Palestine Monetary Authority

Circular No. (100/2025)
To all banks operating in Palestine
Date: Tuesday, August 19, 2025

Subject: High-Risk Countries and Countries Under Enhanced Follow-Up

Attached is a copy of the decision issued by the Financial Follow-Up Unit No. (2025/2) regarding High-Risk Countries and Countries Under Enhanced Follow-Up according to the list endorsed by the Financial Action Task Force (FATF). Accordingly, the necessary legal measures are requested to implement the requirements of the aforementioned decision and the measures to be taken in this regard, emphasizing the necessity to comply with the following:

1. Taking into account concerns regarding deficiencies in Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) systems in countries classified within the "Grey List" (Countries Under Enhanced Follow-Up), when conducting and updating the self-assessment of money laundering and terrorism financing risks.

2. Applying the Risk-Based Approach (RBA), such that the application of due diligence measures is proportional to (risk analysis results, nature of the financial transaction risks, customer risks, and country classification), with enhanced due diligence measures to be taken when high risks are perceived.

Supervision Group
Palestine Monetary Authority

Copy: To the respected gentlemen/ Financial Follow-Up Unit

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www.pma.ps

Ramallah & Al-Bireh Governorate - Palestine P.O. Box 452
Ramallah and Al-Bireh Governorate - Palestine P.O. Box
info@pma.ps | Fax: +970 2 2415310 | Tel: +970 2 2415251 | Postal code: P6160675

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Financial Follow-Up Unit

State of Palestine

Decision No. (2025/2)

Issued by the Financial Follow-Up Unit
On 19/06/2025

Regarding Lists of High-Risk Countries and Countries Under Enhanced Follow-Up

Based on the provisions of Law No. (39) of 2022 regarding the combating of money laundering and the financing of terrorism and its amendments, particularly the provisions of Article (20) and paragraphs (3, 4) of Article (30), and based on the decision of the National Committee for Combating Money Laundering and the Financing of Terrorism No. (8/J/2016) issued on 01/12/2016 regarding the delegation to 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 since 21/02/2020, until 13/06/2025, and in addition to the decision of the National Committee for Combating Money Laundering and the Financing of Terrorism No. (T/2020/5) issued on 24/02/2020 regarding High-Risk Countries and Countries Under Enhanced Follow-Up, and subsequently the Financial Follow-Up Unit Decision No. (2020/1) dated 25/02/2020 and subsequent decisions regarding High-Risk Countries and Countries Under Enhanced Follow-Up.

And based on the requirements of public interest, it is decided as follows:

First

High-Risk Countries List (Black List)

All financial institutions, businesses, and specified non-financial professions in the State of Palestine must continue to apply the following procedures towards high-risk countries:

Country	Required Procedures Towards Countries
- Democratic People's Republic of Korea (North Korea).	1. Apply targeted financial sanctions in accordance with the provisions of Executive Decree No. (2022/14) regarding the implementation of Security Council resolutions.<br>2. Pay special attention to commercial relations and transactions with those countries, including companies and financial institutions, and apply the following counter-measures:<br>a. Take enhanced due diligence measures on business relations and operations with those countries (as part of counter-measures), and in proportion to the risks arising therein, according to the details of Articles (26, 27) of National Committee Instructions No. (4) of 2022 regarding financial institutions, and Articles (24, 25) of National Committee Instructions No. (3) of 2022 regarding specified businesses and non-financial professions.<br>b. Apply the enhanced due diligence measures mentioned in paragraph (a) of this item when dealing with any entity acting on behalf of a natural or legal person, including companies or financial institutions operating in those countries.
- Islamic Republic of Iran (Iran).

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FINANCIAL FOLLOW-UP UNIT
State of Palestine – Al Bireh P.O.Box 3981
Tel: +970 22422551\2 | Fax: +970 22422553 | E-mail: info@ffu.ps | www.ffu.ps
State of Palestine – Al Bireh P.O.Box: 3981
Tel: +970 22422551\2 | Fax: +970 22422553

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Financial Follow-Up Unit

State of Palestine

c. Enhance the reporting mechanisms adopted by the financial institution or one of the specified non-financial businesses, including increasing cooperation between employees and expediting the provision of data to the money laundering and terrorism financing compliance officer within the financial institution or one of the specified non-financial businesses, to ensure that no transaction or operation suspected of involving money laundering or one of the predicate crimes or terrorism financing is executed, and to report to the Unit immediately and without delay regarding this violation, providing it with all data related to attempts to conclude those transactions, while ensuring the confidentiality of the report and not notifying the customer.<br>d. Do not establish branches, representative offices, or subsidiaries in those countries.<br>e. Do not rely on third parties located in those countries in taking any due diligence measures towards customers.<br>f. Do not establish any banking correspondent relationships or similar correspondent relationships with financial institutions in those countries.
- Union of Myanmar (Myanmar).	1. Apply enhanced due diligence measures on business relations and operations with Myanmar, and in proportion to the risks arising in the country, according to the details of Articles (26, 27) of National Committee Instructions No. (4) of 2022 regarding financial institutions, and Articles (24, 25) of National Committee Instructions No. (3) of 2022 regarding specified businesses and non-financial professions.<br>2. When applying enhanced due diligence measures, ensure that the flow of funds for humanitarian aid and legitimate non-profit organization activities and financial transfers is not disrupted.<br>3. Regarding earthquake relief efforts specifically, ensure that the implementation of AML/CFT requirements does not negatively or disproportionately affect non-profit organizations, and does not unjustifiably hinder the work of civil society and the provision of humanitarian aid related to earthquake relief in Myanmar.

Second

Countries Under Enhanced Follow-Up List (Grey List)

Amend the list of Countries Under Enhanced Follow-Up (Grey List) stipulated in the Unit's Decision No. (2025/1) by adding (Bolivia, British Virgin Islands), and removing (Croatia, Republic of Mali, Tanzania), so that the list becomes as in the table below, and taking into account concerns regarding deficiencies in the AML/CFT systems of these countries (according to the attachments to this decision) when conducting the self-assessment of money laundering and terrorism financing risks, including identifying, analyzing, and evaluating those risks.

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FINANCIAL FOLLOW-UP UNIT
State of Palestine – Al Bireh P.O.Box 3981
Tel: +970 22422551\2 | Fax: +970 22422553 | E-mail: info@ffu.ps | www.ffu.ps
State of Palestine – Al Bireh P.O.Box: 3981
Tel: +970 22422551\2 | Fax: +970 22422553

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Financial Follow-Up Unit

State of Palestine

No.	Country Name	No.	Country Name
1	Algeria	13	Monaco
2	Angola	14	Republic of Mozambique
3	Bolivia	15	Republic of Namibia
4	Bulgaria	16	Federal Democratic Republic of Nepal (Nepal)
5	Burkina Faso	17	Republic of Nigeria
6	Cameroon	18	Republic of South Africa
7	Côte d'Ivoire (Ivory Coast)	19	Republic of South Sudan
8	Democratic Republic of the Congo	20	Syrian Arab Republic (Syria)
9	Republic of Haiti	21	Venezuela
10	Republic of Kenya	22	Vietnam
11	Lao People's Democratic Republic (Laos)	23	British Virgin Islands
12	Republic of Lebanon	24	Republic of Yemen (Yemen)

Third

Implementation

All financial institutions, businesses, and specified non-financial professions must implement the provisions of this decision, and it shall be effective from the date of its circularization.

Director of the Financial Follow-Up Unit
Dr. Firas Marar

Attachment: Concerns regarding deficiencies in Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) systems.

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State of Palestine – Al Bireh P.O.Box 3981
Tel: +970 22422551\2 | Fax: +970 22422553 | E-mail: info@ffu.ps | www.ffu.ps
State of Palestine – Al Bireh P.O.Box: 3981
Tel: +970 22422551\2 | Fax: +970 22422553

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Concerns Regarding Deficiencies in Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Systems

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Attached to Financial Follow-Up Unit Decision No. (2025/2)

Regarding Lists of High-Risk Countries and Countries Under Enhanced Follow-Up

Concerns Regarding Deficiencies in AML/CFT Systems in Countries

Part One: Deficiencies through Mutual Evaluation Reports (All Countries)

This section illustrates how to access concerns regarding the AML/CFT and proliferation financing (PF) systems of countries listed on the Grey List, as well as all other countries undergoing mutual evaluation by the FATF or regional bodies. Those concerns can be accessed by reviewing the mutual evaluation reports related to those countries and the follow-up reports subsequent to that report.

Mutual Evaluation Reports (MERs) and Follow-up Reports on the FATF website or the FATF Middle East and North Africa Regional Body (MENAFATF) contain all deficiencies and key conclusions regarding the AML/CFT systems of countries listed on the Enhanced Follow-Up List and all other countries that have undergone evaluation. The following evidence can be obtained:

a. Access to Mutual Evaluation Reports in English (All Countries):

1. Enter the website: www.fatf-gafi.org
2. From the Topics menu, select (Mutual Evaluations)
3. Select Mutual Evaluations Reports
4. Search for the country name in English in the search window shown in the image on the side.

b. Access to Mutual Evaluation Reports in Arabic (For countries subject to evaluation by the FATF MENA Regional Body):

1. Enter the website: www.menafatf.org/ar
2. Select the item (Mutual Evaluation) then (Evaluation Reports – Second Round of Evaluation), or follow-up reports.
3. Select the report from the list that appears according to the country name.

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Attached to Financial Follow-Up Unit Decision No. (2025/2)

Regarding Lists of High-Risk Countries and Countries Under Enhanced Follow-Up

Part Two: Implementation of Action Plans to Address Deficiencies

Countries listed on the Grey List have made a high-level political commitment to address strategic deficiencies in their AML/CFT systems, and those countries are still fulfilling their commitments to address remaining deficiencies.

The items below outline the key pillars that those countries are working to address or have addressed, which depend on specific deficiencies identified in mutual evaluation reports and follow-up reports, which must be taken into account whether negative or positive:

Country	Key Pillars
Algeria	(Statement from October 2024)<br>In October 2024, Algeria made a high-level political commitment to work with the FATF and MENAFATF to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its mutual evaluation report (MER) in May 2023, Algeria has made progress on many of the MER’s recommended actions including by more effectively pursuing money laundering investigations and prosecutions. Algeria will continue to work with FATF to implement its action plan by: (1) improving risk-based supervision, especially for higher risk sectors, including through the adoption of new procedures, risk assessments, supervision manuals and guidelines, as well as undertaking inspections and applying effective, proportionate and dissuasive sanctions; (2) developing an effective framework for basic and beneficial ownership information; (3) enhancing its regime for suspicious transaction reports; (4) establishing an effective legal and institutional framework for targeted financial sanctions for terrorism financing; and (5) implementing a risk-based approach to oversight of non-profit organisations, without disrupting or discouraging legitimate activity.
Angola	In October 2024, Angola made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime. Angola should continue to work with the FATF to implement its FATF action plan by: (1) enhancing its understanding of ML/TF risks; (2) improving risk-based supervision of non-financial banking entities and DNFBPs; (3) ensuring competent authorities have adequate, accurate and timely access to beneficial ownership information and that breaches to obligations are adequately addressed; (4) demonstrating an increase in ML investigations and prosecutions; (5) demonstrating the ability to identify, investigate and prosecute TF; and (6) demonstrating an effective process to implement targeted financial sanctions without delay.
Bolivia	In June 2025, Bolivia made a high-level political commitment to work with the FATF and GAFILAT to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in December 2023, Bolivia has made significant progress on the MER’s recommended actions including enhancing its ML/TF risk understanding; enhancing the production and dissemination of operational and strategic financial intelligence; strengthening the seizure and forfeiture of criminal proceeds; increasing capacity to investigate TF offences; and improving

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Attached to Financial Follow-Up Unit Decision No. (2025/2)

Regarding Lists of High-Risk Countries and Countries Under Enhanced Follow-Up

	its process to implement targeted financial sanctions on TF and PF. Bolivia will continue to work with the FATF to implement its FATF action plan by: (1) ensuring relevant special investigative techniques can be used in ML investigations; (2) implementing risk-based supervision of real estate agents, lawyers, accountants and DPMS; (3) ensuring that beneficial ownership information is accurate and up-to-date and breaches to obligations are sanctioned; (4) increasing ML investigations and prosecutions.
Bulgaria	Since October 2023, when Bulgaria made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Bulgaria has taken steps towards improving its AML/CFT regime, including by providing guidance and training on ML/TF risk understanding and STR reporting to postal money operators, currency exchange providers and real estate agents, addressing technical compliance issues in relation to its TF offence and ensuring the ability to conduct parallel financial investigations in all terrorism investigations. Bulgaria should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) addressing the remaining technical compliance deficiencies; (2) improving investigations and prosecutions of different types of money laundering in line with risks, including high-scale corruption and organised crime; (3) addressing gaps in the PF TFS frameworks; and (4) demonstrating initial implementation of risk-based monitoring of NPOs to prevent abuse for TF purposes.
Burkina Faso	In February 2021, Burkina Faso made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime. At its June 2025 Plenary, the FATF made the initial determination that Burkina Faso has substantially completed its action plan and warrants an on-site assessment to verify that the implementation of the AML/CFT reforms has begun and is being sustained, and that the necessary political commitment remains in place to sustain implementation in the future.<br><br>Burkina Faso has made key reforms, including by: (1) adopting follow-up mechanisms for monitoring actions in the national strategy; (2) seeking MLA and other forms of international cooperation in line with its risk profile; (3) strengthening resource capacities of all AML/CFT supervisory authorities and implementing risk based supervision of FIs and DNFBPs; (4) maintaining comprehensive and up-to-date basic and beneficial ownership information and strengthening the system of sanctions for violations of transparency obligations; (5) increasing the diversity of suspicious transactions reporting; (6) enhancing the FIU’s human resources through additional hiring, training and budget; (7) conduct training for LEAs, prosecutors and other relevant authorities; (8) demonstrating that authorities are pursuing confiscation as a policy objective; (9) enhancing capacity and support for LEAs and prosecutorial authorities involved in combating TF, in line with the National TF Strategy; and (10) implementing effective targeted financial sanctions regimes related to terrorist financing and proliferation financing as well as risk-based monitoring and supervision of NPOs.

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