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2026-02-19

Added 2026-09-01

Circular No. 8 High-Risk Countries and Countries Under Enhanced Monitoring

The Palestine Monetary Authority requires financial institutions and designated non-financial businesses and professions to implement enhanced due diligence and counter-measures regarding North Korea, Iran, and Myanmar, and to consider deficiencies in the AML/CFT systems of countries on the enhanced monitoring list during self-assessments. The Financial Follow-Up Unit's Decision No. (2026/1) updates the enhanced monitoring list by adding Kuwait and Papua New Guinea, bringing the total to 22 countries, and mandates compliance with these measures effective upon issuance.

Palestine

Palestine Monetary Authority

Palestine Monetary Authority

(2026/8) Circular No. To all bankers working in Palestine Date: Wednesday, 18 February 2026

Subject: High-Risk Countries and Countries Under Enhanced Monitoring

Attached is a copy of the decision issued by the Financial Follow-Up Unit No. (2026/1) regarding High-Risk Countries and Countries Under Enhanced Monitoring in accordance with 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:

Take into account concerns regarding deficiencies in the anti-money laundering and counter-terrorist financing systems in countries classified on the "Grey List" (Countries Under Enhanced Monitoring), when conducting and updating the self-assessment of money laundering and terrorist financing risks.
Apply the Risk-Based Approach (RBA), such that the application of due diligence procedures is proportional to (risk analysis results, nature of financial transaction risks, currency risks, and country classification), with enhanced due diligence measures to be taken when high risks are identified.

Supervision Group Palestine Monetary Authority

Copy: The respected gentlemen / Financial Follow-Up Unit

www.pma.ps

Financial Follow-Up Unit

State of Palestine

دولة فلسطين وحدة المتابعة المالية

Decision No. (2026/1) Issued by the Financial Follow-Up Unit On 15/02/2026

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

Based on the provisions of Decision-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 publish the list of high-risk countries issued periodically by the Financial Action Task Force (FATF), and subsequently what was decided by the Group since 21/02/2020, until 13/02/2026, and in addition to the decision of the National Committee for Combating Money Laundering and Terrorist Financing No. (T/2020/5/T) issued on 24/02/2020 regarding High-Risk Countries and Countries Under Enhanced Monitoring, and subsequently the Financial Follow-Up Unit Decision No. (2020/1) dated 25/02/2020 and subsequent decisions regarding lists of High-Risk Countries and Countries Under Enhanced Monitoring.

And based on the requirements of public interest, it has been decided as follows:

First

List of High-Risk Countries (Black List)

All financial institutions, businesses, and designated non-financial professions in the State of Palestine must continue to apply the following procedures towards high-risk countries:

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 counter-measures:<br>a. Take enhanced due diligence measures on business relations and transactions with those countries (as part of counter-measures), in proportion to the risks arising therein, according to the details of Articles (26, 27) of the National Committee Instructions No. (4) of 2022 regarding financial institutions, and Articles (24, 25) of the National Committee Instructions No. (3) of 2022 regarding designated non-financial businesses and professions.
- Islamic Republic of Iran

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. 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 transactions with those countries (as part of counter-measures), in proportion to the risks arising therein, according to the details of Articles (26, 27) of the National Committee Instructions No. (4) of 2022 regarding financial institutions, and Articles (24, 25) of the National Committee Instructions No. (3) of 2022 regarding designated non-financial businesses and professions.

- Islamic Republic of Iran

FINANCIAL FOLLOW-UP UNIT الوحدة المالية للمتابعة

1/3

State of Palestine – Al Bireh P.O.Box 3981 دولة فلسطين - البيرة ص.ب: 3981 Tel: +970 224225512 | Fax: +970 22422553 | +970 22422553 | فاكس | +970 224225512 | هاتف E-mail: info@ffu.ps | www.ffu.ps

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

Financial Follow-Up Unit

State of Palestine وحدة المتابعة المالية date of Palestine

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 expediting the 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 transactions, 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 to take any due diligence measures towards customers.

f. Do not establish any correspondent banking relationships or similar correspondent relationships with financial institutions in those countries.

1. Apply 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 the National Committee Instructions No. (4) of 2022 regarding financial institutions, and Articles (24, 25) of the 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, especially regarding earthquake relief efforts in Myanmar.

Union of Myanmar (Myanmar)

Second

List of Countries Under Enhanced Monitoring (Grey List)

Amendment of the list of Countries Under Enhanced Monitoring (Grey List) stipulated in the Unit's Decision No. (2025/3) by adding both (State of Kuwait, and Papua New Guinea), so that the list becomes as in the table below, and taking into account the concerns regarding

Deficiencies in Anti-Money Laundering and Counter-Terrorist Financing Systems for these Countries (according to the attached annex to this decision) when conducting the self-assessment of money laundering and terrorist financing risks, including identifying, analyzing, and assessing those risks.

No.	Country Name	No.	Country Name
1	Algeria	12	Republic of Lebanon
2	Angola	13	Monaco
3	Bolivia	14	Republic of Namibia
4	Bulgaria	15	Federal Democratic Republic of Nepal (Nepal)
5	Cameroon	16	Papua New Guinea
6	Côte d’Ivoire (Ivory Coast)	17	Republic of South Sudan
7	Democratic Republic of the Congo	18	Syrian Arab Republic (Syria)
8	Republic of Haiti	19	Venezuela
9	Republic of Kenya	20	Vietnam
10	State of Kuwait	21	Faroe Islands (United Kingdom)
11	Lao People's Democratic Republic (Laos)	22	Republic of Yemen (Yemen)

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 Mawad 15/02/2026

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

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

Attached to Financial Follow-Up Unit Decision No. (2026/1) Regarding lists of High-Risk Countries and Countries 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, counter-terrorist financing, and counter-proliferation financing systems of countries listed on the Grey List, as well as all other countries subject to mutual evaluation by the Financial Action Task Force or regional 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 and 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 contain all deficiencies and key conclusions regarding the anti-money laundering and counter-terrorist financing systems of countries listed on the enhanced monitoring list and all other countries that have undergone evaluation. Those can be obtained according to the following mechanism:

a. 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 shown beside.

b. 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.

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 their 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 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. At its February 2026 Plenary, the FATF made the initial determination that Algeria has substantially completed its action plan and warrants an on-site assessment to verify that the implementation of AML/CFT reforms has begun and is being sustained, and that the necessary political commitment remains in place to sustain implementation in the future. Algeria has made the following reforms: (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. 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	Since June 2025, when Bolivia made a high-level political commitment to work with the FATF and GAFILAT to strengthen the effectiveness of its AML/CFT regime, Bolivia has taken steps to improve its AML/CFT regime by ensuring that beneficial ownership information is accurate and up-to-date. Bolivia should continue working 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 breaches to beneficial ownership obligations are

Attached to Financial Follow-Up Unit Decision No. (1/2026) Regarding lists of High-Risk Countries and Countries Under Enhanced Monitoring


	sanctioned; and (4) increasing ML investigations and prosecutions in line with the country’s risks (including other high-risk predicates in addition to corruption and drug trafficking).
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 addressing remaining technical compliance deficiencies including in relation to confiscation and 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 to address its remaining strategic deficiency in relation to improving investigations and prosecutions of different types of money laundering in line with risks, including high-scale corruption and organised crime. The FATF encourages Bulgaria to build on its recent progress and continue to implement its action plan to address the above-mentioned strategic deficiency as soon as possible.
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 designating an authority for AML/CFT supervision of all DNFBPs and by effectively conducting a range of investigations, including conducting parallel financial investigations and seeking international cooperation, and prosecute ML in line with risks. Cameroon should continue working on implementing its FATF 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) 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; (4) 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 improving the implementation of risk-based supervision of financial institutions and designated non-financial businesses and professions, enhancing the use of


	financial intelligence by law enforcement authorities and improving disseminations by the FIU and demonstrating a sustained increase in the number of TF investigations and prosecutions in line with the country’s risk profile. Côte d’Ivoire should continue working on implementing its FATF action plan to address its strategic deficiencies, including by demonstrating a sustained increase in the number of investigations and prosecutions of different types of ML 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 developing risk-based supervision plans for financial institutions and designated non-financial businesses and professions, addressing most technical compliance deficiencies with R.5, 10, 11 and 20, demonstrating its ability to conduct effective ML investigations and prosecutions and demonstrating effective implementation of TF and PF-related TFS. The DRC should continue to work to implement its FATF action plan to address its strategic deficiencies, including by: (1) implementing its risk-based supervision plan; and (2) identifying and investigating TF activities in line with its risks. <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	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.

Attached to Financial Follow-Up Unit Decision No. (2026/1) Regarding lists of High-Risk Countries and Countries Under Enhanced Monitoring


	The FATF notes Haiti’s continued progress across its action plan, however all deadlines have 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 strengthening the capacities of AML/CFT supervisors, adopting a legal framework for the licensing and supervision of virtual assets service providers and demonstrating a sustained increase in TF investigations and prosecutions in line with the country’s risk profile. 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; (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 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.
Kuwait	In February 2026, Kuwait 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 MER in June 2024, Kuwait has made significant progress on the vast majority of its MER’s recommended actions, including adopting a new national AML/CFT/CPF strategy, further improving its technical compliance framework for TF and PF targeted financial sanctions, further enhancing its understanding of ML and TF risks and conducting risk-based outreach and supervision of financial institutions and DNFBPs. Kuwait will continue to work with the FATF to implement its FATF action plan by: (1) enhancing outreach to real estate agents and DPMSs on STR reporting, including through distribution of sector-based indicators of ML/TF; (2) ensuring that beneficial ownership information in the registry is accurate, and applying effective, proportionate and dissuasive sanctions in cases of inaccurate information where appropriate; (3)


	increasing ML investigations and prosecutions in relation to cross-border movements of currency and BNIs.
lao pdr	In February 2025, 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 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 cooperation; (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	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. Lebanon should continue working on implementing its FATF action plan to address its strategic deficiencies 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 DNFBPs’ risk understanding and applying effective, proportionate and dissuasive sanctions for breaches of AML/CFT obligations; (4) ensuring beneficial ownership information is up-to-date and that there are adequate sanctions and risk-mitigating in place for legal persons; (5) enhancing competent authorities’ use of products of the FIU and financial intelligence; (6) demonstrating a sustained increase in investigations, prosecutions and court rulings for types of ML in line with the risk; (7) improving its approach to asset recovery and identifying and seizing illicit cross-border movements of currency and precious metals and stones; (8) pursuing TF investigations and sharing information with foreign partners