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2019-01-01

Palestine Monetary Authority Circular No. 16/2019: Instructions on Politically Exposed Persons

The Palestine Monetary Authority issued Circular No. 16/2019 to enforce the National Committee for Combating Money Laundering and Terrorist Financing's Instructions No. 1 of 2018 regarding Politically Exposed Persons (PEPs). The directive mandates that all specialized lending institutions in Palestine implement strict risk-based due diligence, enhanced scrutiny, and senior management approval for relationships with PEPs and their associates. Banks are further required to submit quarterly Excel reports detailing PEP accounts and transactions to the AML-CFT department to ensure full regulatory compliance.

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Palestine Monetary Authority

PALESTINE MONETARY AUTHORITY

Circular No. (16/2019)

To all specialized lending institutions operating in Palestine Date: Sunday, January 13, 2019

Subject: Instructions on Politically Exposed Persons

Attached are the instructions of the National Committee for Combating Money Laundering and Terrorist Financing No. (1) of 2018, published in Official Gazette No. (149) regarding "Politically Exposed Persons," and therefore, we emphasize the necessity of full compliance with the provisions of the aforementioned instructions.

Supervision and Inspection Department Palestine Monetary Authority

Attachment: Instructions on Politically Exposed Persons. Copy: To the esteemed Financial Monitoring Unit.

Ramallah & Al-Bireh Governorate - Palestine P.O. Box 452 info@pma.ps | Fax: +970 2 2415310 | Tel: +970 2 2415251 Gaza - Palestine P.O. Box 4026 Fax: +970 8 2844487 | Tel: +970 8 2825292 www.pma.ps

Palestinian Documents

2018/11/28

No. (149)

Instructions No. (1) of 2018

On Politically Exposed Persons

The National Committee for Combating Money Laundering and Terrorist Financing, Based on the provisions of Law No. (20) of 2018 regarding the combating of money laundering and terrorist financing, and its amendments, particularly the provisions of Articles (6) and (14/20) thereof, and based on the powers delegated to us, and in pursuit of the public interest, Have issued the following instructions:

Article (1) Definitions

  1. The words and expressions contained in these instructions shall have the meanings assigned to them below, unless the context indicates otherwise:
    • The Law: Law No. (20) of 2015 regarding the combating of money laundering and terrorist financing, and its amendments.
    • The Committee: The National Committee for Combating Money Laundering and Terrorist Financing, established pursuant to the provisions of Article (19) of the Law.
    • The Unit: The Financial Monitoring Unit, established pursuant to the provisions of Article (23) of the Law.
    • Financial Institution: Any natural or legal person subject to the laws in force in the State of Palestine, whose profession or business is related to any of the activities shown in Table No. (1) attached to the Law, whether practiced for their own benefit or for the benefit of their clients.
    • Designated Non-F Businesses and Professions: The businesses and professions listed in Table No. (2) attached to the Law.
    • Client: The natural or legal person who has a business relationship with any of the financial institutions or any of the designated non-financial businesses and professions.
    • Politically Exposed Person: A person, their family members, and close associates who hold or have held, whether in Palestine or abroad, public political positions or senior functions, which include, for example, the categories stipulated in Article (3) of these instructions.
    • Trust: A legal relationship under which the settlor places funds under the control of a trustee for the benefit of a beneficiary or for a specific purpose, and those assets form assets independent of the trustee's property, and the right to the trustee's assets remains in the name of the trustee or in the name of another person on behalf of the settlor.
    • Legal Arrangement: The legal relationship that arises between several parties pursuant to an agreement, including trusts or any similar legal arrangements.

Article (2) Scope of Application

The provisions of these instructions apply to financial institutions and designated non-financial businesses and professions, and their branches operating abroad, to the extent permitted by the laws and regulations in force in the countries where those branches operate.

Article (3) Categories of Politically Exposed Persons

The categories of politically exposed persons are graded within the following classification:

  1. Public political positions or senior functions, including, for example:

    • a. The Head of State, their advisors, and the heads of institutions affiliated with the Presidency.
    • b. The Prime Minister and members of the Council of Ministers, and those in their stead.
    • c. Deputy Ministers, and those in their stead.
    • d. Directors and General Managers in government and public positions, and those in their stead.
    • e. Directors and heads of public bodies and institutions, and those in their stead.
    • f. The Head and members of the Legislative Council.
    • g. The Head and members of the Judicial Council.
    • h. Judges of courts of all degrees.
    • i. Members of the Public Prosecution.
    • j. Directors and heads of security agencies, and officials therein, and directors of their administrations and departments in general administrations and governorates.
    • k. Directors and heads of the Palestinian General Security, and officials therein, and directors of administrations and departments of General Security in general administrations and governorates.
    • l. Leaders and senior ranks in political parties and Palestinian factions, and those with important positions in these parties and factions.

  2. Heads, deputies, and directors of institutions or charitable associations and local and foreign non-governmental bodies, and members of boards of directors.

  3. Ambassadors, consuls, and members of the diplomatic corps.

Article (4) Risk-Based Approach

Financial institutions and designated non-financial businesses and professions are committed to identifying and understanding risks, assessing them, and applying the risk-based approach in due diligence procedures with politically exposed clients stipulated in Article (6) of the Law, and putting in place the necessary policies, strategies, and measures for that purpose.

Article (5) Enhanced Due Diligence

In addition to the due diligence procedures stipulated in Article (6) of the Law, financial institutions and designated non-financial businesses and professions must take the following measures regarding politically exposed persons:

  1. Establishing appropriate systems and policies for risk management to determine whether the client or beneficial owner is a politically exposed person, whether local or foreign, and their family members and close associates.
  2. Obtaining senior management approval before establishing a business relationship or continuing a business relationship with them.
  3. Taking reasonable measures to determine the source of wealth and funds for politically exposed persons, based on legally certified data proving the source.
  4. Conducting continuous monitoring of the business relationship, verifying its integrity, and its proportionality to the financial activity, and exercising special care in their dealings, and the transactions carried out with any of them, and the purpose of those transactions, and recording the results in special records.

Article (6) Insurance Policy Risks

Financial institutions and designated non-financial businesses and professions must put in place and take the necessary measures to determine whether the politically exposed person is a beneficial owner of a life insurance policy, and if so, they must do the following:

  1. Inform senior management before paying compensation from life insurance proceeds, and conduct a detailed review of the business relationship.
  2. Consider reporting to the Unit on the reporting form approved by the Committee for this purpose.

Article (7) Repeal

  1. Instructions No. (1) of 2014 regarding Politically Exposed Persons are repealed.
  2. Everything inconsistent with the provisions of these instructions is repealed.

Article (8) Entry into Force and Implementation

All competent authorities shall, each within their respective competence, implement the provisions of these instructions, and they shall be effective from the date of their publication in the Official Gazette.

Issued in the city of Ramallah on: 1/11/2018 AD Corresponding to: 23 Safar 1440 AH

The National Committee for Combating Money Laundering and Terrorist Financing

Reference No.: 149-11-2018 Legislation and Legislation Office 122

Palestine Monetary Authority

PALESTINE MONETARY AUTHORITY

Circular (2018/209)

Wednesday, September 19, 2018 To all banks operating in Palestine

Subject: Politically Exposed Persons (PEPs)

In order to enhance the environment for combating money laundering and terrorist financing in Palestine in accordance with the provisions of Law No. (20) of 2015 regarding "combating money laundering and terrorist financing" and the instructions issued by the National Committee pursuant thereto, and in accordance with international standards and practices related to Politically Exposed Persons (PEPs), we emphasize the following:

  1. Full compliance with the provisions of Law No. (20) of 2015 and the instructions issued pursuant thereto regarding the management of accounts of these persons and their close associates.
  2. Providing us with information on what the bank has done regarding the following:
    • a. The extent to which approved policies and work procedures are provided regarding enhancing identification and verification procedures for these persons and the source of wealth and funds, and exercising enhanced and strict due diligence on financial transactions executed on their behalf.
    • b. The extent to which the banking system and the bank's anti-money laundering and counter-terrorist financing systems are prepared to enable:
      • Determining the degree of risk of these persons and classifying them within the category of "Politically Exposed Clients and their close associates," providing us with the names of clients classified within that category.
      • Issuing alerts when executing financial transactions on behalf of these persons.

1

Ramallah - Palestine P.O. Box 452 | Tel: +970 2 2415250 | Fax: +970 2 2415310 Gaza - Palestine P.O. Box 4026 | Tel: +970 8 2825292 | Fax: +970 8 2844487 Email: info@pma.ps www.pma.ps

- Providing and extracting supervisory reports on the supervision of accounts of these persons and the financial transactions executed on their behalf, specifying the types and contents of those reports.

- Extracting a list of Politically Exposed Persons and their close associates, showing the names, account numbers, personal ID numbers, risk degree, and reason for inclusion in the client category.

  1. Providing us with a periodic (quarterly) report in Excel file format of Politically Exposed Persons and their close associates and the total transactions executed on their behalf, to be provided starting from the end of the third quarter of the current year on a quarterly basis, according to the data specified in the attached statement, with the list to be sent no later than five working days after the end of each quarter to the following email address of the Anti-Money Laundering and Counter-Terrorist Financing Department: AML-CFT@PMA.PS.

  2. Banks must ensure compliance with the National Committee's instructions regarding this, by providing and updating policies, procedures, and the banking system, and providing us with an action plan to rectify the situation by the end of the current year at the latest.

Supervision and Inspection Department Palestine Monetary Authority

Attachment: List of Politically Exposed Persons and their close associates.

2

Ramallah - Palestine P.O. Box 452 | Tel: +970 2 2415250 | Fax: +970 2 2415310 Gaza - Palestine P.O. Box 4026 | Tel: +970 8 2825292 | Fax: +970 8 2844487 Email: info@pma.ps www.pma.ps

Form for Sending Data of Politically Exposed Persons (PEPs) and their close associates

| Serial No. | Client Name | Relationship Type | Account Number | Account Number (if in foreign currency) | Account Type | Currency Type | ID Number | Passport Number | Institution Name | Institution No. | Director Name | Director No. | Agent Name | Agent No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | Director Name | Director No. | 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