Palestine Monetary Authority

Circular No. (2/2025)

To all bankers working in Palestine

Date: Thursday, February 27, 2025

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

Attached is a copy of the decision issued by the Financial Follow-Up Unit No. (2025/1) dated 23/02/2025 regarding High-Risk Countries and Countries Under Enhanced Follow-Up 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 measures to be taken specifically, 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 within the "Grey List" (Countries Under Enhanced Follow-Up), 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 procedures is proportional to (risk analysis results, nature of the financial transaction risk, customer risks, and country classification), with enhanced due diligence measures to be taken when high risks are perceived.

Supervision Group
Palestine Monetary Authority

Copy: To the esteemed gentlemen/ 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

Decision No. (1/2025)
Issued by the Financial Follow-Up Unit
Dated 23/02/2025

Regarding Lists of High-Risk Countries and Countries Under Enhanced Follow-Up

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 (3, 4) of Article (30), and based on the decision of the National Committee for Combating Money Laundering and Terrorist Financing No. (8/J/2016) issued on 01/12/2016, regarding the delegation to the Financial Follow-Up Unit to list high-risk countries issued periodically by the Financial Action Task Force (FATF), and subsequently decided by the Group since 21/02/2020, until 21/02/2025, 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 Countries and Countries Under Enhanced Follow-Up, and subsequently to the Financial Follow-Up Unit Decision No. (1/2020) dated 25/02/2020 and subsequent decisions regarding lists of high-risk countries and countries under enhanced follow-up.

And 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 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 provisions of Executive Decree No. (2022/14) regarding the implementation of Security Council resolutions.; 2. Pay special attention to commercial relations and transactions with those countries, including companies and financial institutions, and apply the following counter-measures:; a. Take enhanced due diligence measures on business relations and operations with those countries (as part of counter-measures), and in proportion to the risks arising therein, 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 Designated Non-Financial Businesses and Professions.

| Islamic Republic of Iran (Iran). | b. Apply the enhanced due diligence measures referred to in paragraph (a) of this item when dealing with any entity acting on behalf of a natural or legal person, including companies or financial institutions operating in those countries.; c. Enhance the reporting mechanisms adopted by the financial institution or one of the designated non-financial businesses and professions, including increasing cooperation between employees and the rapid provision of data to the money laundering and terrorist financing compliance officer within the financial institution or one of the designated non-financial businesses and professions, to ensure that no transaction or operation suspected of involving money laundering or one of the predicate offenses associated with it or terrorist financing is executed, and to report such suspicion to the Unit immediately and without delay, providing it with all data related to the attempt to conclude such operations, while ensuring the confidentiality of the report and not notifying the customer.; d. Do not establish branches, representative offices, or subsidiaries in those countries.; e. Do not rely on third parties located in those countries in taking any due diligence measures regarding customers.; f. Do not establish any banking relationships or similar correspondent relationships with financial institutions in those countries. |

| Republic of the Union of Myanmar (Myanmar). | 1. Apply enhanced due diligence measures on business relations and operations with Myanmar, and 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 Designated Non-Financial Businesses and Professions.; 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 Countries Under Enhanced Follow-Up (Grey List)

Amend the list of Countries Under Enhanced Follow-Up (Grey List) stipulated in the Unit's Decision No. (3/2024) by adding both (the Lao People's Democratic Republic (Laos), and the Federal Democratic Republic of Nepal (Nepal)), and removing (the Republic of the Philippines), so that the list becomes as in the table below, and taking into account concerns regarding deficiencies in anti-money laundering and counter-terrorist financing systems, when conducting the self-assessment of money laundering and terrorist financing risks.

No.	Country Name	No.	Country Name
1	Algeria	14	Monaco
2	Angola	15	Republic of Mozambique
3	Bulgaria	16	Republic of Namibia
4	Burkina Faso	17	Federal Democratic Republic of Nepal (Nepal)
5	Cameroon	18	Republic of Nigeria
6	Côte d'Ivoire (Ivory Coast)	19	Republic of South Africa
7	Croatia	20	Republic of South Sudan
8	Democratic Republic of the Congo	21	Syrian Arab Republic (Syria)
9	Republic of Haiti	22	Republic of Tanzania
10	Republic of Kenya	23	Venezuela
11	Lao People's Democratic Republic (Laos)	24	Vietnam
12	Republic of Lebanon	25	Republic of Yemen (Yemen)
13	Republic of Mali	-	-

Third

Implementation

All financial institutions and designated non-financial businesses and 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 Murad

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

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Concerns Regarding Deficiencies in Anti-Money Laundering and Counter-Terrorist Financing Systems

Attached to Financial Follow-Up Unit Decision No. (1/2025)

Regarding Lists of High-Risk Countries and Countries Under Enhanced Follow-Up

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 system and proliferation financing in countries listed on the Grey List; in addition to all other countries subject to mutual evaluation by the Financial Action Task Force or regional groups. Those concerns can be accessed through mutual evaluation reports of those countries, and follow-up reports for this report.

Mutual evaluation reports (mutual evaluation reports) and published follow-up reports on the website of the Financial Action Task Force or the Financial Action Task Force of the Middle East and North Africa region contain all deficiencies and main conclusions regarding the anti-money laundering and counter-terrorist financing system in countries listed on the enhanced follow-up list and all other countries that have undergone evaluation. Those can be obtained according to the following mechanisms:

1. Access to mutual evaluation reports in English (all countries):

   • Enter the website: www.fatf-gafi.org
   • From the Topics menu, select (Mutual Evaluations)
   • Select Mutual Evaluations Reports
   • Search for the country name in English in the search window shown in the image on the side.

2. Access to mutual evaluation reports in Arabic (for countries subject to evaluation by the Financial Action Task Force of the Middle East and North Africa):

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

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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 related to anti-money laundering and counter-terrorist financing systems, and those countries are still fulfilling their commitments to address remaining deficiencies. The items below outline the key axes that those countries are working to address or have addressed, which depend on specific deficiencies according to mutual evaluation reports and follow-up reports, where they must be taken into account whether negative or positive:

Country	Key Axes
Algeria	(Statement from October 2024); 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	(Statement from October 2024); 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.

Bulgaria	Since October 2023, when Bulgaria made a high-level political commitment to work with the FATF and MONEVAL to strengthen the effectiveness of its AML/CFT regime, Bulgaria has taken steps towards improving its AML/CFT regime, including by ensuring that the beneficial ownership information held in its Register is accurate and up-to-date and by identifying the subset of non-profit organisations (NPOs) most vulnerable to TF abuse. 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) improving investigations and prosecutions of different types of money laundering in line with risks, including high-scale corruption and organised crime; (3) ensuring the ability to conduct parallel financial investigations in all terrorism investigations; (4) addressing gaps in the PF TFS frameworks; and (5) demonstrating initial implementation of risk-based monitoring of NPOs to prevent abuse for TF purposes.
Burkina Faso	In February 2021, 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 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 has taken steps to improve its AML/CFT regime by aligning AML/CFT national strategies and policies with the findings of the NRA; demonstrating AML/CFT cooperation and coordination between competent authorities; improving risk-based prioritisation of incoming international cooperation, and establishing a regime for violations of transparency obligations applicable to legal persons. 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) maintaining and ensuring timely access by competent authorities to adequate and up to date beneficial ownership information on legal persons; (3) 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; (4) demonstrating that authorities are able to conduct a range of ML investigations, and prosecute ML in line with risks; (5) 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; (6) demonstrating that TF investigations and prosecutions are pursued in line with risk; and (7) demonstrating effective implementation of