Palestine Monetary Authority

PALESTINE MONETARY AUTHORITY

Circular No. (16 / 2025)

To all payment service companies operating in Palestine Date: Tuesday, August 19, 2025

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Subject: High-Risk Countries and Countries Under Increased Monitoring

Attached is a copy of the decision issued by the Financial Follow-Up Unit No. (2025/2) regarding High-Risk Countries and Countries Under Increased Monitoring 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 in this regard, 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 on the "Grey List" (Countries Under Increased Monitoring), 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.

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Supervision Group
Palestine Monetary Authority

Copy: The Honorable / Financial Follow-Up Unit

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www.pma.ps

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Ramallah & Al-Bireh Governorate - Palestine P.O. Box 452 محافظة رام الله والبيرة - فلسطين ص.ب info@pma.ps | Fax: +970 2 2415310 : فاكس | Tel: +970 2 2415251 : هاتف | Postal code: P6160675 : الرمز البريدي

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Financial Follow-Up Unit

State of Palestine

وحدة المتابعة المالية

دولة فلسطين

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(2025/2) Decision No.
Issued by the Financial Follow-Up Unit
Date 19/06/2025

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Regarding Lists of High-Risk Countries and Countries Under Increased Monitoring

Based on the provisions of Law No. (39) of 2022 regarding the prevention 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/4/2016) 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 13/06/2025, and in addition to the decision of the National Committee for Combating Money Laundering and Terrorist Financing No. (t/5/2020) issued on 24/02/2020 regarding High-Risk Countries and Countries Under Increased Monitoring, and subsequently the Financial Follow-Up Unit Decision No. (1/2020) dated 25/02/2020 and its subsequent decisions regarding lists of High-Risk Countries and Countries Under Increased Monitoring.

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

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First

List of High-Risk Countries (Black List)

All financial institutions, businesses, and specified 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. (14/2022) 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 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 Specified Non-Financial Businesses and Professions. <br> 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.
- Islamic Republic of Iran (Iran).

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Financial Follow-Up Unit

State of Palestine

وحدة المتابعة المالية

دولة فلسطين

Country	Required Procedures Towards Countries
	c. Enhance the reporting mechanisms adopted by the financial institution or one of the specified non-financial businesses, including increasing cooperation between employees and promptly providing data to the anti-money laundering and counter-terrorist financing officer within the financial institution or one of the specified non-financial businesses, to ensure that no transaction suspected of involving money laundering or related crimes or terrorist financing is executed, and to report this violation to the Unit immediately and without delay, providing it with all data related to attempting to conclude those transactions, while ensuring the confidentiality of the report and not notifying the customer. <br> d. Do not establish branches, representative offices, or subsidiaries in those countries. <br> e. Do not rely on third parties located in those countries in taking any due diligence measures towards customers. <br> f. Do not establish any banking correspondent relationships or similar correspondent relationships with financial institutions in those countries.
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 Specified Non-Financial Businesses and Professions. <br> 2. When applying enhanced due diligence measures, it must be ensured that the flow of funds for humanitarian aid and legitimate non-profit organization activities and financial transfers is not disrupted. <br> 3. Regarding earthquake relief efforts specifically, it must be ensured that the implementation of anti-money laundering and counter-terrorist financing requirements does not negatively or disproportionately affect non-profit organizations, and does not unjustifiably hinder the work of civil society and the provision of humanitarian aid related to earthquake relief in Myanmar.

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Second

List of Countries Under Increased Monitoring (Grey List)

Amend the list of Countries Under Increased Monitoring (Grey List) stipulated in the Unit's Decision No. (2025/1) by adding (Bolivia, Virgin Islands (United Kingdom)), and removing (Croatia, Republic of Mali, Tanzania), 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 for these countries (according to the attachment attached to this decision) when conducting the self-assessment of money laundering and terrorist financing risks, including identifying, analyzing, and evaluating those risks.

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Financial Follow-Up Unit

State of Palestine

وحدة المتابعة المالية

دولة فلسطين

Number	Country Name	Number	Country Name
1	Algeria	13	Monaco
2	Angola	14	Republic of Mozambique
3	Bolivia	15	Republic of Namibia
4	Bulgaria	16	Federal Democratic Republic of Nepal (Nepal)
5	Burkina Faso	17	Republic of Nigeria
6	Cameroon	18	Republic of South Africa
7	Côte d'Ivoire (Ivory Coast)	19	Republic of South Sudan
8	Democratic Republic of the Congo	20	Syrian Arab Republic (Syria)
9	Republic of Haiti	21	Venezuela
10	Republic of Kenya	22	Vietnam
11	Lao People's Democratic Republic (Laos)	23	Virgin Islands (United Kingdom)
12	Republic of Lebanon	24	Republic of Yemen (Yemen)

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Third

Implementation

All financial institutions, businesses, and specified non-financial 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 Marar

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

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

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

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Attached to Financial Follow-Up Unit Decision No. (2025/2)

Regarding Lists of High-Risk Countries and Countries Under Increased Monitoring

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

Part One: Deficiencies through Mutual Evaluation Reports (All Countries)

This section explains how to access concerns regarding the anti-money laundering and counter-terrorist financing and proliferation financing systems of countries listed on the Grey List, as well as all other countries undergoing mutual evaluation by the Financial Action Task Force or regional groups. Those concerns can be accessed by viewing the mutual evaluation reports related to those countries, and the follow-up reports for this report.

Mutual evaluation reports and follow-up reports on the FATF or MENAFATF website contain all deficiencies and key conclusions regarding the anti-money laundering and counter-terrorist financing systems in countries listed on the Increased Monitoring List and all other countries that have undergone evaluation. The following evidence can be obtained:

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

1. Enter 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 in the search window shown in the image on the side.

b. Access to Mutual Evaluation Reports in Arabic (For Countries Undergoing Evaluation by MENAFATF):

1. Enter the website:
   www.menafatf.org/ar

2. Select the item (Mutual Evaluation) then (Evaluation Reports – Second Round of Evaluation), or select the report from the list that appears according to the country name.

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Attached to Financial Follow-Up Unit Decision No. (2025/2)

Regarding Lists of High-Risk Countries and Countries Under Increased Monitoring

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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 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 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, which must be taken into account whether negative or positive:

Country	Key Axes
Algeria	(Statement from October 2024)<br>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	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	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

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Attached to Financial Follow-Up Unit Decision No. (2025/2)

Regarding Lists of High-Risk Countries and Countries Under Increased Monitoring

	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 by providing guidance and training on ML/TF risk understanding and STR reporting to postal money operators, currency exchange providers and real estate agents, addressing technical compliance issues in relation to its TF offence and ensuring the ability to conduct parallel financial investigations in all terrorism investigations. 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) addressing gaps in the PF TFS frameworks; and (4) 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. At its June 2025 Plenary, the FATF made the initial determination that Burkina Faso has substantially completed its action plan and warrants an on-site assessment to verify that the implementation of the AML/CFT reforms has begun and is being sustained, and that the necessary political commitment remains in place to sustain implementation in the future.<br><br>Burkina Faso has made key reforms, including by: (1) adopting follow-up mechanisms for monitoring actions in the national strategy; (2) seeking MLA and other forms of international cooperation in line with its risk profile; (3) strengthening resource capacities of all AML/CFT supervisory authorities and implementing risk based supervision of FIs and DNFBPs; (4) maintaining comprehensive and up-to-date basic and beneficial ownership information and strengthening the system of sanctions for violations of transparency obligations; (5) increasing the diversity of suspicious transactions reporting; (6) enhancing the FIU’s human resources through additional hiring, training and budget; (7) conduct training for LEAs, prosecutors and other relevant authorities; (8) demonstrating that authorities are pursuing confiscation as a policy objective; (9) enhancing capacity and support for LEAs and prosecutorial authorities involved in combating TF, in line with the National TF Strategy; and (10) implementing effective targeted financial sanctions regimes related to terrorist financing and proliferation financing as well as risk-based monitoring and supervision of NPOs.

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