COSOB Guidelines No. 03-2025 of October 22, 2025, on Freezing and/or Seizure Measures for Targeted Financial Sanctions (Version 0.2)

---

Republic of Algeria Commission for the Organization and Supervision of Stock Exchange Operations Commission d’Organisation et de Surveillance des Opérations de Bourse – COSOB -

COSOB Guidelines No. 03-2025 Issued on

October 22, 2025, Concerning Measures for Freezing and/or Seizure of Funds and Assets

in the Framework of Targeted Financial Sanctions

Issue Number 0.2 October 2025

Introduction:

It is noted that in recent years, there has been a significant increase in threats related to terrorism and its financing, as well as global security threats, particularly the proliferation of weapons of mass destruction. In light of these challenges, the need for international cooperation to enhance mechanisms combating these phenomena has emerged, aiming to adopt comprehensive strategies to dry up the sources of unregulated financing, by disrupting and dismantling terrorist networks.

In this regard, the United Nations and the Security Council have played a pivotal role, issuing a series of binding resolutions requiring member states to take strict measures to freeze funds and prohibit dealings with individuals and entities associated with these activities.

To this end, Algeria has been keen to fulfill its commitments to the international community by updating and developing its legal and institutional frameworks to keep pace with international standards, particularly those issued by the Financial Action Task Force (FATF). Algeria has also adopted local supporting regulations, such as Law No. 05-01 concerning the prevention of money laundering and the financing of terrorism and combating them, alongside the establishment of specialized bodies such as the "Financial Intelligence Processing Unit" to ensure the effective implementation of targeted financial sanctions.

The Commission for the Organization and Supervision of Stock Exchange Operations (COSOB) has issued these Guidelines as part of its efforts to strengthen the Algerian stock market, making it more resistant to exploitation by terrorist groups or entities not intended for legitimate use. It also aims to clarify the procedures to be followed by entities under its supervision and monitoring, in full compliance with local and international laws, while protecting the rights of non-involved parties.

Accordingly, this document has been prepared to serve as a comprehensive reference for regulated entities, containing clear definitions of terms, mechanisms for implementing sanctions, procedures for managing frozen or seized funds, in addition to risk indicators for detecting suspicious activities. In doing so, the Commission for the Organization and Supervision of Stock Exchange Operations contributes effectively to Algeria's efforts, based on its conviction that combating terrorism and its financing is a shared responsibility requiring the convergence of efforts at all levels.

I. Legal and Regulatory References:

• Ordinance No. 66-156 dated 18 Safar 1386 corresponding to June 8, 1966, concerning the Penal Code, amended and supplemented;
• Executive Decree No. 93-109 dated May 23, 1993, concerning the Stock Exchange of Transferable Securities;
• Law No. 05-01 dated 27 Dhu al-Hijjah 1425 corresponding to February 6, 2005, concerning the prevention of money laundering and the financing of terrorism and combating them, amended and supplemented;
• Executive Decree No. 101-25 dated 12 Ramadan 1446 corresponding to March 12, 2025, concerning procedures for the prevention of the financing of terrorism and the financing of the proliferation of weapons of mass destruction;
• Executive Decree No. 102-25 dated 12 Ramadan 1446 corresponding to March 12, 2025, determining the composition, organization, and functioning of the Committee for the Follow-up of Targeted International Sanctions;
• Executive Decree No. 103-25 dated 12 Ramadan 1446 corresponding to March 12, 2025, determining the procedures for registration on the National List of Terrorist Persons and Entities and removal therefrom, and the effects thereof;
• COSOB Regulation No. 01-24 dated 11 Muharram 1446 corresponding to July 17, 2024, concerning the prevention of money laundering, the financing of terrorism, and the financing of the proliferation of weapons of mass destruction and combating them.
• Guidelines issued by the Financial Intelligence Processing Unit concerning measures for the freezing and/or seizure of funds and assets in the framework of targeted financial sanctions.

II. Definitions:

For the purposes of these Guidelines, the following terms are defined as follows:

• 1. Relevant Security Council Resolutions: Resolutions of the United Nations Security Council issued under Chapter VII of the Charter of the United Nations, concerning the fight against terrorism and its financing and the prevention of the proliferation of weapons of mass destruction and its financing. These include in particular Resolutions 1267 (1999) and 1989 (2011) concerning Al-Qaida and Da'esh (ISIS) and associated persons, groups, undertakings, and entities; Resolution 1988 (2001) concerning the Taliban and associated persons, groups, undertakings, and entities; Resolution 1718 (2006); Resolution 1737 (2006); Resolution 1874 (2009); Resolution 2087 (2013); Resolution 2094 (2013); Resolution 2231 (2015); Resolution 2270 (2016); Resolution 2356 (2017); and all current and subsequent relevant resolutions.
• 2. Competent Security Council Committees: Committees established pursuant to Security Council Resolutions 1267 (1999) and 1989 (2011) and 2253 (2015) concerning the Islamic State in Iraq and the Levant (Da'esh), Al-Qaida, and associated individuals, groups, institutions, and entities; the Committee established pursuant to Resolution 1988 (2011) concerning the Taliban; the Committee established pursuant to Resolution 1718 (2006); the Committee established pursuant to Resolution 2231 (2015); and other relevant committees. Also includes the Security Council when acting under Chapter VII of the Charter of the United Nations and adopting targeted financial sanctions to prevent terrorism and its financing and the proliferation of weapons of mass destruction and its financing.
• 3. Consolidated Sanctions List: A list containing the full identity of persons and information regarding all entities and groups concerned by targeted financial sanctions imposed by the United Nations Security Council, related to terrorism and its financing or the prevention of the proliferation of weapons of mass destruction and its financing.
• 4. The Committee: The Committee for the Follow-up of Targeted International Sanctions, established pursuant to Article 20 bis of Law No. 01-05 concerning the prevention of money laundering and the financing of terrorism and combating them, amended and supplemented, placed under the Minister responsible for Foreign Affairs.
• 5. Ombudsman Office: The body established pursuant to Security Council Resolution 1904 (2009) for the purpose of examining requests for the removal of names of persons, entities, institutions, and groups from the sanctions lists imposed on Da'esh and Al-Qaida and considering them.
• 6. Focal Point Center: The center established pursuant to Security Council Resolution 1730 (2006) for the purpose of examining requests for the removal of names of persons, entities, institutions, and groups from Security Council lists, provided that they have not been listed by the Committee for the Follow-up of the Implementation of Sanctions imposed on Da'esh and Al-Qaida.
• 7. Entity: Any association, organization, group, or organization, regardless of its form or name, whose purpose or activities fall under the provisions of Article 87 bis of the Penal Code.
• 8. Without Delay: In all cases, this deadline is set at 24 hours from the issuance of Security Council resolutions related to terrorism and the financing of the proliferation of weapons of mass destruction, as per these Guidelines.
• 9. Targeted Financial Sanctions: Freezing of assets and prohibitions imposed on the Consolidated List, for the benefit of persons, entities, institutions, and groups listed, to prevent the provision of funds, directly or indirectly, to persons and entities.
• 10. Prohibition of Dealings: The prohibition of providing funds or financial or other related services, directly or indirectly, to a person or entity listed on the Consolidated List or entities owned or controlled by them.
• 11. Specialized Body: The Financial Intelligence Processing Unit.
• 12. Freezing and/or Seizure: The temporary imposition of a ban on the transfer, exchange, or disposal of funds, or temporary possession or control of property, based on a judicial or administrative decision.
• 13. Funds: Includes money, assets, and other assets and economic resources, including in particular:

• Money and property: All money and property defined by law.

• Financial or other assets: Any financial or economic assets, including oil and natural resources.

• Economic resources: Assets that can be used to obtain money, goods, or services.

• 14. Exceptional Expenditures: Costs related to public interest or legal services, or expenses associated with the preservation or maintenance of frozen property.
• 15. Basic Needs: Financial amounts allocated to cover basic expenses such as food, clothing, rent, medicine, and utilities.
• 16. Due Payments: Amounts due under a contract or judicial or administrative decision issued before the date of listing.
• 17. Bona Fide Third Parties: Persons who were not subject to investigation or criminal prosecution and hold valid title or possession of the frozen funds.
• 18. Regulated Entities: Stock exchange operators, securities brokers, collective investment scheme management companies, crowdfunding platform managers, investment financing managers, and custodians of securities accounts.

III. Implementation of Targeted Financial Sanctions (UN Security Council Consolidated List):

Algeria has established a clear and organized mechanism for implementing targeted financial sanctions, aiming to ensure the effective implementation of Security Council resolutions concerning the freezing and seizure of funds of persons, groups, and entities listed on international lists. The following details the mechanism:

III-1. Obligation to Consult UN Security Council Lists

Regulated entities are legally obligated, under current legislative and regulatory texts, to permanently review the Consolidated Sanctions List through one of the following sources:

• The Financial Intelligence Processing Unit website (http://www.mf-ctrf.gov.dz)
• The United Nations Security Council website (https://www.un.org/securitycouncil)

This consultation and verification must be performed daily, including weekends and official holidays. The Financial Intelligence Processing Unit works to ensure that updates to the UN Security Council Consolidated List are available on its website, without prejudice to other legal procedures for notification. The official notice from the Unit serves as notification to regulated entities of persons, groups, institutions, and entities listed on the Consolidated List, requiring them to take necessary measures to prohibit the activities of listed persons or entities.

III-2. Notification Mechanisms (for Regulated Entities)

All regulated entities must provide their specific email addresses to the Commission for the Organization and Supervision of Stock Exchange Operations. These addresses are used to receive official notifications regarding the inclusion of names on the Consolidated List or any updates thereto, including amendments, additions, or deletions. These procedures are necessary to ensure the smooth flow of notifications and updates between regulated entities and the Commission for the Organization and Supervision of Stock Exchange Operations.

III-3. Requesting Assistance from the Specialized Body (Unit)

Regulated entities may request direct assistance from the Specialized Body when needed, to ensure the execution of tasks related to freezing and seizure procedures and following up on updates. The Specialized Body provides the necessary support and guidance to ensure full compliance with required procedures, and makes communication means available to regulated entities. The Specialized Body also takes all legal measures to find solutions to issues raised by regulated entities during the implementation of the mechanism. This mechanism aims to create a familiar email communication network between regulated entities and the competent body, ensuring the immediate and accurate flow of notifications regarding the Consolidated Sanctions List. The Specialized Body also provides necessary support to facilitate the implementation of procedures and ensure compliance.

III-4. Obligations of Regulated Entities:

• Immediate Freezing and Seizure of Funds: Upon notification of the Consolidated Sanctions List or any updates thereto (addition, deletion, or modification of names) on the website, regulated entities are obligated to take immediate measures to prohibit any activity related to listed persons or entities. These measures must be implemented without delay, including on weekends and official holidays, to ensure uninterrupted execution of decisions. These measures include freezing or seizing funds owned or controlled by listed persons or entities, preventing them from using or disposing of these funds.

• Regular Verification of Lists: Regulated entities must constantly and continuously ensure that persons or entities listed on the Consolidated Sanctions List are not among their clients, do not hold funds on their behalf, or are not beneficiaries. If a client's, principal's, or beneficial owner's name is found on the Consolidated Sanctions List, they must be immediately reported to the Specialized Body and the Commission for the Organization and Supervision of Stock Exchange Operations without delay or prior notice. Regulated entities are required to regularly check lists and perform accurate checks on listed names, including new clients and potential beneficial owners.

• Immediate Freezing or Seizure of Funds Upon Match: If a match is found with listed names on the Consolidated Sanctions List, regulated entities must freeze or seize funds without delay, respecting the rights of bona fide third parties. In this case, the Commission for the Organization and Supervision of Stock Exchange Operations and the Specialized Body must be notified immediately.

• Verification at Establishment of New Business Relationships: When establishing a business relationship with new clients or conducting an occasional financial transaction, regulated entities must verify that these clients or transaction beneficiaries are not included in the Consolidated Sanctions List. If it is determined that a client or beneficiary is listed, the regulated entity must refrain from completing the transaction immediately, freeze or seize received funds, and notify the Specialized Body and the Commission for the Organization and Supervision of Stock Exchange Operations immediately.

• Prohibition of Providing Financial Services or Economic Resources: Regulated entities are prohibited from providing any funds, economic resources, financial services, or other related services to listed persons or entities, whether directly or indirectly, alone or in collaboration with other parties. This includes funds derived from or generated by assets owned by listed persons, groups, institutions, or entities, as well as entities controlled or directed by them, whether directly or indirectly, and entities acting on behalf of or directed by listed persons, groups, institutions, or entities. This prohibition applies unless a license or authorization is granted by competent authorities, except in cases permitted by Security Council resolutions.

• Allowing Addition of Interest and Profits to Frozen Amounts: Adding interest, profits, or other due revenues to frozen accounts is permitted, provided that these funds remain subject to the same freezing provisions stipulated.

• Lifting of Freezing of Funds: If a person's or entity's name is removed from the Consolidated Sanctions List, the freezing or seizure of their funds must be lifted immediately and in the same manner. Subsequently, dealings with the funds may be permitted upon receipt of confirmation to that effect.

• Notification to Specialized Body and COSOB: Regulated entities must notify the Specialized Body and the Commission for the Organization and Supervision of Stock Exchange Operations (within 24 hours) of the freezing or seizure of funds. Notifications must include details of frozen funds, their type, value, and date of freezing, or lifting of freezing. Any measures taken, including attempts to execute transactions, must be reported.

Regulated entities must also notify the Specialized Body and COSOB if it is determined that one of their clients, previous clients, principals, or beneficial owners is listed on the Consolidated Sanctions List.

When attempting to execute any transaction for the benefit of a person or entity listed on the Consolidated Sanctions List, in addition to the aforementioned notification, the funds related to the execution of the transaction must be frozen and/or seized.

Regulated entities must also notify if there is suspicion that one of their previous clients, principals, or beneficial owners is listed on the Consolidated Sanctions List.

Requests to lift freezing and/or seizure due to name similarity or lack of available information can be accessed.

• Establishing Internal Controls and Procedures: Regulated entities must prepare and implement internal controls and procedures ensuring effective and continuous compliance with the mechanism resulting from the Consolidated Sanctions List. These procedures include a financial monitoring system and customer identity verification to ensure they are not associated with persons or entities listed on the List.

• Establishing Strict Policies Regarding Notification: Regulated entities must establish clear and strict policies prohibiting users from notifying clients or other parties that freezing or seizure measures or related measures will be applied. This policy aims to maintain the confidentiality of procedures and prevent any attempt to evade or manipulate funds or economic resources.

• Cooperation with Competent Authorities: Regulated entities must cooperate fully with the Specialized Body and the Commission for the Organization and Supervision of Stock Exchange Operations to verify the accuracy of provided information and ensure the effective implementation of required procedures. This cooperation includes providing necessary documents and reports and responding immediately to any inquiries or requests from the Commission for the Organization and Supervision of Stock Exchange Operations and the Specialized Body.

• Respecting the Rights of Bona Fide Third Parties: Any measures taken under this mechanism must ensure that the rights of bona fide third parties are not violated.

III-5. Measures Concerning the Management of Frozen and Seized Funds:

Any frozen or seized funds reported by regulated entities must be reported to the Minister responsible for Finance immediately by the Specialized Body to take appropriate measures.

• Decisions of the Minister Responsible for Finance: The Minister responsible for Finance may issue decisions, including in particular:

• Determining the entity responsible for managing frozen or seized funds.

• Authorizing the use of part of the funds to cover basic or exceptional needs of listed individuals, according to specific procedures.

• Authorizing the payment of due payments related to contracts or agreements concluded before the imposition of sanctions, according to detailed procedures.

• Procedures for Payment of Due Amounts: For individuals or entities listed pursuant to Security Council Resolutions 1718 (2006) or 2231 (2015), due payments may be settled provided that:

• Prior notice is sent to competent Security Council authorities 10 days before payment.

For persons, groups, institutions, and entities listed pursuant to Resolution 1737 (2006) and other resolutions adopted under or pursuant to Resolution 2231 (2015), or listed under Resolution 2231 (2015) itself, payment is made according to conditions including:

• The contracts are not related to any prohibited activities or materials subject to restrictions under Security Council Resolution 2231 (2015) and any subsequent resolutions.
• The payment does not directly or indirectly benefit the person, group, or entity subject to measures in paragraph 2 of the Annex to UN Security Council Resolution 2231 (2015).
• Coordination with the Ministry responsible for Foreign Affairs to notify competent Security Council authorities of the intention to allow or authorize the payment of due amounts or to lift freezing and/or seizure of funds for the same purposes, at least 10 working days before the date of authorization.

For due payments based on a contract or judicial decision prior to Security Council Resolution 1718 (2006) and any subsequent resolutions, payment is made provided that:

• It is proven that the contract or decision predates Security Council Resolution 1718 (2006) or any subsequent resolutions.
• It is proven that the contract or decision does not benefit any person, group, institution, or entity specified by Security Council Resolution 1718 (2006) and any subsequent resolutions, or any other person, group, institution, or entity specified by competent Security Council authorities established under Resolution 1718 (2006).
• Coordination with the Ministry responsible for Foreign Affairs to notify competent Security Council authorities of the intention to allow or authorize the payment of due amounts or to lift freezing and/or seizure of funds for the same purposes, at least 10 working days before the date of authorization.

III-6. Measures Concerning the Prohibition of Activities and Financing:

• Prohibition of Activities: Persons or entities listed on the Sanctions List are prohibited from engaging in any activity whatsoever. If the entities are associations, their activity is suspended during the listing period, unless a judicial decision states otherwise.

• Prohibition of Providing Financing and Services: Regulated entities are prohibited from making funds, financial services, or economic resources available to listed persons or entities, whether directly or indirectly. This prohibition includes entities owned or controlled by listed persons or entities acting on their behalf.

• Use of Frozen Funds: Requests may be submitted to the Specialized Body to obtain permission to use part of the funds to cover basic or exceptional expenses, from the listed person, group, or entity or their representative. The request must be accompanied by all necessary documents and evidence, specifying the amounts to be used. The necessary documents for the request are submitted to the Minister responsible for Finance for consideration.

If the Minister responsible for Finance decides to reject the request, a reasoned decision is issued, and the Specialized Body notifies the applicant. The rejection decision can be appealed before the competent judicial authorities.

If the Minister responsible for Finance decides to accept the request, the following procedures are followed:

• If the request concerns covering basic needs, the Minister responsible for Finance, in coordination with the Ministry responsible for Foreign Affairs, notifies competent Security Council authorities. The request is approved only after receiving a notification from the Minister responsible for Finance indicating no objection from competent Security Council authorities. The applicant is notified through the Specialized Body.
• If the request concerns exceptional expenditures, the Minister responsible for Finance, in coordination with the Ministry responsible for Foreign Affairs, notifies competent Security Council authorities. The request is approved only after receiving a notification from the Minister responsible for Finance indicating no objection from competent Security Council authorities. The applicant is notified through the Specialized Body.

In case of acceptance, the Minister responsible for Finance issues a decision. The entity holding the frozen and/or seized funds is notified of the Minister's decision and must take necessary measures to implement its provisions.

In all cases where the request is accepted, the entity holding the frozen and/or seized funds must notify the Specialized Body of the measures taken to implement the Minister's decision within 3 working days from the date of execution.

• Management of Frozen Funds: Frozen funds in bank accounts and securities accounts are transferred to the Central Treasury to be accurately registered in the Central Treasury's records. These funds remain frozen until an official decision to lift the freezing is issued by competent authorities. Active management is required until the lifting of freezing.

III-7. Procedures for Submitting Delisting Requests:

Persons, groups, institutions, or Algerian entities listed on the UN Security Council lists may submit delisting requests to the Ombudsman Office, the Focal Point Center, or the Specialized Body. The request must be accompanied by all information and documents supporting the request.

• In case the request is submitted to the Specialized Body: Upon receipt of the delisting request, the Body transfers it to the competent Committee (placed under the Minister responsible for Foreign Affairs, responsible for following up on relevant Security Council resolutions and lists resulting from their application). The Committee refers the request to the Rapporteur, in coordination with the Ministry responsible for Foreign Affairs, along with its opinion on the merit of the request. The Committee may also submit a delisting request on its own initiative or based on available cases. In cases of death, the Committee, in coordination with the Ministry of Foreign Affairs, may submit delisting requests for Algerians, provided that documents supporting the death and the status of heirs are attached. The Committee may also remove names of entities that are no longer listed or have no active activity.

• Response and Notification: The Committee notifies the Specialized Body immediately upon receiving the response from competent Security Council authorities. The Specialized Body also notifies the applicant and regulated entities of the legal procedures of the Security Council resolution upon receipt from the Committee.

III-8. Processing Requests to Lift Freezing or Seizure Due to Name Similarity:

• Procedures for Submitting the Request: Persons, groups, institutions, or entities whose names match those listed on Security Council lists may submit a request to lift freezing or seizure to the Specialized Body. The request can also be submitted to the Ombudsman Office or the Focal Point Center. Requests must be accompanied by supporting information and are referred immediately to the Committee for consideration within 10 working days.

• Request Processing Mechanism: ✓ In case of Approval: The Committee notifies the Specialized Body immediately upon approval. The Specialized Body notifies the applicant and competent authorities of the lifting of freezing of funds or economic assets in their possession. Competent authorities are obligated to notify the Specialized Body within 3 working days of the measures taken to lift the freezing.

✓ In case of Lack of Information: The Specialized Body requests...