Palestine Monetary Authority

PALESTINE MONETARY AUTHORITY

Circular No. (2025/25)

To all specialized lending institutions in Palestine

Date: Tuesday, October 28, 2025

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

Attached is a copy of the decision issued by the Financial Follow-Up Unit No. (2025/3) regarding High-Risk Jurisdictions and Jurisdictions Under Enhanced Follow-Up according to the list issued by the Financial Action Task Force (FATF). Accordingly, the necessary legal proposal is requested to implement the requirements of the aforementioned decision and the measures to be taken, with emphasis on 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" (Jurisdictions 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, worker risks, and country classification), with enhanced due diligence measures to be exercised when high risks are perceived.

Supervisory Group

Palestine Monetary Authority

Copy: The Minister / Financial Follow-Up Unit

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www.pma.ps

Ramallah & Al-Bireh Governorate - Palestine P.O. Box 452 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

وحدة المتابعة المالية

دولة فلسطين

Decision No. (2025/3)

Issued by the Financial Follow-Up Unit

Date: 26/10/2025

Regarding lists of High-Risk Jurisdictions and Jurisdictions Under Enhanced Follow-Up

Based on the provisions of Law No. (39) of 2022 regarding the prevention of money laundering and the financing of terrorism and its amendments, particularly the provisions of Article (20) and paragraphs (4, 3) of Article (30), and based on Decision No. (8/J/2016) of the National Committee for Combating Money Laundering and the Financing of Terrorism 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, up to 24/10/2025, and in accordance with Decision No. (T/2020/5/2) of the National Committee for Combating Money Laundering and the Financing of Terrorism issued on 24/02/2020 regarding High-Risk Jurisdictions and Jurisdictions Under Enhanced Follow-Up, and subsequently Decision No. (2020/1) of the Financial Follow-Up Unit dated 25/02/2020 and subsequent decisions regarding lists of High-Risk Jurisdictions and Jurisdictions Under Enhanced Follow-Up.

And based on public interest requirements, it has been decided as follows:

First

List of High-Risk Jurisdictions (Black List)

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

Country	Required Procedures Regarding Countries
- Democratic People's Republic of Korea (North Korea).	1. Apply targeted financial sanctions in accordance with the implementing provisions 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 countermeasures:<br>a. Take enhanced due diligence measures on business relations and transactions with those countries (as part of countermeasures), proportionate to the risks arising therein, according to the details of Articles (27, 26) 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.
- Islamic Republic of Iran (Iran).
- Republic of the Union of Myanmar (Myanmar).	1. Apply enhanced due diligence measures on business relations and transactions with Myanmar, proportionate to the risks arising in the country, according to the details of Articles (27, 26) 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 assistance and legitimate non-profit organization activities and financial transfers is not disrupted.

Second

List of Jurisdictions Under Enhanced Follow-Up (Grey List)

Amend the list of Jurisdictions Under Enhanced Follow-Up (Grey List) stipulated in Unit Decision No. (2025/2) by deleting both (Republic of South Africa, Federal Republic of Nigeria, Republic of Mozambique, Burkina Faso), so that the list becomes as in the table below, and take into account concerns regarding deficiencies in the AML/CFT systems of these countries (according to the attachment to this decision) when conducting the self-assessment of money laundering and terrorism financing risks, including identifying, analyzing, and assessing those risks.

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

Director of the Financial Follow-Up Unit

Dr. Firas Marar

Attachment: Concerns regarding deficiencies in Anti-Money Laundering and Combating the Financing of Terrorism 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

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Attachment to Financial Follow-Up Unit Decision No. (2025/3)

Regarding lists of High-Risk Jurisdictions and Jurisdictions 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 (All Countries)

This section explains how to access concerns regarding the Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing (AML/CFT/PF) system of countries listed on the Grey List, as well as all other countries undergoing mutual evaluation by the FATF or peer groups. These 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 or MENAFATF website contain all deficiencies and key conclusions regarding the AML/CFT system in countries listed on the Enhanced Follow-Up list and all other countries that have undergone evaluation. These can be obtained according to the following mechanism:

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 as shown in the image.

B. Access to Mutual Evaluation Reports in Arabic (For countries undergoing evaluation by the MENAFATF):

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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General Storage
Mutual Evaluation Team
Evaluation Report
First Round of Evaluation
Second Round of Evaluation
Follow-up Reports

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Attachment to Financial Follow-Up Unit Decision No. (2025/3)

Regarding lists of High-Risk Jurisdictions and Jurisdictions 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 these countries are still fulfilling their commitments to address remaining deficiencies.

The items below outline the core concerns 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	Core Axes
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 then, Algeria has taken significant steps towards improving its AML/CFT regime on many of its action items with some ahead of schedule, including by improving risk-based supervision through the adoption of new procedures, risk assessments, supervision manuals and guidelines, establishing a legal framework for sanctions for breaches of basic and beneficial ownership requirements for legal persons, establishing an effective legal and institutional framework for targeted financial sanctions for terrorism financing and undertaking a terrorism financing risk assessment of the non-profit sector. Algeria will continue to work with FATF to implement its FATF action plan by: (1) improving risk-based supervision, especially for higher risk sectors, by 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; and (4) implementing a risk-based approach to oversight of non-profit organisations, without disrupting or discouraging legitimate activity, by undertaking outreach to the non-profit sector
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	(Statement from June 2025)

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Attachment to Financial Follow-Up Unit Decision No. (2025/3)

Regarding lists of High-Risk Jurisdictions and Jurisdictions Under Enhanced Follow-Up

	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 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 in the last reporting cycle by establishing a more proportionate and dissuasive sanctioning regime to address AML/CFT breaches by reporting entities, training law enforcement and prosecutors on ML cases, and addressing technical compliance deficiencies through the passage of legislative reforms in relation to the terrorism financing offence and the liability of legal persons, the seizure and confiscation of assets from non-bona fide third parties and proliferation financing. Bulgaria should continue to work on implementing its FATF action plan to address its strategic deficiencies, including by: (1) addressing the remaining technical compliance deficiencies in relation to confiscation; (2) improving investigations and prosecutions of different types of money laundering in line with risks, including high-scale corruption and organised crime; and (3) demonstrating initial implementation of risk-based monitoring of NPOs to prevent abuse for TF purposes.<br><br>The FATF notes Bulgaria continued progress across its action plan, however all deadlines have now expired and work remains. The FATF encourages Bulgaria to build on its recent progress and continue to implement its action plan to address the above-mentioned strategic deficiencies as soon as possible, particularly in relation to its efforts to investigate and prosecute money laundering.
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 a mechanism to promote interagency AML coordination and cooperation at the operational level. Cameroon should continue working on implementing its action plan to address its strategic deficiencies, including by: (1) enhancing risk-based supervision of banks and implementing effective risk-

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Attachment to Financial Follow-Up Unit Decision No. (2025/3)

Regarding lists of High-Risk Jurisdictions and Jurisdictions Under Enhanced Follow-Up

	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.<br><br>The FATF notes Cameroon continued progress across its action plan, however all deadlines have now expired and work remains. The FATF encourages Cameroon to continue to implement its action plan to address the above-mentioned strategic deficiencies as soon as possible.
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 enhancing its use of international cooperation in ML/TF investigations and prosecutions, conducting outreach to improve compliance of AML/CFT obligations, improving the verification and access to beneficial ownership information of legal persons and sanctioning non-compliance, and strengthening the implementation of its targeted financial sanctions regime. Côte d’Ivoire should continue working on implementing its action plan to address its strategic deficiencies, including by: (1) improving the implementation of risk-based supervision of financial institutions and designated non-financial businesses and professions; (2) enhancing the use of financial intelligence by law enforcement authorities and improving disseminations by the FIU; and (3) demonstrating a sustained increase in the number of investigations and prosecutions of different types of ML and TF offences in line with the country’s risk profile.
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 providing its law enforcement agencies involved in TF investigation and prosecution with increased training and resources; and by addressing previously identified technical deficiencies in relation to FATF Recommendations 6 and 7. 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) identifying and investigating TF activities in line