provision was envisaged to assist the DSD in engaging with other departments regarding support to facilitate certain functions.

She said these arrangements could be investigated and potentially entered into as a mechanism to help support the directorate and ensure that the functions are effectively and properly performed.

The Chairperson said it was unanimously agreed upon that there were huge capacity and resource challenges to implementing this Bill. He said that this was the reason FATF grey-listed South Africa until dramatic changes were made. He said that FATF viewed the state as weak in implementing FATF regulations and standards.

He used the example of the Department of Home Affairs functioning poorly to exemplify that, despite this, the functions were not outsourced to other entities. He asked stakeholders what choice there is, apart from Members of Parliament and civil society putting pressure on the Minister and the Department to improve.

The Chairperson said, on alternatives offered, that he thought the FIC could not do this. He felt that civil society was conflating general frustrations about NPO registration in a broad sense with issues raised in the Bill regarding the 10 000 NPOs required to register in terms of it.

He felt that they all shared concerns on budgeting capacity and suggested that the DSD challenges must be fixed, rather than finding alternative remedies. Responding to the Helen Suzman Foundation, he said that he struggled to follow their comment. He asked if the Foundation had a response regarding that the NPO was able to perform their functions without taking over the role of the DSD.

On the implementation plan, the Chairperson said that Bills must be considered bearing in mind what the memorandum states. He explained that it would provide a brief programme of action regarding the capacity required to implement the Bill.

The Chairperson reminded civil society that there is a distinction between active public participation and that in practice decisions are made in alignment with their own views. He said that civil society could not co-govern, however they had the right to demand to be heard.

He said he felt optimistic regarding the alignment of the two Bills. He said that they could not impose on the DSD and its Minister, although they could engage with Members of the Committee. He said that the Committee would monitor the alignment.

The Chairperson said that, ultimately, the Ministers were accountable for how late a Bill was published. He said it was important that they implement what was intended by the Bill. He said that he felt one of the reasons FATF grey-listed South Africa was due to the HAWKS, delayed corruption case processing and the justice system being immensely slow. He said this applied great pressure for these Bills to execute their plans.

He appreciated the inputs of civil society in participating in these matters and explained the great influence that it had. He reminded civil society that they were not the ultimate decision makers. He suggested that NT, the DSD and the NGOs engage on these submissions to answer some issues which had already been resolved to avoid repetition.

Mr van Dalsen said that the comments from the FIC were welcomed and felt they were on the same page regarding the principles at hand.

NGOLaw

Ms Nicole Copely, NGOLaw, said that while the NPO directorate remained a sub-department in the DSD, it would always be hampered and underfunded. She said that the NPO directorate should be allowed to appoint and dismiss their own people and issue their own communications to be effective.

NGOLaw said that there was a history of the loss of credibility of the NPO register due to the NPO directorate not being able to fulfil its own statutory duties and clean up the register as it was under the Minister of Social Development.

She said that it went beyond capacity concerns. She said that the scope of the non-profit sector involved education, environment, health, safety, and religious and cultural issues beyond social work. NGOLaw felt this was important reasoning for relocating the NPO directorate or an independent NPO directorate outside of the DSD.

She recognised that some of the timelines mentioned seemed soon. However, she also recognised that the clean-up process had been initiated many times, and that there were pre-existing plans and dates in place. NGOLaw felt that the clean-up was necessary before the new work was implemented.

The Chairperson asked where the NPO directorate would relocate.

Ms Copely said that she felt the best option was to become an independent institution that reports directly. She said that this was how it operated in the United Kingdom and should be looked into in South Africa. She recognised that the Bill would not accomplish this.

The Chairperson said that what was being asked for required a greater degree of sophistication and capacity. He felt that this was not practical. He said that relocation or independence would not resolve issues of capacity constraints.

Ms Copely said that she felt that this approach would increase budget allocation and the directorate’s ability to make its own decisions and fulfil its mandate.

The Chairperson understood that NGOLaw was petitioning for the NPO directorate to have independent decision-making powers and budget allowances. He asked who would appoint the director of the directorate under this independent framework.

Ms Copely believed that mechanisms would be put in place for this, which would require further discussion. She affirmed her stance that the NPO directorate should not be limited due to residing within the DSD.

The Chairperson said that the Committee could add it to the recommendations to refer it to the relevant issue. He felt that removing the NPO directorate would not resolve the capacity issues at hand.

Ms Mngxitama responded that the DSD understood where the sector was coming from regarding independence of the directorate. She said this would require certain bureaucratic processes in place and was a long-term plan. She agreed with the Chairperson’s suggestion and recognised that the appropriate processes must be followed to mandate being envisaged for the good of service delivery and involvement of the sector.

The Chairperson suggested that a middle ground could be found. He said that administratively, sometimes alternative remedies could cause more challenges on an already burdened system. He felt the idea sounded good in principle but may not work practically.

Beneficial Ownership

Ms Bednar-Giyose said that various stakeholders submitted definitions of beneficial ownership in terms of the Trust Property Control Act, Companies Act and Financial Sector Regulation Act. NT said this was thoroughly considered and significant changes were made to the definitions, specifically the Trust Property Control Act and Companies Act.

The definitions were crafted to appropriately interpret and be implemented in the context of the specific legislation. NT submitted that the revised definitions contained in the GLAB had been significantly revised and hoped that they would be appropriately implemented to address beneficial ownership relating to trusts, companies and financial institutions.

Discussion

COSATU

Mr Parks appreciated the amendments effected on beneficial ownership. COSATU felt their issues regarding the definitions had been addressed in the revised beneficial ownership definitions. COSATU felt that the Companies Amendment Bill would synchronise with the GLAB.

On public access to information, COSATU said they were concerned with the practicalities of this and enforceability. COSATU appreciated the positive commitments made by NT to ensure that sufficient capacity and training occur.

COSATU said that once the Bill has been enacted, they would engage with the regulations to enhance public access to information. He also appreciated the report from NT regarding issues of penalties. COSATU felt pleased with the Bill and agreed with the Chairperson that the Bill could address not all issues.

On capacitating the DSD, COSATU said that this was a fundamental issue. He felt that there could be no shortcut to this matter. He acknowledged the issues stemming from capacity constraints. This included long queues to receive Social Relief of Distress (SRD) Grants and compensation funds.

The Chairperson urged Mr Parks to also put pressure on the Ministers to ensure that the DSD is capacitated to avoid severe consequences. He asked NT why it had to be raised that the register would have to be as public as possible.

Mr Ryder said that the issue of beneficial ownership was important. He asked NT what the degree was of cooperation with the South African Reserve Bank (SARB), Prudential Authority (PA), FIC, Financial Sector Conduct Authority (FSCA), the Deeds Office, Department of Home Affairs, DSD and CIPC.

He asked whether there were service level agreements between all role players in the matter.

Responses

Mr Vukile Davidson, Chief Director: Financial Sector Policy, NT, said cooperation was critical for an effective outcome. He said that this occurred on three levels. He explained that the NT Director-General chairs the interdepartmental committee which identifies potential bottlenecks, further refinements, and evaluates the effectiveness of the outcomes and law.

NT said that the second critical pillar was the integration of information technology. He said this involved having systems in different departments communicating with one another and having a consolidated beneficial ownership registry accessible to law enforcement and other stakeholders.

The final level involved cooperation through creating and implementing various memoranda of understanding through the entities outlined. Mr Davidson said this was to ensure cooperation amongst agencies listed and a coherent system of beneficial ownership. He asked FIC to provide further information on the pillars of cooperation.

FIC

Mr Smit confirmed that the FIC had a memorandum of understanding with a number of government agencies. The FIC said that they had the memoranda where it was needed for the governance of access to information. He listed entities involved such as CIPC and the Department of Justice.

The FIC said that the interdepartmental committee is still working towards harmonising access across agencies. He clarified that DSD, FIC, PA, FSCA, Department of Justice and CIPC were all members of the interdepartmental committee.

Mr Ryder accepted the responses from NT and the FIC.

The Chairperson said that issues, such as the proposal to amend the FIC, compulsory registration of NPOs and disclosure of access, had been resolved. He asked NT what the outstanding policy issues were that needed to be addressed.

Ms Bednar-Giyose said that the main issues identified in the submissions were resolved. NT noted an issue raised to the Standing Committee on Finance relating to the Companies Act which was included in the latest amended version of the Bill.

The Chairperson appreciated the comprehensive table of comments.

Mr Parks said, on public access to information, that COSATU was happy with the regulatory provisions from NT. He noted examples of departments failing to communicate with each other on shared responsibilities during COVID.

COSATU noted resistance to the Government Technical Advisory Centre assisting in identifying gaps in the Bill. He said that, at times, this gatekeeping and resistance has been due to corrupt affairs. He made an example of the previous DSD Minister saying that the sexual offenders registry was live and populated while inaccurate. He said that these kinds of matters should not be taken lightly.

COSATU said that resources should be readily available without Parliament asking for them, given the background departments failing or refusing to respond concerning PPE procurement. He suggested that a website be available to check the work being done and ensure transparency, which is critical in combatting corruption.

The Chairperson said there must be openness and transparency within the constitutional limits. He said that this would accelerate service delivery and development. He said this did not mean full transparency could always be granted. He said that he doubted the Minister would have explicitly lied, regarding the sexual offenders registry.

He said that a middle ground should be reached between transparency and a general obduracy of the state and state departments about transparency.

The Chairperson asked the NPOs whether there were any other policy issues that needed to be discussed.

Ms Wright appreciated the time afforded to submit comments and pledged their support to the Committee to implement the Bill successfully. On capacity, she said that she looked forward to hearing concrete ways in which this issue would be addressed.

The Chairperson said that the NPO Working Group must summarise the key points of the recommendation plan. He asked whether they wanted to highlight anything from their action plan.

Ms Wright said that the action plan included practical steps and timelines. She felt that the timeframes gave a sense of when the biggest impact the soonest within available resources. The NPO working group suggested that NPO certificates be sent electronically as e-certificates. This was in response to the current problem where NPOs were registering, although there were delays in receiving certificates.

On cleaning up and updating the register, she said that this was something that the NPO directorate had been trying to do for a while. She said that the NPO directorate had lost credibility as they were not able to keep up with this as they were required to. She said that prioritising this would allow things to go more smoothly on the ground and during NPO registration.

On stability issues, she said that looking at short-term solutions to instability was important. She explained that when NPOs tried to upload their documents and report to fulfil their obligations, the system was unstable and would work on occasion.

On staffing capacity, the NGO Working Group suggested lawyers, auditors and people in financial education assist in providing the needed skill sets. Regarding security, she emphasised the importance of access and stability.

Finally, the NGO Working Group encouraged NT to consider the future when amending the Bill. She suggested that the new system include future improvements and has the interoperability of the systems factored in from the beginning. She said that this would allow for data to be searched and classified and ensure financial oversight to prevent money laundering and financial terrorism.

Ms Ramsden thanked the Committee for allowing them to make suggestions and addressing their concerns.

The Chairperson asked the DSD if they were going to respond in the meeting or at a later point.

Ms Mngxitama said the DSD would process the submissions before responding in the upcoming meeting.

The Chairperson encouraged stakeholder inputs, though he emphasised that not all inputs would become affected in the Bill. On stakeholders providing specific dates of compliance, such as February 2023, were at times unrealistic. He said that the DSD would be consulted on determining their own dates to ensure that the Bill is implemented quickly, within the available resources.

He referred this report to the Select Committee on Social Development and their Department’s Director-General. He encouraged the Committee to craft their responses before the upcoming meeting on Thursday.

The Chairperson asked whether the clause-by-clause treatment of the Bill should be conducted or postponed to the upcoming meeting.

Mr Njadu suggested that the item be tabled for the agenda of the upcoming meeting due to time constraints.

Mr Ryder agreed that time did not permit this to occur in the current meeting.

The Chairperson agreed with the suggestions of the Committee and alerted stakeholders that they also had until Thursday evening to provide the Committee with submissions in one final sitting on the matter.

Mr S Du Toit (FF+, North West) asked what time the meeting on Thursday would be. He said this bearing in mind that flights would have to be booked at the last minute to attend.

The Chairperson said that the Committee Secretary would be in contact with the Committee to see who is available when. He said that it was not necessary for the Committee to meet every day on the matter as most issues had been repeated or resolved.

He suggested that the GLAB aspects in question be reviewed after an 18 month period. He said that it was unrealistic to do this assessment after a year. He felt this structure also complimented the timelines and upcoming tasks held by the Committee.

Mr Ryder said that he was not available on Thursday.

The Chairperson suggested the following Wednesday after 6pm as an alternative time.

Ms Wright said that the NPO Working Group had no new issues, however they said that they wanted to appear in the meeting to support the work of the Committee.

The Chairperson noted how the upcoming parliamentary processes of the Bill would occur. 

The Chairperson thanked all in attendance.

The meeting was adjourned.