Palestine Monetary Authority

PALESTINE MONETARY AUTHORITY

Circular No. (2024/110)

To all banks operating in Palestine
Date: Wednesday, October 30, 2024

Subject: High-Risk Jurisdictions and Jurisdictions Under Enhanced Monitoring

Attached is a copy of the decision issued by the Financial Follow-up Unit No. (2024/3) dated 27/10/2024 regarding High-Risk Jurisdictions and Jurisdictions Under Enhanced Monitoring according to the list issued by the Financial Action Task Force (FATF). Accordingly, it is requested to take the necessary legal measures 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. Take into account concerns regarding deficiencies in anti-money laundering and counter-terrorist financing systems in countries classified on the "Grey List" (Jurisdictions Under Enhanced Monitoring), when conducting and updating the self-assessment of money laundering and terrorist financing risks.

2. Apply the Risk-Based Approach (RBA), such that the application of due diligence measures is proportional to (risk analysis results, nature of the financial transaction risk, customer risk, and country classification), with enhanced due diligence measures to be exercised 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 P.O. Box - Palestine Postal Code: P6160675 | Phone: +970 2 2415251 | Fax: +970 2 2415310 | info@pma.ps

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Financial Follow-up Unit

State of Palestine

Decision No. (2024/3)

Issued by the Financial Follow-up Unit
On 27/10/2024

Regarding lists of High-Risk Jurisdictions and Jurisdictions Under Enhanced Monitoring

Based on the provisions of Law No. (39) of 2022 regarding the combating of money laundering and terrorist financing and its amendments, particularly the provisions of Article (20) and paragraphs (4, 3) of Article (30), and based on the decision of the National Committee for Combating Money Laundering and Terrorist Financing No. (8/J) issued on 01/12/2016, regarding the delegation of the Financial Follow-up Unit to publish the list of high-risk jurisdictions issued periodically by the Financial Action Task Force (FATF), and subsequently as determined by the Group since 21/02/2020, until 25/10/2024, and in addition to the decision of the National Committee for Combating Money Laundering and Terrorist Financing No. (t/2020/5) issued on 24/02/2020 regarding High-Risk Jurisdictions and Jurisdictions Under Enhanced Monitoring, and subsequently to the Financial Follow-up Unit decision No. (2020/1) dated 25/02/2020 and subsequent decisions regarding lists of High-Risk Jurisdictions and Jurisdictions Under Enhanced Monitoring.

And based on the requirements of public interest, the following is decided:

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 apply the following procedures towards high-risk jurisdictions:

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 countermeasures: <br> a. Take enhanced due diligence measures on business relations and transactions with those countries (as part of countermeasures), and in proportion 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).	1. Apply enhanced due diligence measures on business relations and transactions with Myanmar, and in proportion 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, it must be ensured 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 Monitoring (Grey List)

Amend the list of Jurisdictions Under Enhanced Monitoring (Grey List) included in the Unit's decision No. (2024/2) by adding (Lebanon, Algeria, Angola, Côte d'Ivoire), and deleting (Senegal), so that the list becomes as in the table below, and take into account concerns regarding deficiencies in anti-money laundering and counter-terrorist financing systems for these countries according to the attachment attached to this decision when conducting the self-assessment of money laundering and terrorist 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	Bulgaria	15	Republic of Namibia
4	Burkina Faso	16	Republic of Nigeria
5	Cameroon	17	Republic of the Philippines
6	Côte d'Ivoire (Ivory Coast)	18	Republic of South Africa
7	Croatia	19	Republic of South Sudan
8	Democratic Republic of the Congo	20	Syrian Arab Republic (Syria)
9	Republic of Haiti	21	Republic of Tanzania
10	Republic of Kenya	22	Venezuela
11	Republic of Lebanon	23	Vietnam
12	Republic of Mali	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 circular.

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

Attachment: Concerns regarding deficiencies in anti-money laundering and counter-terrorist financing systems.

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
Phone: +970 22422551\2 Fax: +970 22422553

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Attachment to Financial Follow-up Unit Decision No. (2024/3)

Regarding lists of High-Risk Jurisdictions and Jurisdictions Under Enhanced Monitoring

Concerns regarding deficiencies in anti-money laundering and counter-terrorist financing systems in countries

Part One: Deficiencies through Assessment Reports (All Countries)

This section explains how to access concerns regarding the anti-money laundering and counter-terrorist financing and proliferation financing systems of countries listed on the Grey List, as well as all other countries undergoing mutual evaluation by the Financial Action Task Force 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.

Mutual evaluation reports (MERs) and follow-up reports on the website of the Financial Action Task Force or the Middle East and North Africa Financial Action Task Force (MENAFATF) contain all deficiencies and key conclusions regarding the anti-money laundering and counter-terrorist financing systems in countries listed on the Enhanced Monitoring List and all other countries that have undergone assessment. Those can be obtained according to the following mechanisms:

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 Evaluation Reports
4. Search for the country name in English in the search window.

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

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

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Attachment to Financial Follow-up Unit Decision No. (2024/3)

Regarding lists of High-Risk Jurisdictions and Jurisdictions Under Enhanced Monitoring

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 anti-money laundering and counter-terrorist financing 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
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. Since the adoption of its MER in June 2023, Angola has made progress on some of the MER's recommended actions including enhancing national cooperation and coordination, international cooperation and the use of financial intelligence by competent authorities. Angola 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 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.

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Attachment to Financial Follow-up Unit Decision No. (2024/3)

Regarding lists of High-Risk Jurisdictions and Jurisdictions Under Enhanced Monitoring

Country	Key Pillars
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 demonstrating initial implementation of its national action plan for its AML/CFT Strategy; demonstrating initial implementation of risk-based supervision for postal money operators, currency exchange providers and real estate agents and ensuring that confiscation is pursued as a policy objective. 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) ensuring that the beneficial ownership information held in the Register is accurate and up-to-date; (3) improving investigations and prosecutions of different types of money laundering in line with risks, including high-scale corruption and organised crime; (4) ensuring the ability to conduct parallel financial investigations in all terrorism investigations; (5) addressing gaps in the PF TFS frameworks; and (6) identifying the subset of non-profit organisations (NPOs) most vulnerable to TF abuse and demonstrating initial implementation of risk-based monitoring to prevent abuse for TF purposes.
Burkina Faso	Since February 2021, when Burkina Faso made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime, Burkina Faso has taken steps towards improving its AML/CFT regime, including by strengthening supervision of financial institutions and designated non-financial businesses and professions, establishing a system to provide access to competent authorities of accurate and up-to-date beneficial ownership information, and implementing a framework for the monitoring of the activities of NPOs at risk of TF abuse. Burkina Faso should continue to work on implementing its action plan to address its remaining strategic deficiency, by: implementing an effective targeted financial sanctions regime related to TF and PF. The FATF notes Burkina Faso's continued progress across its action plan, however all deadlines have expired and work remains. The FATF urges Burkina Faso to swiftly implement its action plan to address the above-mentioned strategic deficiency as soon as possible as all deadlines expired in December 2022.
Cameroon	In June 2023, Cameroon made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime. Cameroon should continue working on implementing its action plan to address its strategic deficiencies, including by: (1) aligning AML/CFT national strategies and policies with the findings of the NRA and monitoring their implementation, and demonstrating AML/CFT cooperation and coordination between competent authorities; (2) ensuring risk-based prioritisation of incoming international

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Attachment to Financial Follow-up Unit Decision No. (2024/3)

Regarding lists of High-Risk Jurisdictions and Jurisdictions Under Enhanced Monitoring

Country	Key Pillars
Cameroon	cooperation requests in line with risks and responding in an effective manner; (3) enhancing risk-based supervision of banks and implementing effective risk-based supervision for non-bank FIs and DNFBPs, and conducting appropriate outreach to high-risk FIs and DNFBPs; (4) maintaining and ensuring timely access by competent authorities to adequate and up to date beneficial ownership information on legal persons, and establishing a sanctions regime for violations of transparency obligations applicable to legal persons; (5) 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; (6) demonstrating that authorities are able to conduct a range of ML investigations, and prosecute ML in line with risks; (7) 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; (8) demonstrating that TF investigations and prosecutions are pursued in line with risk; and (9) 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	In October 2024, 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. Since the adoption of its MER in June 2023, Côte d’Ivoire has made significant progress on many of the MER's recommended actions including by strengthening its legal AML/CFT framework through several important legislative and regulatory amendments, updating ML/TF analysis by drafting typology reports on the highest risk predicate offences, strengthening the human and technical resources of the FIU and prosecutors, and operationalising the agency in charge of the management of assets seized and confiscated. Côte d’Ivoire will continue to work with the FATF to implement its FATF action plan 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; (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 ML and TF investigations and prosecutions of different types in line with the country’s risk profile; and (6) strengthening the targeted financial sanctions framework.