Decision No. 1 of 2026 Regarding High-Risk and Enhanced Follow-Up Countries

Palestine Monetary Authority / Financial Follow-Up Unit, State of Palestine Circular No. (21/2026) to all banks operating in Palestine Date: Wednesday, 18 February 2026

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

Attached is a copy of the decision issued by the Financial Follow-Up Unit No. (2026/1) regarding high-risk countries and enhanced follow-up countries, in accordance with the list issued by the Financial Action Task Force (FATF). Accordingly, legal measures required to implement the aforementioned decision and related measures are requested, with emphasis on compliance as follows:

1. Taking into account concerns regarding deficiencies in anti-money laundering and counter-terrorist financing (AML/CFT) systems in countries classified on the "grey list" (enhanced follow-up countries), when conducting and updating self-assessments of AML/CFT risks.
2. Applying the risk-based approach (RBA), such that due diligence measures are proportional to (risk analysis results, nature of financial transactions, customer risks, and country classifications), with enhanced due diligence measures applied when high risks are identified.

Supervisory Group
Palestine Monetary Authority

Copy to: The respected Financial Follow-Up Unit

---

Financial Follow-Up Unit, State of Palestine Decision No. (2026/1) issued by the Financial Follow-Up Unit dated 15 February 2026

Regarding High-Risk and Enhanced Follow-Up Country Lists

Based on the provisions of Law No. (39) of 2022 regarding combating money laundering and terrorist financing, particularly Articles (20) and paragraphs (3, 4) of Article (30), and in accordance with Decision No. (8/J/2016) of the National Committee for Combating Money Laundering and Terrorist Financing dated 01 December 2016, regarding the delegation to the Financial Follow-Up Unit to publish the list of high-risk countries issued periodically by FATF, and subsequently as determined by the Group since 21 February 2020 until 13 February 2026, and further to Decision No. (T/2020/5) of the National Committee dated 24 February 2020 regarding high-risk and enhanced follow-up countries, and subsequently to Decision No. (2020/1) of the Financial Follow-Up Unit dated 25 February 2020 and subsequent decisions regarding the lists of high-risk and enhanced follow-up countries. In light of public interest requirements, it is decided as follows:

First
High-Risk Country List (Blacklist)

All financial institutions, designated non-financial businesses and professions (DNFBPs) in the State of Palestine must continue to apply 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 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 countermeasures: <br> a. Apply enhanced due diligence measures to business relations and transactions with those countries (as part of countermeasures), proportional to the arising risks, according to Articles (26, 27) of National Committee Instructions No. (4) of 2022 for financial institutions, and Articles (24, 25) of National Committee Instructions No. (3) of 2022 for DNFBPs. <br> b. Apply the enhanced due diligence measures mentioned in paragraph (a) when dealing with any entity acting on behalf of a natural or legal person, including companies or financial institutions operating in those countries. <br> c. Enhance the reporting mechanisms adopted by the financial institution or DNFBP, including increasing cooperation among staff and promptly providing data to the AML/CFT compliance officer within the institution, ensuring no transactions suspected of involving money laundering or predicate offenses/terrorist financing are executed, and reporting such suspicions to the Unit immediately without delay, providing all data related to transaction attempts, while ensuring confidentiality of reporting and non-notification to 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 for any due diligence measures regarding customers. <br> f. Do not establish banking correspondent relationships or similar correspondent relationships with financial institutions in those countries.

Country

Required Procedures Regarding Countries

Republic of Myanmar (Myanmar).

1. Apply enhanced due diligence measures to business relations and transactions with Myanmar, proportional to the risks arising in the country, according to Articles (26, 27) of National Committee Instructions No. (4) of 2022 for financial institutions, and Articles (24, 25) of National Committee Instructions No. (3) of 2022 for DNFBPs. <br> 2. When applying enhanced due diligence measures, ensure that fund flows for humanitarian assistance and legitimate non-profit organizations' activities and financial transfers are not disrupted, particularly regarding earthquake relief efforts in Myanmar.

Second
Enhanced Follow-Up Country List (Greylist)

Amend the list of enhanced follow-up countries (grey list) stipulated in the Unit's Decision No. (2025/3) by adding both (the State of Kuwait, and Papua New Guinea), so that the list becomes as shown in the table below. Take into account concerns regarding deficiencies in AML/CFT systems for these countries (according to the attached appendix to this decision) when conducting self-assessments of AML/CFT risks, including identifying, analyzing, and evaluating 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	British Virgin 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, which shall take effect from the date of its circular issuance.

Director of the Financial Follow-Up Unit
Dr. Firas Marar
15/02/2026

Attachment: Concerns Regarding Deficiencies in AML/CFT Systems.

---

Concerns Regarding Deficiencies in AML/CFT Systems

Attached to Financial Follow-Up Unit Decision No. (2026/1) regarding high-risk and enhanced follow-up country lists.

Concerns Regarding Deficiencies in AML/CFT Systems in Countries

Part One: Deficiencies through Assessment Reports (for all countries): This section explains how to access concerns regarding AML/CFT and proliferation financing (PF) systems for countries listed on the grey list, as well as all other countries subject to mutual evaluation by FATF or peer groups. These concerns can be accessed by reviewing the mutual evaluation reports for those countries, and subsequent follow-up reports.
The published mutual evaluation reports (MERs) and follow-up reports on the FATF or MENAFATF websites contain all deficiencies and conclusions regarding AML/CFT systems for countries on the enhanced follow-up list and other evaluated countries. Access is available via the following mechanism:

a. Access to mutual evaluation reports in English (for all countries).

1. Visit 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 on the search window shown in the adjacent figure.

b. Access to mutual evaluation reports in Arabic (for countries subject to MENAFATF assessment).

1. Visit the website: www.menafatf.org/ar
2. Select (Mutual Evaluation) then (Evaluation Reports - Second Round of Assessment), or follow-up reports.
3. Select the report from the list appearing by country name.

Part Two: Implementation of Action Plans to Address Deficiencies Countries listed on the grey list have made high-level political commitments to address strategic deficiencies in AML/CFT systems, and these countries continue to implement their commitments to address remaining deficiencies.
The items below outline the key pillars that those countries are addressing or have addressed, based on specific deficiencies identified in mutual evaluation and follow-up reports. These should be considered whether negative or positive:

Country	Key Pillars
Algeria	In October 2024, Algeria made a high-level political commitment to work with FATF and MENAFATF to strengthen AML/CFT effectiveness. At its February 2026 Plenary, FATF determined that Algeria has substantially completed its action plan and warrants an on-site assessment to verify sustained AML/CFT reform implementation. Reforms include: (1) improving risk-based supervision, especially for higher-risk sectors; (2) developing an effective framework for basic and beneficial ownership information; (3) enhancing suspicious transaction reporting regime; (4) establishing effective legal/institutional framework for targeted financial sanctions for TF; and (5) implementing risk-based oversight of NPOs without disrupting legitimate activity.
Angola	In October 2024, Angola made a high-level political commitment to work with FATF and ESAAMLG. Angola should continue implementing its FATF action plan by: (1) enhancing understanding of ML/TF risks; (2) improving risk-based supervision of non-financial banking entities and DNFBPs; (3) ensuring competent authorities have adequate, accurate, timely access to beneficial ownership information and addressing breaches; (4) demonstrating increased ML investigations/prosecutions; (5) demonstrating ability to identify, investigate, and prosecute TF; and (6) demonstrating effective process to implement targeted financial sanctions without delay.
Bolivia	Since June 2025, when Bolivia made a high-level political commitment to work with FATF and GAFILAT, it has improved AML/CFT by ensuring accurate/up-to-date beneficial ownership information. Bolivia should continue implementing 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 breaches to beneficial ownership obligations are sanctioned; and (4) increasing ML investigations/prosecutions in line with country risks.
Bulgaria	Since October 2023, when Bulgaria made a high-level political commitment to work with FATF and MONEYVAL, it has improved AML/CFT, addressing technical compliance deficiencies (including confiscation) and demonstrating initial risk-based monitoring of NPOs to prevent TF abuse. FATF notes continued progress, but all deadlines have expired and work remains to address strategic deficiency in improving investigations/prosecutions of different ML types in line with risks (including high-scale corruption and organized crime). FATF encourages Bulgaria to build on recent progress and implement its action plan soon.
Cameroon	Since June 2023, when Cameroon made a high-level political commitment to work with FATF and GABAC, it has improved AML/CFT by designating an authority for AML/CFT supervision of all DNFBPs and conducting parallel financial investigations, international cooperation, and prosecuting ML in line with risks. Cameroon should continue implementing its FATF action plan by: (1) enhancing risk-based supervision of banks and non-bank FIs/DNFBPs; (2) enhancing secure information exchange between FIU, reporting entities and competent authorities; (3) implementing policies for seizing/confiscating proceeds/instruments of crime and managing frozen/seized/confiscated property; (4) demonstrating effective TF/PF TFS regimes and risk-based NPO oversight. FATF notes continued progress, all deadlines expired, work remains.
Côte d'Ivoire	Since October 2024, when Côte d'Ivoire made a high-level political commitment to work with FATF and GIABA, it has improved AML/CFT by enhancing risk-based supervision of FIs/DNFBPs, increasing financial intelligence use by law enforcement, improving FIU dissemination, and demonstrating sustained increase in TF investigations/prosecutions. Should continue implementing FATF action plan by demonstrating sustained increase in investigations/prosecutions of different ML types in line with risk profile.
Democratic Republic of the Congo	Since October 2022, when DRC made a high-level political commitment to work with FATF and GABAC, it has improved AML/CFT by developing risk-based supervision plans for FIs/DNFBPs, addressing technical compliance deficiencies with R.5, 10, 11 and 20, demonstrating effective ML investigations/prosecutions and TF/PF-related TFS. DRC should continue implementing FATF action plan by: (1) implementing risk-based supervision plan; and (2) identifying/investigating TF activities in line with risks. FATF notes continued progress, all deadlines expired, work remains.
Haiti	Since June 2021, when Haiti made a high-level political commitment to work with FATF and CFATF, it has improved AML/CFT by implementing risk-based CFT supervision for all FIs and ensuring FIU has adequate resources/processes for operational/strategic analysis. FATF recognizes high-level political commitment and efforts amid challenging social/economic/security situation. Haiti should continue implementing action plan by: (1) completing ML/TF risk assessment process and disseminating findings; (2) implementing risk-based AML/CFT supervision for higher-risk DNFBPs; (3) ensuring basic/beneficial ownership information maintained/accessed timely; (4) demonstrating authorities identifying/investigating/prosecuting ML cases consistent with risk profile; (5) demonstrating increased identification/tracing/recovery of crime proceeds; (6) addressing technical deficiencies in targeted financial sanctions regime; and (7) conducting appropriate risk-based monitoring of TF-vulnerable NPOs. FATF notes continued progress, all deadlines expired, work remains.
Kenya	Since February 2024, when Kenya made a high-level political commitment to work with FATF and ESAAMLG, it has improved AML/CFT by strengthening supervisor capacities, adopting legal framework for virtual asset service providers licensing/supervision, and demonstrating sustained increase in TF investigations/prosecutions. Kenya should continue implementing FATF action plan by: (1) improving risk-based AML/CFT supervision of FIs/DNFBPs; (2) enhancing understanding of preventive measures by FIs/DNFBPs, including increasing STR filing and implementing TFS without delay; (3) designating authority for trust regulation and collecting accurate/up-to-date beneficial ownership information, implementing remedial actions for compliance breaches; (4) improving use/quality of financial intelligence products; (5) increasing ML investigations/prosecutions in line with risks; (6) bringing TFS framework into compliance with R.6 and ensuring effective implementation; and (7) revising NPO regulation/oversight framework to ensure risk-based mitigating measures.
Kuwait	In February 2026, Kuwait made a high-level political commitment to work with FATF and MENAFATF. Since adopting its MER in June 2024, Kuwait has made significant progress on most MER recommended actions, including adopting new national AML/CFT/CPF strategy, improving technical compliance framework for TF/PF TFS, enhancing understanding of ML/TF risks, and conducting risk-based outreach/supervision. Kuwait will continue implementing FATF action plan by: (1) enhancing outreach to real estate agents and DPMSs on STR reporting, including sector-based indicators; (2) ensuring registry beneficial ownership information is accurate and applying effective/proportionate/dissuasive sanctions for inaccuracies; (3) increasing ML investigations/prosecutions related to cross-border currency/BNI movements.
Lao PDR	In February 2025, Lao PDR made a high-level political commitment to work with FATF and APG. Lao PDR should continue implementing FATF action plan by: (1) enhancing 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 quality/quantity of financial intelligence analysis and spontaneous dissemination to law enforcement; (4) ensuring law enforcement agencies receive training/guidance on ML; (5) demonstrating increased ML investigations/prosecutions in line with risk profile, emphasizing transnational crimes requiring international cooperation; (6) developing national confiscation policy consistent with ML/TF risks; (7) demonstrating competent authorities taking measures to identify/seize/confiscate proceeds/instrumentalities of crime; (8) monitoring FIs'/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 FATF and MENAFATF despite challenging social/economic/security situation. Lebanon should continue implementing FATF action plan by: (1) conducting assessments of specific TF/ML risks identified in MER and ensuring policies/measures mitigate these risks; (2) enhancing mechanisms for timely/effective execution of mutual legal assistance, extradition and asset recovery requests; (3) enhancing DNFBPs' risk understanding and applying effective/proportionate/dissuasive sanctions for AML/CFT breaches; (4) ensuring beneficial ownership information is up-to-date and adequate sanctions/risk-mitigating measures are in place for legal persons; (5) enhancing competent authorities' use of FIU products/financial intelligence; (6) demonstrating sustained increase in investigations/prosecutions/court rulings for ML types in line with risk; (7) improving asset recovery approach and identifying/seizing illicit cross-border currency/precious metals/stones movements; (8) pursuing TF investigations and sharing information with foreign partners related to TF investigations per MER; (9) enhancing implementation of targeted financial sanctions without delay, particularly at DNFBPs and certain non-banking FIs; and (10) undertaking targeted/risk-based monitoring of high-risk NPOs.
Monaco	[Details pending in attached report]