Regulatory Alerts2019-01-01
Decision No. (3) of 2019 on High-Risk Countries and Countries Under Increased Monitoring
The Financial Follow-Up Unit of the State of Palestine issued Decision No. 3 of 2019 to designate specific jurisdictions as high-risk or under increased monitoring based on FATF assessments. The decision mandates Palestinian financial institutions to impose a complete transaction ban on North Korea and apply enhanced due diligence measures to Iran, while implementing ongoing due diligence for eleven other countries including The Bahamas, Botswana, Ghana, Pakistan, Syria, Iceland, Mongolia, Yemen, Zimbabwe, Trinidad and Tobago, Cambodia, and Panama. This directive supersedes Decision No. 2/2019 and requires immediate compliance with the specified risk-based controls to align with national anti-money laundering and counter-terrorist financing laws.
Palestine Monetary Authority
Circular No. (259/2019) To all banks operating in Palestine Date: Wednesday, October 30, 2019
Subject: High-Risk Countries and Countries Under Increased Monitoring of Compliance with International Standards
Attached is a copy of Decision No. (3/2019) issued by the Financial Follow-Up Unit on 23/10/2019 regarding high-risk countries and countries under increased monitoring of compliance with international standards, in accordance with the list issued by the Financial Action Task Force (FATF).
Accordingly, all banks operating in Palestine are requested to take the necessary legal measures to implement the requirements of the aforementioned decision and the measures to be taken in this regard.
Supervision and Inspection Department
Palestine Monetary Authority
Copy: To the esteemed Financial Follow-Up Unit
West Bank - Ramallah & Al-Bireh - 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 2825713
Financial Follow-Up Unit
State of Palestine
Financial Follow-Up Unit
State of Palestine
Decision No. (3/2019)
Issued by the Financial Follow-Up Unit
Dated 23/October/2019
Regarding High-Risk Countries and Countries Under Increased Monitoring of Compliance with International Standards
Based on the ruling of Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, particularly paragraph (16) of Article (20),
and based on the decision of the National Committee for Combating Money Laundering and Financing of Terrorism No. (8/J/2016) issued on 01/12/2016 regarding delegating the Financial Follow-Up Unit to publish the list of high-risk countries issued periodically by the Financial Action Task Force (FATF), and subsequently what was decided by the Group on 18/10/2019,
and in addition to the decision of the National Committee for Combating Money Laundering and Financing of Terrorism No. (6/J/2016) issued on 01/08/2017 regarding the prohibition of financial transactions with the Democratic People's Republic of Korea,
and based on public interest requirements, the following is decided:
First: High-Risk Countries
The following countries are considered high-risk due to strategic deficiencies regarding anti-money laundering and counter-terrorist financing standards, and they are to be treated according to the following specifications:
| Country Name | Measures to be Taken |
|---|---|
| Democratic People's Republic of Korea (North Korea) | All financial institutions are prohibited from conducting financial transactions with North Korea. |
State of Palestine – Al Bireh P.O.Box 3981
Tel.: 0097022967401/2 Fax: 0097022967426
E-mail: info@ffu.ps www.ffu.ps
State of Palestine – Al Bireh P.O.Box 3981
Tel.: 0097022967401/2 Fax: 0097022967426
Financial Follow-Up Unit
State of Palestine
Financial Follow-Up Unit
State of Palestine
Continuing to apply enhanced due diligence measures regarding business relationships with the Islamic Republic of Iran
| Country Name | Measures to be Taken |
|---|---|
| Iran | Continuing to apply enhanced due diligence measures regarding business relationships with Iran, including financial transactions executed from or to it, whether for natural or legal persons, and taking into account correspondent relationships with financial institutions operating and licensed in Iran, in accordance with the provisions of Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder, and with FATF Recommendation No. (19) and its Interpretive Note, including collecting information on the purpose of transactions and sources of funds, and conducting enhanced monitoring of business relationships by increasing the number and evaluation of applied controls, and identifying transaction patterns requiring further due diligence and monitoring. |
Second: Countries Under Increased Monitoring of Compliance with International Standards
The following countries are under increased monitoring of compliance with international standards related to combating money laundering and financing of terrorism, and they are to be treated according to the following specifications:
| Country Name | Measures to be Taken |
|---|---|
| Commonwealth of The Bahamas (Bahamas Islands) | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
| Botswana | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
| Ghana | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
| Pakistan | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
| Syria | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
| Iceland | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
| Mongolia | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
State of Palestine – Al Bireh P.O.Box 3981
Tel.: 0097022967401/2 Fax: 0097022967426
E-mail: info@ffu.ps www.ffu.ps
State of Palestine – Al Bireh P.O.Box 3981
Tel.: 0097022967401/2 Fax: 0097022967426
Financial Follow-Up Unit
State of Palestine
Financial Follow-Up Unit
State of Palestine
| Country Name | Measures to be Taken |
|---|---|
| Yemen | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
| Zimbabwe | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
| Trinidad and Tobago | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
| Cambodia | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
| Panama | Given that these countries have made a high political commitment to address strategic deficiencies, all financial institutions must apply ongoing due diligence measures regarding business relationships with these countries, including financial transactions executed from or to them, to verify the purposes of executed financial transactions and ascertain the sources of funds, in accordance with Law-Decree No. (20) of 2015 on Combating Money Laundering and Financing of Terrorism and its amendments, and the instructions issued thereunder. |
Third: Obligations of Financial Institutions
All financial institutions operating in Palestine must take the measures specified in the tables outlined in items (First) and (Second) of this decision.
Fourth: Repeal
This decision repeals Financial Follow-Up Unit Decision No. (2/2019) issued on 17/July/2019 regarding high-risk countries and/or non-compliant countries with anti-money laundering and counter-terrorist financing standards.
Fifth: Implementation
All competent authorities are required to implement the provisions of this decision, which shall take effect from the date of its issuance.
Director of the Financial Follow-Up Unit
Mr. Wael Lavi
State of Palestine – Al Bireh P.O.Box 3981
Tel.: 0097022967401/2 Fax: 0097022967426
E-mail: info@ffu.ps www.ffu.ps
State of Palestine – Al Bireh P.O.Box 3981
Tel.: 0097022967401/2 Fax: 0097022967426