Regulatory Alerts2026-01-23
Circular to Exchange Offices No. 2026-02 of January 23, 2026
The Governor of the Central Bank of Tunisia issued Circular No. 2026-02 mandating exchange offices to implement robust internal vigilance and surveillance systems for combating money laundering, terrorist financing, and weapons of mass destruction proliferation. The circular requires manual exchangers to conduct enhanced due diligence on high-risk and politically exposed clients, screen transactions against UN sanctions lists, report suspicious activities via the goAML platform within strict timelines, and retain all relevant records for ten years. Non-compliance subjects exchange offices to disciplinary sanctions ranging from warnings and reprimands to authorization suspension or withdrawal, while good-faith reporters are shielded from civil and criminal liability.