Palestine Monetary Authority

PALESTINE MONETARY AUTHORITY

Circular No. 137/2025 To all banks operating in Palestine Date: Tuesday, October 28, 2025

Subject: High-Risk Countries and Enhanced Monitoring Countries

Enclosed is a copy of the decision issued by the Financial Follow-Up Unit No. (2025/3) regarding High-Risk Countries and Enhanced Monitoring Countries according to 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, 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 Monitoring 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 financial transaction risks, customer risks, and country classification), with enhanced due diligence measures to be applied when high risks are identified.

Supervision Department Palestine Monetary Authority

Copy to: The Approved Financial Follow-Up Unit 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

date of Palestine

Financial Follow-Up Unit State of Palestine

Decision No. (2025/3) issued by the Financial Follow-Up Unit dated October 26, 2025

Regarding the Lists of High-Risk Countries and Enhanced Monitoring Countries

Based on the provisions of Decision No. (39) of 2022 regarding Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) and its amendments, particularly Article (20) and paragraphs (4, 3) of Article (30), and based on the decision of the National Committee for AML/CFT No. (8/ج/2016) issued on December 1, 2016, regarding delegating the Financial Follow-Up Unit to publish the list of high-risk countries periodically issued by the Financial Action Task Force (FATF), and subsequently decided by the Group since February 21, 2020, until October 24, 2025, and further to the decision of the National Committee for AML/CFT No. (ت/2020/5/20) issued on February 24, 2020, regarding High-Risk Countries and Enhanced Monitoring Countries, and subsequently the Financial Follow-Up Unit decision No. (2020/1) dated February 25, 2020, and its subsequent decisions regarding the lists of High-Risk Countries and Enhanced Monitoring Countries.

Based on public interest requirements, the following is decided:

First

List of High-Risk Countries (Black List)

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

Country	Required Measures Regarding Countries
- Democratic People's Republic of Korea (North Korea).	1. Applying pre-financial sanctions in accordance with the provisions of Executive Decree No. (2022/14) regarding the implementation of Security Council resolutions. <br>2. Paying special attention to commercial relations and transactions with those countries, including companies and financial institutions, and applying the following countermeasures: <br>a. Applying enhanced due diligence measures on business relations and transactions with those countries (as part of countermeasures), in proportion to the arising risks, according to the details of Articles (26, 27) of National Committee Instructions No. (4) of 2022, and Articles (24, 25) regarding financial institutions, and Article (3) of National Committee Instructions No. (3) of 2022 regarding specified non-financial businesses and professions.
- Islamic Republic of Iran (Iran).	1. Applying enhanced due diligence measures on business relations and transactions 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 specified non-financial businesses and professions. <br>2. When applying enhanced due diligence measures, it must be ensured that funding flows for humanitarian assistance and legitimate non-profit organization activities and financial transfers are not disrupted.

Second

List of Enhanced Monitoring Countries (Grey List)

Amendment to the list of Enhanced Monitoring Countries (Grey List) stipulated in Unit Decision No. (2025/2), by deleting the following: (Republic of South Africa, Federal Republic of Nigeria, Republic of Mozambique, Burkina Faso), so that the list becomes as shown in the table below, and taking into account concerns regarding deficiencies in the AML/CFT systems of these countries (according to the annex 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	Yemeni Republic (Yemen)

Third

Implementation

All financial institutions and specified 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

Annex: Concerns Regarding Deficiencies in AML/CFT Systems.

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

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

Regarding the Lists of High-Risk Countries and Enhanced Monitoring Countries

Concerns Regarding Deficiencies in AML/CFT Systems in Countries

Part One: Deficiencies through Evaluation Reports (All Countries)

This part explains how to access concerns regarding the AML/CFT and Proliferation Financing (PF) systems for countries listed on the Grey List, as well as all other countries subject to mutual evaluation by the FATF or peer groups. These concerns can be accessed by reviewing the Mutual Evaluation Reports (MERs) and subsequent follow-up reports.

The Mutual Evaluation Reports (MERs) and follow-up reports on the FATF or MENAFATF websites contain all deficiencies and key conclusions regarding the AML/CFT systems of countries on the Enhanced Monitoring List and other evaluated countries, which can be obtained through the following mechanisms:

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

1. Visit 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 using the search window illustrated in the adjacent figure.

B. Access to Mutual Evaluation Reports in Arabic (For countries subject to evaluation by the FATF MENA region group):

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

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Part Two: Implementation of Action Plans to Address Deficiencies

Countries on the Grey List have made high-level political commitments to address strategic deficiencies in AML/CFT systems, and these countries continue to fulfill their obligations to resolve remaining deficiencies.

The items below outline the key pillars that these countries are addressing or have addressed, based on specific deficiencies according to MERs and follow-up reports, which must be considered 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 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