Regulatory Alerts2018-10-18
BCT Circular to Banks and Financial Institutions No. 2018-09 of October 18, 2018
The Central Bank of Tunisia issued Circular No. 2018-09 to update and replace key provisions of its previous AML/CFT internal control framework, mandating stricter customer due diligence, beneficial ownership verification, and enhanced monitoring for politically exposed persons and high-risk jurisdictions. The circular requires covered institutions to implement risk-based simplified or enhanced due diligence measures, document their risk assessments, and ensure group-wide compliance programs for foreign branches and subsidiaries. It further establishes strict reporting obligations for suspicious transactions, outlines countermeasures for FATF-listed jurisdictions, and clarifies the conditions under which institutions may rely on third parties for client identification.