- Tribunal found Moltken Pitso Maake paid more than R1.1 million in bribes to protect his Sanlam franchise from oversight.
- Payments were made over 18 months and disguised as payments for Services, despite no legitimate work being performed.
- Tribunal dismissed Maake's challenge, finding he lacked the honesty and integrity required under the FAIS Act
More than R1.1 million was paid in 23 instalments over 18 months to buy protection from a senior Sanlam employee, secure the removal of a business partner, and shield a franchise from investigation. This sits at the centre of a Financial Services Tribunal judgment exposing an alleged bribery scheme inside the insurer's adviser network.
According to the Tribunal, Moltken Pitso Maake, who served as the authorised principal of Tebogo Ya Pitso Holdings (Pty) Ltd (TYP), admitted making 23 payments totalling R1 142 500 to former Sanlam portfolio manager Khuliso Mulaudzi between August 2023 and February 2025.
These included large transfers such as R270 000, R275 000, R200 000 and R100 000 paid directly into Mulaudzi's bank account with the reference 'Services'. Maake told investigators these payments were intended to secure Mulaudzi's help in removing his business partner and to provide ongoing protection so his franchise would not face investigation or termination by Sanlam. He also admitted that no actual business services or tangible benefits were provided in return.
The investigation, carried out by Bowmans, found that the payments were not supported by any legitimate services or deliverables. They appeared designed to secure improper influence over internal processes and shield TYP from oversight and corrective action, raising serious concerns about Maake's integrity and potential corruption.
Those findings ultimately led Sanlam Developing Markets Limited to debar Maake under the Financial Advisory and Intermediary Services Act. His attempt to overturn that decision was dismissed by the Financial Services Tribunal in a decision delivered on 3 August 2026 by a panel chaired by Judge Kgomo, with PR Long and A Saldulker concurring.
Whistleblower triggers wider investigation
The Tribunal heard that concerns about TYP emerged from two sources. The first was Maake himself, who disclosed the repeated protection payments to Mulaudzi. The second was a whistleblower who alleged advisers linked to the franchise were using the Easypay payment system to stop client policies from lapsing and avoid commission clawbacks.
Bowmans was appointed to investigate both matters. Investigators examined banking records, Easypay data, text messages and payment receipts, while interviewing Maake and other witnesses.
The Easypay investigation found that 58 percent of Easypay payments collected on TYP policies were below 30 percent of the required premium, resulting in underpayments of R1 856 862.90. Investigators also found messages instructing advisers to fix or save policies before they lapsed and multiple R50 payments made simultaneously at the same payment points. Maake denied instructing advisers to make the payments.
Debarment process challenged
Maake challenged his debarment on both procedural and substantive grounds. He argued that the process was unfair because no witnesses testified, he could not cross-examine investigators and Sanlam acted as the player and the referee at the same time. He also claimed there was insufficient evidence to justify his debarment and maintained he had been the victim of extortion by Mulaudzi.
The Tribunal rejected those complaints, finding Sanlam had complied fully with the Financial Advisory and Intermediary Services Act by providing written notice of its intention to debar him, supplying the investigation report and policies, inviting written submissions and allowing him to attend the debarment hearing with legal representation.
It went further than the section required and afforded the applicant an oral hearing in addition to the invitation to make written submissions.
The Tribunal found that the evidence against Maake rested largely on his own admissions. He voluntarily disclosed the payments, provided proof of payment and banking records, and admitted the purpose of the payments.
Tribunal finds adviser no longer fit and proper
Although the Easypay allegations formed part of the investigation, the Tribunal said it was unnecessary to decide them because the admitted payments alone justified Sanlam's decision.
The Tribunal emphasised that debarment is intended to protect the public rather than punish financial advisers. The Tribunal dismissed Maake's application for reconsideration, leaving Sanlam's debarment decision in force.
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