As time goes on, the perspicacity that characterises the government’s Broad-based Black Economic Empowerment (BBBEE) policy and strategy becomes clearer as companies clamour to achieve the desired BEE status. This involves a kind of orchestrated self-regulation which relies on the power of cascade to sustain momentum. There are no legal penalties for those that do not comply. Indeed, it is a matter of choice. It was too much to expect that the BBBEE would be rolled out without bureaucratic obstacles, however. The audit process is not yet finalised and this has caused companies to be confused and be-wildered. As is so often the case, there are too many loopholes to be closed in order to prevent fraud and abuse. Typically, this requires a cumulative aggregation of procedural demands, for as each loophole is addressed, several others reveal their potential vulnerability.