Circular to Exchange Offices No. 2026-02 of January 23, 2026

Tunis, January 23, 2026. CIRCULAR TO EXCHANGE OFFICES No. 2026-02 Subject: Obligations of exchange offices regarding the fight against money laundering, terrorist financing, and proliferation of weapons of mass destruction.

The Governor of the Central Bank of Tunisia, Having regard to Organic Law No. 2015-26 of August 7, 2015, on the fight against terrorism and repression of money laundering as amended and supplemented by Organic Law No. 2019-9 of January 23, 2019; Having regard to Law No. 76-18 of January 21, 1976, on the revision and codification of foreign exchange legislation governing relations between Tunisia and foreign countries; Having regard to Law No. 2014-54 of August 19, 2014, on supplementary finance law for 2014 and notably its Article 54; Having regard to Law No. 2016-35 of April 25, 2016, fixing the status of the Central Bank of Tunisia; Having regard to Law No. 2016-48 of July 11, 2016, on banks and financial institutions; Having regard to Law No. 2018-52 of October 29, 2018, on the National Business Register; Having regard to Decree-Law No. 2011-87 of September 24, 2011, on the organization of political parties; Having regard to Decree-Law No. 2011-88 of September 24, 2011, on the organization of associations; Having regard to Government Decree No. 2016-1098 of August 15, 2016, fixing the organization of the Tunisian Financial Analysis Commission; Having regard to Government Decree No. 2017-1366 of December 25, 2017, fixing the minimum threshold for bank guarantee and candidacy conditions for exercising manual exchange activity by creating an exchange office, as amended by Government Decree No. 2018-593 of July 17, 2018; Having regard to Government Decree No. 2019-54 of January 21, 2019, fixing criteria and procedures for identifying beneficial owners; Having regard to Government Decree No. 2019-419 of May 17, 2019, fixing procedures for implementing resolutions adopted by competent UN bodies related to the repression of terrorist financing and proliferation of weapons of mass destruction, as amended and supplemented by Government Decree No. 2019-457 of May 31, 2019; Having regard to the Minister of Finance Order of July 24, 2019, amending the March 1, 2016 order fixing amounts provided in Articles 100, 107, 108, 114 and 140 of Law No. 2015-26 of August 7, 2015 on the fight against terrorism and repression of money laundering; Having regard to Circular No. 2018-07 of July 30, 2018 of the Central Bank of Tunisia on exercising manual exchange activity by natural persons through opening exchange offices, as amended by Circular No. 2019-07 of October 14, 2019; Having regard to Decision No. 2017-02 of March 2, 2017 of the Tunisian Financial Analysis Commission on guiding principles for financial professions regarding detection and reporting of suspicious transactions; Having regard to Decision No. 2017-03 of March 2, 2017 of the Tunisian Financial Analysis Commission on beneficial owners, as amended by Decision No. 2018-10 of June 8, 2018; Having regard to Decision No. 2024-01 of June 27, 2024 of the Tunisian Financial Analysis Commission on guiding principles regarding reporting of suspicious transactions; Having regard to Opinion No. 2026-2 of January 23, 2026 of the Compliance Control Committee, as provided by Article 42 of Law No. 2016-35 of April 25, 2016 fixing the status of the Central Bank of Tunisia. Decides:

Chapter I: Definitions Article 1 For the purposes of this circular, the following terms apply: Exchange office: A natural person authorized by the Central Bank of Tunisia to exercise manual exchange activity in accordance with Circular No. 2018-07 of July 30, 2018 on exercising manual exchange activity by natural persons for opening exchange offices. "Manual exchanger": Any natural person who exercises manual exchange activity as the owner of the office or as an employee/collaborator. Client: Any person receiving services from the exchange office, either within a business relationship or occasionally. Regular client: A client who regularly conducts manual exchange operations with an exchange office. Occasional client: A transient client who does not regularly conduct manual exchange operations with the exchange office. Beneficial owner: Any natural person who ultimately owns or exercises effective control, directly or indirectly, over the client or the natural person on whose behalf a manual exchange operation is carried out. The foreign and national politically exposed persons (PEPs): Persons who have held or currently hold important public offices in Tunisia or abroad, including:

• Head of State, Head of Government or government member,
• Governors,
• Members of parliament, national, regional and local elected officials,
• Members of a constitutional court or high jurisdiction,
• Members of a constitutional body,
• Senior military officers,
• Ambassadors, chargés d'affaires or consuls,
• Members of governing bodies or boards of control and regulatory authorities, as well as their top executives,
• Members of administrative, management or supervisory bodies of public entities or companies,
• Members of governing bodies or boards of international institutions created by treaty, or top executives of their representations,
• Senior political party officials,
• Members of governing bodies of trade union or employer organizations. This definition includes close relatives up to at least the first degree and persons having a link with them.

Business relationship: Any link between the manual exchanger and the client whereby the latter regularly or occasionally benefits from manual exchange services through multiple operations or a continuous operation. Unusual transaction: Any transaction involving an abnormally high amount. Suspicious transaction: Any transaction that appears unrelated to the client's business nature; or for which documents/information showing its purpose have not been provided and that lack any apparent economic or lawful justification.

Chapter II: Duties of Exchange Offices Regarding Vigilance and Surveillance Article 2 The exchange office must implement an internal vigilance and surveillance system adapted to the size of its activity, the nature of its clientele, volume, and risks associated with this activity. This system is deployed at each exchange office operated by the manual exchanger, when operating more than one.

Article 3 The internal vigilance and surveillance system includes procedures for combating money laundering, terrorist financing, and proliferation of weapons of mass destruction governing: • identification of regular or occasional clients and beneficial owners using official documents and other reliable independent sources; • systematic screening of clients and beneficial owners in manual exchange operations against national lists of persons, organizations, and entities linked to terrorist offenses and UN Security Council sanctions lists; • monitoring and surveillance of manual exchange operations; • timely detection of suspicious and unusual transactions; • immediate reporting of suspicious transactions to the Tunisian Financial Analysis Commission; • retention of documents related to clients and their operations on material or electronic media for ten years from the date of the operation; • continuous staff training in combating money laundering, terrorist financing, and proliferation of weapons of mass destruction, adapted to different staff profiles and roles.

Article 4 The exchange office must define and implement a risk identification and assessment system for money laundering, terrorist financing, and proliferation of weapons of mass destruction risks to which it is exposed, along with risk mitigation measures. In identifying and assessing these risks, it considers:

• risk factors related to clientele characteristics, operation volume, or geographic locations of exchange offices.
• conclusions from national risk assessments on combating money laundering, terrorist financing, and proliferation of weapons of mass destruction, including emerging threats; and
• information from other reliable external sources on combating money laundering, terrorist financing, and proliferation of weapons of mass destruction. The risk assessments must be documented in a report, updated upon significant events affecting risk factors or when competent authority information may modify inherent risk assessments (e.g., legal/regulatory changes or updated national sectoral risk assessments). The exchange office must be able to demonstrate, upon request by the Central Bank of Tunisia, the relevance of its risk assessment and the adequacy of proportionate vigilance measures to prevent, mitigate, and manage money laundering and terrorist financing risks. Documents used for risk assessment are retained and made available to the Central Bank of Tunisia upon request. For this circular, proliferation of weapons of mass destruction financing risk means any potential failure to apply or circumvention of targeted financial sanctions obligations under UN Security Council resolutions, including immediate freezing of funds and prohibition on making funds available to or for the benefit of designated persons/entities under Chapter VII of the UN Charter.

Article 5 The exchange office must take necessary measures to manage and control its internal vigilance and surveillance system. This office is required in particular to: • Review suspicious and unusual transactions promptly; • Perform enhanced due diligence on high-risk business relationships.

Article 6 The internal vigilance and surveillance system must be periodically evaluated and controlled to: • Test overall system effectiveness; • Verify adequacy of money laundering, terrorist financing, and proliferation of weapons of mass destruction procedures against current legislation; • Control staff compliance with existing procedures; • Test screening and surveillance systems for suspicious/unusual transactions; • Ensure document retention; • Verify honorability criteria, especially during staff appointments; • Test the quality of dedicated staff training; • Control correction of previously identified deficiencies.

Chapter III: Identification of Clients and Beneficial Owners Article 7 The manual exchanger must identify clients seeking its services and beneficial owners using official documents and other reliable independent sources. These documents must be valid and bear the client's photograph.

Article 8 If the client is a natural person, the manual exchanger must collect in the client file all identification elements listed in the annex to this circular, plus any additional information deemed necessary. The identification elements must also be collected for persons acting on behalf of the client under a power of attorney or mandate, using official documents and other reliable independent sources.

Article 9 If the client is a legal person or legal structure, the manual exchanger must collect in the client file all identification elements listed in the annex, plus any additional information deemed necessary. The identification elements must be supported by official documents or certified copies proving the legal person's existence and registration with the National Business Register. The manual exchanger must also collect identification elements for persons representing the legal person and its beneficial owner, using official documents and other reliable independent sources.

Article 10 When the manual exchanger doubts the accuracy of client or beneficial owner identification data, it must: • Refrain from executing the manual exchange operation; • Refrain from establishing a business relationship; • Terminate the business relationship; • Promptly transmit a suspicion report to the Tunisian Financial Analysis Commission; The manual exchanger must refrain from establishing a business relationship or executing a manual exchange operation for a client whose necessary identification due diligence has not been properly completed.

Article 11 The manual exchanger must comply with decisions of the National Commission for the Fight against Terrorism. The manual exchanger must perform necessary checks on national and UN lists published by the National Commission for the Fight against Terrorism and refrain from establishing a business relationship or conducting any operations with persons on these lists until their removal.

Article 12 The information form, copies of identity documents, exchange slip, and any other relevant documents must be filed in a client-specific open file.

Article 13 The exchange office must periodically update identification elements and documents specified in Articles 8 and 9, based on the risk level of the business relationship and results of its money laundering and terrorist financing risk assessment (Article 4).

Article 14 The manual exchanger must take due diligence measures proportionate to risk levels, based on the results of its money laundering and terrorist financing risk assessment (Article 4). The manual exchanger must apply enhanced vigilance measures for client identification to: • Politically exposed persons; • Clients identified as high-risk by the exchange office based on its risk assessment (Article 4); • Nationals, residents, or clients conducting operations with jurisdictions subject to enhanced FATF surveillance; • Nationals, residents, or clients conducting operations with jurisdictions identified by FATF as high-risk and subject to a call for action; • Clients conducting unusual transactions. The enhanced vigilance measures applicable to high-risk clients include: • Collecting additional information on clients, beneficial owners, and the purpose/nature of operations; • Monitoring and conducting thorough examinations of client transactions; • Increasing the frequency of identification element updates. Except in cases of suspected money laundering or terrorist financing, the manual exchanger may apply simplified due diligence for client identification. These simplified measures include: • Complete verification of client and beneficial owner identity; • Reduced frequency of identification element updates.

Chapter IV: Suspicion Reporting and Asset Freezing Obligations Article 15 The exchange office must transmit to the Tunisian Financial Analysis Commission its designation as correspondent and deputy. The correspondent and deputy must register on the goAML platform of the Commission to promptly transmit suspicion reports for any suspicious transaction potentially linked, directly or indirectly, to funds from illicit acts classified as misdemeanors or crimes, or to financing of persons/organizations/activities related to terrorist offenses. The Commission's correspondent or deputy must also declare any attempts to conduct such operations. The reporting obligation applies even after the operation, when new information may link it directly or indirectly to funds from illicit acts or terrorist financing.

Article 16 The Commission's correspondent, deputy, manual exchanger, or any other person regardless of function at the exchange office must refrain from informing the concerned person or third party about a suspicion report filed against them.

Article 17 In accordance with Article 137 of Law No. 2015-26, the manual exchanger and/or declarant, acting as correspondent of the Tunisian Financial Analysis Commission, cannot be subject to civil damages or criminal prosecution for acting in good faith when fulfilling the reporting obligation under Article 15.

Article 18 The manual exchanger must transmit to the National Commission for the Fight against Terrorism frozen assets regarding:

• Freezes under UN sanctions; and
• Freezes decided by the National Commission for the Fight against Terrorism. This obligation also covers freezes under the fight against proliferation of weapons of mass destruction financing.

Article 19 Without prejudice to criminal sanctions under applicable legislation, and in case of non-compliance with any obligation under this circular, the Governor of the Central Bank of Tunisia is authorized, after hearing the concerned person, to impose one of the following disciplinary sanctions: • Warning; • Reprimand; • Prohibition from exercising activity or suspension of authorization for up to two years; • Withdrawal of authorization.

Article 20 This Circular enters into force as of the date of its publication. THE GOVERNOR, FETHI ZOUHAIER NOURI

Annex to Circular No. 2026-02 of January 23, 2026 ELEMENTS OF CLIENT IDENTIFICATION I. Natural Person:

• Name and surname
• Date and place of birth
• Marital status
• Nationality
• ID number or passport/residence permit number with issue and expiration dates
• Official address
• Profession/Employer
• Income or other elements to estimate resources
• Identity of beneficial owner(s) II. Legal Person:
• Trade name/Company name
• Registered office address
• Legal form
• Nature of activity
• National Business Register identifier
• Name of legal representative or person acting on behalf of the client
• Main shareholders/partners
• Mandates and powers
• Any element to assess financial situation, notably financial statements and auditor reports (if applicable)
• Identity of beneficial owner(s) III. Associations:
• Association name
• Main office address
• National Business Register identifier
• Names and IDs of persons authorized to conduct financial operations, with their ID numbers
• Statutes and JORT extract reference regarding association constitution
• Any element to assess financial situation, notably financial statements and auditor reports (if applicable)
• Identity of beneficial owner(s) IV. Political Parties:
• Main office address
• List of executive bureau members and their ID numbers
• Statutes
• National Business Register identifier
• JORT extract regarding constitution
• Any element to assess financial situation, notably financial statements and auditor reports.
• Sworn declaration confirming the party holds no other bank or postal accounts (under Article 22 of Decree-Law No. 2011-87)
• Identity of beneficial owner(s). V. Legal Structures:
• Name/Designation
• Address
• Certificate of incorporation or trust-creating deed
• Nature of activity
• Governing powers
• Names of directors holding Trustee functions
• Trustee residence
• Identity of beneficial owner(s).