Circular No. 100/2025: High-Risk Countries and Countries Under Enhanced Follow-Up

---

[Logo of the Palestine Monetary Authority]

Palestine Monetary Authority
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, in accordance with the list issued by the Financial Action Task Force (FATF). Accordingly, the necessary legal measures are requested to implement the requirements of the aforementioned decision and the specific measures to be taken, emphasizing the necessity to comply with the following:

1. Take into account concerns regarding deficiencies in Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) systems in countries classified on the "Grey List" (Countries Under Enhanced Follow-Up), when conducting and updating the self-assessment of money laundering and terrorism financing risks.
2. Apply the Risk-Based Approach (RBA), such that the application of due diligence measures is proportionate to (risk analysis results, nature of the financial transaction risk, customer risks, and country classification), with enhanced due diligence measures to be exercised when high risks are identified.

Supervision Group
Palestine Monetary Authority
[Signature]

Copy: The Honorable Financial Follow-Up Unit

---

Financial Follow-Up Unit
State of Palestine

Decision No. (2025/2)
Issued by the Financial Follow-Up Unit
Date: June 19, 2025

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

Based on the provisions of Law No. (39) of 2025 regarding the prevention of money laundering and terrorist financing and its amendments, particularly Article (20) and paragraphs (3, 4) of Article (30), and in light of Decision No. (4/J/2016) of the National Committee for Combating Money Laundering and Terrorist Financing issued on December 1, 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 as determined by the Group since February 21, 2020, until June 13, 2025, and in reference to Decision No. (T/2020/5) of the National Committee for Combating Money Laundering and Terrorist Financing issued on February 24, 2020, regarding High-Risk Countries and Countries Under Enhanced Follow-Up, and subsequently to Decision No. (2020/1) of the Follow-Up Unit dated February 25, 2020, and its subsequent decisions regarding lists of High-Risk Countries and Countries Under Enhanced Follow-Up.

And in light of public interest requirements, it has been decided as follows:

First
List of High-Risk Countries (Black List)

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

Country	Required Measures 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.
- Islamic Republic of Iran (Iran).	2. Pay special attention to commercial relations and transactions with those countries, including companies and financial institutions, and apply the following countermeasures: <br> a. Apply enhanced due diligence measures on business relations and operations with those countries (as part of countermeasures), 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 Designated Non-Financial Businesses and 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.

---

c. Enhance the reporting mechanisms adopted by the financial institution or one of the designated non-financial businesses and professions, including increasing cooperation between employees and promptly providing data to the Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) officer within the financial institution or one of the designated non-financial businesses and professions, to ensure that no transaction or operation suspected of involving money laundering or one of the predicate crimes associated with it, or terrorist financing, is executed, and to report such suspicion to the Unit immediately and without delay, providing it with all data related to the attempt to conclude those transactions, while ensuring the confidentiality of the report and not notifying the customer.
d. Do not establish branches, representative offices, or subsidiaries in those countries. e. Do not rely on third parties located in those countries to take any due diligence measures towards customers. f. Do not establish any banking correspondent relationships or similar correspondent relationships with financial institutions in those countries.

Country

Required Measures Towards Countries

Republic of the Union of Myanmar (Myanmar).

1. Apply enhanced due diligence measures on business relations and operations with Myanmar, 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 Designated Non-Financial Businesses and 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
List of Countries Under Enhanced Follow-Up (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, Virgin Islands (United Kingdom)), 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 attached appendix to this decision) when conducting the self-assessment of money laundering and terrorism financing risks, including identifying, analyzing, and evaluating those risks.

---

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 (Lao)	23	Virgin Islands (United Kingdom)
12	Republic of Lebanon	24	Republic of Yemen (Yemen)

Third
Implementation

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

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

Attachment: Concerns Regarding Deficiencies in Anti-Money Laundering and Combating the Financing of Terrorism Systems.

---

Concerns Regarding Deficiencies in Anti-Money Laundering and Combating the Financing of Terrorism Systems

---

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 Anti-Money Laundering and Combating the Financing of Terrorism Systems in Countries

• Part One: Deficiencies through Assessment Reports (for all countries):
  This section explains how to access concerns regarding the Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) and Combating the Financing of Proliferation (CFP) systems of countries listed on the Grey List, as well as all other countries undergoing mutual evaluation by the FATF or peer groups. Those concerns can be accessed by reviewing the mutual evaluation reports related to those countries, and the follow-up reports subsequent to that report.

The published Mutual Evaluation Reports (MERs) and Follow-up Reports on the FATF website or the FATF Middle East and North Africa Regional Body (MENAFATF) website 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. Those can be obtained via the following mechanism:

a. Accessing Mutual Evaluation Reports in English (for 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. Accessing 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.

---

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 implementing 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 according to mutual evaluation reports and follow-up reports, which must be taken into account whether negative or positive:

Country	Key Pillars (Statement from October 2024)
Algeria	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

---

Attached to Financial Follow-Up Unit Decision No. (2025/2) Regarding Lists of High-Risk Countries and Countries Under Enhanced Follow-Up

Country	Key Pillars
	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. 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 combatting 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.

---

Attached to Financial Follow-Up Unit Decision No. (2025/2) Regarding Lists of High-Risk Countries and Countries Under Enhanced Follow-Up

Country	Key Pillars
Cameroon	Since June 2023, when Cameroon made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime, Cameroon has taken steps to improve its AML/CFT regime by establishing and implementing an effective mechanism to maintain adequate, accurate and up-to-date beneficial information; prioritising the identification of TF activities, investigations and prosecutions in line with risk; and addressing technical deficiencies in its legal and institutional frameworks to implement targeted financial sanctions related to Recommendations 6 and 7. Cameroon should continue working on implementing its action plan to address its strategic deficiencies, including by: (1) implementing effective risk-based supervision for non-bank FIs and DNFBPs, and conducting appropriate outreach to high-risk FIs and DNFBPs; (2) enhancing secure information exchange between the FIU, reporting entities and competent authorities and demonstrating an increase in dissemination of intelligence reports to support operational needs of competent authorities; (3) demonstrating that authorities are able to conduct a range of ML investigations, and prosecute ML in line with risks; (4) implementing policies and procedures for seizing and confiscating proceeds and instrumentalities of crime and managing frozen, seized and confiscated property, and prioritising seizure and confiscation of assets at the border; (5) demonstrating effective implementation of TF and PF TFS regimes and implementing a risk-based approach to NPOs without disrupting legitimate NPO activities.
Côte D'ivoire	Since October 2024, when Côte d'Ivoire made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime, Côte d'Ivoire has taken steps to improve its AML/CFT regime by strengthening the technical compliance of its targeted financial sanctions framework with Recommendation 6. Côte d'Ivoire should continue working on implementing its action plan to address its strategic deficiencies, including by: (1) enhancing its use of international cooperation in ML/TF investigations and prosecutions; (2) improving the implementation of risk-based supervision of financial institutions and designated non-financial businesses and professions and conducting outreach campaigns to improve compliance; (3) improving the verification and access of basic and beneficial ownership information of legal persons and applying sanctions in case of violation of BO obligations; (4) enhancing the use of financial intelligence by law enforcement authorities and improving disseminations by the FIU; (5) demonstrating a sustained increase in the number of investigations and prosecutions of different types of ML and TF in line with the country's risk profile; and (6) strengthening the implementation of its targeted financial sanctions regime.

---

Attached to Financial Follow-Up Unit Decision No. (2025/2) Regarding Lists of High-Risk Countries and Countries Under Enhanced Follow-Up

Country	Key Pillars
Democratic Republic Of The Congo	Since October 2022, when the DRC made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime, the DRC has taken steps towards improving its AML/CFT regime, including by building the capacity of the FIU to conduct operational and strategic analysis. The DRC should continue to work to implement its FATF action plan to address its strategic deficiencies, including by: (1) developing and implementing a risk-based supervision plan; (2) strengthening the capabilities of authorities involved in the investigation and prosecution of ML and TF; and (3) demonstrating effective implementation of TF and PF-related TFS. The FATF notes that the DRC continued progress across its action plan, however all deadlines have now expired and work remains. The FATF encourages the DRC to continue to implement its action plan to address the above-mentioned strategic deficiencies as soon as possible.
Haiti	Since June 2021, when Haiti made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, Haiti has taken steps towards improving its AML/CFT regime, including implementing risk-based AML/CFT supervision for all financial institutions; and ensuring the FIU has adequate resources and processes to produce and disseminate operational and strategic analysis to competent authorities for combatting ML and TF. The FATF recognises the political commitment expressed at a high level and the efforts demonstrated by Haiti to advance its commitment in the midst of the challenging social, economic and security situation within the country. Haiti should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) completing its ML/TF risk assessment process and disseminating the findings; (2) implementing risk-based AML/CFT supervision for DNFBPs deemed to constitute a higher ML/TF risk; (3) ensuring basic and beneficial ownership information are maintained and accessible in a timely manner; (4) demonstrating authorities are identifying, investigating and prosecuting ML cases in a manner consistent with Haiti's risk profile; (5) demonstrating an increase of identification, tracing and recovery of proceeds of crimes; (6) addressing the technical deficiencies in its targeted financial sanctions regime; and (7) conducting appropriate risk-based monitoring of NPOs vulnerable to TF abuse without disrupting or discouraging legitimate NPO activities. The FATF notes Haiti's continued progress across its action plan, however all deadlines have expired and work remains. The FATF encourages Haiti to continue to implement its action plan to address the above-mentioned strategic deficiencies.

---

Attached to Financial Follow-Up Unit Decision No. (2025/2) Regarding Lists of High-Risk Countries and Countries Under Enhanced Follow-Up

Country	Key Pillars
Kenya	Since February 2024, when Kenya made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime, Kenya has taken steps towards improving its AML/CFT regime, including by updating its national AML/CFT strategies in line with the identified ML/TF risks. Kenya should continue to work to implement its FATF action plan to address its strategic deficiencies, including by: (1) presenting the results of the NRA and other risk assessments in a consistent manner to competent authorities and the private sector; (2) improving risk-based AML/CFT supervision of FIs and DNFBPs and adopting a legal framework for the licensing and supervision of VASPs; (3) enhancing the understanding of preventive measures by FIs and DNFBPs, including to increase STR filing and implement TFS without delay; (4) designating an authority for the regulation of trusts and collection of accurate and up-to-date beneficial ownership information and implementing remedial actions for breaches of compliance with transparency requirements for legal persons and arrangements; (5) improving the use and quality of financial intelligence products; (6) increasing ML and TF investigations and prosecutions in line with risks; (7) bringing the TFS framework in compliance with R.6 and ensure its effective implementation; and (8) revising the framework for NPO regulation and oversight to ensure that mitigating measures are risk-based and do not disrupt or discourage legitimate NPO activity.
Lao Pdr	(Statement from February 2025) In February 2025, Lao PDR made a high-level political commitment to work with the FATF and APG to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in August 2023, Lao PDR has made progress on some of the MER's recommended actions including increasing FIU resources and eliminating bearer shares. Lao PDR will 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 casinos, banks and reporting entities in SEZs, including fit and proper checks; (3) enhancing the quality and quantity of financial intelligence analysis and spontaneous dissemination to law enforcement agencies; (4) ensuring law enforcement agencies receive training and guidance on money laundering; (5) demonstrating an increase in ML investigations and prosecutions in line with Lao PDR's risk profile, with an emphasis on crimes with a transnational element that require international cooperation; (6) developing a national confiscation policy consistent with its ML/TF risks; (7) demonstrating that relevant competent authorities are taking measures to identify, seize and, where applicable, conf

---