Payment-2025- Circular No. 25 High-Risk Countries and Enhanced Follow-Up Countries

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سلطة النقد الفلسطينية PALESTINE MONETARY AUTHORITY

Circular No. (25/2025) To all payment service companies in Palestine Date: Tuesday, October 28, 2025

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

A copy of the decision issued by the Financial Follow-Up Unit No. (2025/3) concerning High-Risk Countries and Enhanced Follow-Up Countries, in accordance with the list issued by the Financial Action Task Force (FATF), is attached. Accordingly, the necessary legal measures are requested to implement the requirements of the aforementioned decision and the specific measures to be taken, with emphasis on compliance with the following:

1. Taking into account concerns regarding deficiencies in the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) systems in countries classified on the "Grey List" ("Enhanced Follow-Up Countries"), when conducting and updating the self-assessment of AML/CFT 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, customer risks, and country classification), with enhanced due diligence measures to be applied when high risks are identified.

Supervisory Group Palestine Monetary Authority

Copy to: The respected Financial Follow-Up Unit

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Financial Follow-Up Unit State of Palestine

Decision No. (2025/3) Issued by the Financial Follow-Up Unit On 26 October 2025

Concerning the Lists of High-Risk Countries and Enhanced Follow-Up Countries

Based on the provisions of Decision-Law No. (39) of 2022 concerning Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) and its amendments, particularly Article (20) and paragraphs (3, 4) of Article (30), and based on the National AML/CFT Committee Decision No. (8/J/2016) issued on 01 December 2016, regarding the authorization of the Financial Follow-Up Unit to publish the list of high-risk countries periodically issued by the Financial Action Task Force (FATF), and subsequently what has been decided by the Group since 21 February 2020 until 24 October 2025, and further to the National AML/CFT Committee Decision No. (T/2020/5) issued on 24 February 2020 concerning High-Risk Countries and Enhanced Follow-Up Countries, and subsequently the Financial Follow-Up Unit Decision No. (2020/1) dated 25 February 2020 and its subsequent decisions concerning the lists of High-Risk Countries and Enhanced Follow-Up Countries. Based on the requirements of public interest, it is decided as follows:

First List of High-Risk Countries (Black List)

All financial institutions and designated non-financial businesses and professions (DNFBPs) 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 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. Apply enhanced due diligence measures to business relations and transactions with those countries (as part of countermeasures), commensurate with the arising risks, according to Articles (26, 27) of the National Committee's instructions for financial institutions (2022), and Articles (24, 25) of the National Committee's instructions No. (3) for DNFBPs (2022).
Islamic Republic of Iran (Iran).	b. Apply the enhanced due diligence measures mentioned in paragraph (a) above when dealing with any entity acting on behalf of a natural or legal person, including companies or financial institutions operating in those countries. <br> c. Enhance the institution's adopted reporting mechanisms, including increasing cooperation between staff and expediting data provision to the AML/CFT compliance officer within the financial institution or DNFBP, to ensure no transaction suspected of involving money laundering or predicate offenses or terrorism financing is executed, and report such suspicion to the Unit immediately without delay, providing all data related to the attempted transactions, while ensuring reporting confidentiality and non-notification to the client. <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 when taking any due diligence measures towards clients. <br> f. Do not establish any correspondent banking relationships or similar correspondent relationships with financial institutions in those countries.
Union of Myanmar (Myanmar).	1. Apply enhanced due diligence measures to business relations and transactions with Myanmar, commensurate with the risks arising in the country, according to Articles (26, 27) of the National Committee's instructions No. (4) for financial institutions (2022), and Articles (24, 25) of the National Committee's instructions No. (3) for DNFBPs (2022). <br> 2. When applying enhanced due diligence measures, ensure that fund flows for humanitarian assistance and legitimate non-profit organizations' activities and financial transfers are not disrupted.

Second List of Enhanced Follow-Up Countries (Grey List)

The list of Enhanced Follow-Up Countries (Grey List) stipulated in the Unit's Decision No. (2025/2) is amended by deleting South Africa, Mozambique, and Burkina Faso, so that the list becomes as shown in the table below, taking into account concerns regarding deficiencies in the AML/CFT systems of these countries (according to the appendices attached to this decision) when conducting the self-assessment of AML/CFT risks, including identifying, analyzing, and evaluating 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 and designated non-financial businesses and professions must implement the provisions of this decision, which shall take effect from the date of its circular issuance.

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

Attachment: Concerns regarding deficiencies in AML/CFT systems.

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Attached to Financial Follow-Up Unit Decision No. (2025/3) Concerning the Lists of High-Risk Countries and Enhanced Follow-Up Countries

• Part One: Deficiencies through Evaluation Reports (for all countries): This part explains how to access concerns regarding the AML/CFT and Countering Proliferation Financing (CPF) systems of countries listed on the Grey List, as well as all other countries subject to mutual evaluation by FATF or peer groups. These concerns can be accessed by reviewing the relevant mutual evaluation reports and subsequent follow-up reports. The published mutual evaluation reports (MERs) and follow-up reports on the websites of FATF or MENAFATF contain all deficiencies and key conclusions regarding the AML/CFT systems of countries on the Enhanced Follow-Up list and other evaluated countries, which can be obtained according to the following mechanism:

a. Accessing mutual evaluation reports in English (for all countries).

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

b. Accessing mutual evaluation reports in Arabic (for countries evaluated by MENAFATF).

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

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Attached to Financial Follow-Up Unit Decision No. (2025/3) Concerning the Lists of High-Risk Countries and Enhanced Follow-Up Countries

• 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 AML/CFT systems, and these countries continue to implement their commitments to resolve remaining deficiencies. The items below outline the key areas these countries are addressing or have addressed, based on specific deficiencies according to mutual evaluation and follow-up reports, which must be taken into account whether negative or positive:

Country	Key Areas
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) 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- 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 with its risks; and (3) demonstrating effective implementation of TF and PF-related TFS. <br><br> 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	(Statement from June 2025) <br><br> 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 now expired and work remains. The FATF encourages Haiti to continue to implement its action plan to address the above-mentioned strategic deficiencies.
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 conducting sensitization activities and producing guidance on the results of its national risk assessment, increasing the number of disseminations by the FIU, and enhancing interagency cooperation on TF investigations at the border. Kenya should continue to work to implement its FATF action plan to address its strategic deficiencies, including by: (1) improving risk-based AML/CFT supervision of FIs and DNFBPs and adopting a legal framework for the licensing and supervision of VASPs; (2) enhancing the understanding of preventive measures by FIs and DNFBPs, including to increase STR filing and implement TFS without delay; (3) 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; (4) improving the use and quality of financial intelligence products; (5) increasing ML and TF investigations and prosecutions in line with risks; (6) bringing the TFS framework in compliance with R.6 and ensure its effective implementation; and (7) 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	Since February 2025, when Lao PDR made a high-level political commitment to work with the FATF and APG to strengthen the effectiveness of its AML/CFT regime, Lao PDR has taken some steps towards improving its AML/CFT regime, including addressing technical compliance deficiencies in relation to the TF offence (Recommendation 5). Lao PDR should continue to work on implementing its FATF action plan to address its strategic deficiencies, including : (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 that 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 co-operation; (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, confiscate proceeds and instrumentalities of crime in line with the risk profile; (8) monitoring FIs' and DNFBPs' compliance with PF TFS obligations; and (9) addressing technical compliance deficiencies in Recommendations 6, 7, and 10.
Lebanon	(Statement from October 2024) <br><br> In October 2024, Lebanon made a high-level political commitment to work with the FATF and MENAFATF to strengthen the effectiveness of its AML/CFT regime in spite of the challenging social, economic and security situation within the country. Since the adoption of its MER in May 2023, Lebanon has made progress on several of the MER's recommended actions and has applied measures to its financial sector, including through issuing a circular for banks and financial institutions to establish a department dedicated to combating bribery and corruption related crimes and guidance on politically exposed persons, while taking measures against unlicensed financial activity. Lebanon will continue to work with the FATF to implement its FATF action plan by: (1) conducting assessments of specific terrorist financing and money laundering risks identified in the MER and ensuring that policies and measures are in place to mitigate these risks; (2) enhancing mechanisms to ensure the timely and effective execution of requests for mutual legal assistance, extradition and asset recovery; (3) enhancing DNFBP