Circular to Banks and Financial Institutions No. 2025-17 of December 22, 2025

Tunis, December 22, 2025.

CIRCULAR TO BANKS AND FINANCIAL INSTITUTIONS No. 2025-17

Subject: Internal control framework and rules regarding the fight against money laundering, terrorism financing, and proliferation financing of weapons of mass destruction.

The Governor of the Central Bank of Tunisia:
Having regard to Organic Law No. 2015-26 of August 7, 2015, on the fight against terrorism and money laundering repression, as amended and supplemented by Organic Law No. 2019-9 of January 23, 2019; Having regard to the Commercial Companies Code as amended and supplemented by subsequent texts; Having regard to Law No. 2005-51 of June 27, 2005, on electronic funds transfer; Having regard to Law No. 2016-35 of April 25, 2016, establishing the status of the Central Bank of Tunisia; Having regard to Law No. 2016-48 of July 11, 2016, on banks and financial institutions; Having regard to Decree-Law No. 2011-87 of September 24, 2011, organizing political parties; Having regard to Decree-Law No. 2011-88 of September 24, 2011, on associations; Having regard to Decree No. 2016-1098 of August 15, 2016, establishing the organization and operating procedures of the Tunisian Financial Analysis Commission (CTAF); Having regard to Government Decree No. 2019-419 of May 17, 2019, establishing procedures for implementing resolutions adopted by competent UN bodies related to the fight against terrorism financing and proliferation of weapons of mass destruction, as amended and supplemented by Government Decree No. 2019-457 of May 31, 2019; Having regard to Circular to Credit Institutions No. 2006-01 of March 28, 2006, on the regulation of outsourcing operations; Having regard to Circular to Credit Institutions No. 2006-19 of November 28, 2006, on internal control; Having regard to Circular to Approved Intermediaries No. 2012-11 of August 8, 2012, on the reporting to the Central Bank of Tunisia of operations in foreign banknotes with a value equal to or greater than 5,000 Tunisian dinars; Having regard to Circular to Banks and Financial Institutions No. 2017-06 of July 31, 2017, on accounting, prudential, and statistical reporting to the Central Bank of Tunisia; Having regard to Circular to Banks and Financial Institutions No. 2017-08 of September 19, 2017, on internal control rules for managing money laundering and terrorism financing risks, as amended by Circular No. 2018-09 of October 18, 2018; Having regard to Circular to Banks and Financial Institutions No. 2021-05 of August 19, 2021, on the governance framework for banks and financial institutions; Having regard to Circular to Banks No. 2025-06 of February 28, 2025, on the minimum rules governing electronic client enrollment; Having regard to Decision No. 2017-02 of the Tunisian Financial Analysis Commission (CTAF) of March 2, 2017, establishing guiding principles on the detection and reporting of suspicious operations and transactions; Having regard to Decision No. 2017-03 of the CTAF of March 2, 2017, on beneficial owners, as amended by Decision No. 2018-10 of June 8, 2018; Having regard to Decision No. 2024-01 of the CTAF of June 27, 2024, establishing guiding principles on the detection and reporting of suspicious operations and transactions; Having regard to Opinion No. 2025-17 of the Compliance Control
Committee dated December 18, 2025, as provided for in Article 42 of Law No. 2016-35 of April 25, 2016, establishing the status of the Central Bank of Tunisia.

Decides:

Article 1: The subject of Circular No. 2017-08 of September 19, 2017, as amended by Circular No. 2018-09 of October 18, 2018, is modified and replaced as follows:
Internal control framework and rules regarding the fight against money laundering, terrorism financing, and proliferation financing of weapons of mass destruction.

Article 2: The provisions of Article 4 of the aforementioned Circular No. 2017-08 are repealed and replaced as follows:
Article 4 (new): Subjected institutions must define and implement a framework for identifying and assessing the money laundering, terrorism financing, and proliferation financing risks to which they are exposed, as well as a policy for mitigating these risks. In the context of identifying and assessing these risks, subjected institutions shall take into account, in particular:
a) risk factors related to the characteristics of their clientele, the products and services provided or envisaged, the technologies used for distribution, as well as risks associated with jurisdictions or geographic zones in which operations are carried out; b) the conclusions of national risk assessments regarding the fight against money laundering, terrorism financing, and proliferation financing of weapons of mass destruction, including identified emerging threats; and c) information from all other reliable external sources related to the fight against money laundering, terrorism financing, and proliferation financing of weapons of mass destruction. The risk assessments to which subjected institutions are exposed must be recorded in a report, updated at least every three years, or more frequently upon the occurrence of a significant event affecting risk factors, or when information from competent authorities is likely to modify the assessment of inherent risks, notably in case of legal or regulatory changes or updates to the national risk assessment. Subjected institutions must be able to demonstrate, upon request by the Central Bank of Tunisia, the relevance of their risk assessments as well as the adequacy of proportionate vigilance measures put in place to prevent, mitigate, and manage money laundering and terrorism financing risks. The documents used to prepare the risk assessments are retained and made available to the Central Bank of Tunisia upon request.

It is considered a proliferation financing risk, within the meaning of this circular, any potential failure, non-application, or circumvention of targeted financial sanctions obligations provided for by United Nations Security Council resolutions. These obligations relate in particular to the immediate freezing of funds and other assets, as well as the prohibition on making funds or other assets available to or for the benefit of any designated person or entity under Chapter VII of the UN Charter.

Article 3: The third dash of the first paragraph of Article 14 of the aforementioned Circular No. 2017-08 is replaced as follows:

• evaluate the money laundering and terrorism financing framework implemented by the institution, including through a questionnaire whose model is attached as Annex 3 to this circular, or through the "Wolfsberg Group" questionnaire when required by the cross-border correspondent bank.

Article 4: The provisions of paragraph 2 of Article 53 of the aforementioned Circular No. 2017-08 are repealed and replaced as follows:
These rules form an integral part of the code of ethics provided for in Article 13 of Circular No. 2021-05 on the governance framework for banks and financial institutions.

Article 5: A paragraph is added after the first paragraph of Article 57 of the aforementioned Circular No. 2017-08 as follows:
A copy of the decision designating the CTAF correspondent and their alternate is sent to the Central Bank of Tunisia within a period not exceeding five (5) days from the date of designation.

Article 6: The provisions of the first paragraph of Article 58 of the aforementioned Circular No. 2017-08 are repealed and replaced as follows:
Subjected institutions must immediately declare suspicious operations and transactions via the goAML platform, in accordance with the procedures and technical measures defined by the CTAF.

Article 7: Annex 5 to the aforementioned Circular No. 2017-08 of September 19, 2017 is repealed and replaced by Annex 5 to this circular.

Article 8: Article 59 bis is added to the aforementioned Circular No. 2017-08 as follows:
Article 59 bis: Subjected institutions are required to transmit to the Central Bank of Tunisia a quarterly statement of frozen assets on their books in accordance with the provisions of Article 46 of this circular, covering:

• Freezes under UN sanctions; and
• Freezes decided by the National Commission for the Fight against Terrorism (CNLCT).
  This obligation also covers freezes carried out in the context of fighting the proliferation financing of weapons of mass destruction.
  The said statement must conform to Annex 6 to this circular and be transmitted within a maximum period of twenty (20) working days following the end of each quarter.

Article 9: The provisions of paragraph 2 of Article 60 of the aforementioned Circular No. 2017-08 are repealed and replaced as follows:
The assessment report provided for in Article 4 of Title I of this circular must be communicated to the Central Bank of Tunisia upon each update.

Article 10: The mention "Number of children" is removed from the identification elements for natural persons appearing among the minimum information provided in Annex 1, as defined in paragraph 3 of Article 5 of the aforementioned Circular No. 2017-08.

Article 11: Annex I to Circular No. 2017-06 on accounting, prudential, and statistical reporting to the Central Bank of Tunisia is modified by adding two declarations to sub-domain 5 "AML/CFT" within domain 5 "Reporting on governance, internal control, and risk management frameworks", in accordance with Annexes 5 and 6 of this circular.

Article 12: This circular enters into force from the date of its publication.
The Governor,
Fethi Zouhaier NOURI

ANNEX 5 TO CIRCULAR NO. 2025-17 OF DECEMBER 22, 2025 STATISTICS RELATED TO DECLARATIONS SUBMITTED TO THE CTAF AT THE END OF THE FINANCIAL YEAR (N) Institution:

Designations	Natural Persons	Legal Entities	Legal Structures (*)	Associations	Political Parties	Total
Total number of suspicious declarations	Disaggregated by: Reasons for declarations, Identified underlying offenses (AML/CFT/PF), Activity sector
Total amount of operations subject to suspicious declarations	Disaggregated by: Reasons for declarations, Activity sector, Country of origin of suspect funds, Destination country of suspect funds
(*) to be specified
Signature and authorized seal

ANNEX 6 TO CIRCULAR NO. 2025-17 OF DECEMBER 22, 2025 Quarterly Statement on Frozen Assets under UN and National Sanctions Subjected Institution:
| No. | Client / Entity concerned | ID | Nationality / Country of registration | Applicable list reference | Date of freeze decision | Frozen Assets (Nature, Currency, Total amount) | CNLCT Information Date | Complementary measures (partial/full lifting, other actions) |