2025-09-04
Added · Updated
The Government of the Lao People’s Democratic Republic establishes procedures for reporting entities and postal enterprises to withhold, suspend, or freeze funds associated with designated persons on the UN Sanctions List or Domestic Designation List. The Ministry of Public Security must issue seizure or freezing orders without delay and complete verification of suspected assets within thirty days, extendable to sixty or ninety days for complex or international cases. The decree outlines exemptions for basic and extraordinary expenses, requires the Ministry of Foreign Affairs to coordinate with the UN Security Council for delisting requests, and mandates that updated sanctions lists be communicated to relevant parties within twenty-four hours of approval.
1 Lao People’s Democratic Republic Peace Independence Democracy Unity Prosperity The Government No. 553 /Gov. Vientiane Capital, dated: 04 September 2025 Decree on Withholding, Seizing or Freezing Funds related to Terrorists and the Financing of Terrorism
The Government issues the Decree: Chapter 1 General Provisions Article 1 Objectives This Decree establishes the principles, requirements, and procedures for the implementation of targeted financial sanctions related to terrorism and terrorist financing, including the identification, withholding, seizure or freezing of the funds. It aims to ensure timely and effective implementation in accordance with international standards, to safeguard national security, maintain financial system integrity, promote international cooperation, and contribute to sustainable development. Article 2 Withholding, Seizing or Freezing Funds related to Terrorists or the Financing of Terrorism The withholding, seizing or freezing funds of designated persons and entities associated with terrorism and terrorist financing constitutes an administrative measure applied to prevent, restrict, and suppress the movement, activities, or conduct related to terrorism and terrorist financing. Article 3 Definition
2 2. UN Sanctions List refers to the list of natural person or legal persons, or organization or group of people associated with terrorism and terrorist financing, as designated by the United Nations Security Council (UNSC) under Resolutions 1267 (1999), 1988 (2011), 1989 (2011), 2253 (2015), and any successor/relevant resolutions (UNSCR). 3. The Domestic Designation List shall refer to the list of natural person or legal persons, or organization or group of people involved in terrorist acts and the financing of terrorism according to the designation listed by Lao PDR. 4. Fund to be withhold, Seized or Frozen shall refer to the funds as defined under the Law on Anti-Money Laundering and Countering the Financing of Terrorism and other assets, which are owned or controlled, directly or indirectly, wholly or jointly, by designated persons or entities associated with terrorism and terrorist financing; funds derived from assets owned or controlled, directly or indirectly, by such designated persons or entities; funds or other assets of persons and entities acting on behalf of, or at the direction of, such designated persons or entities; and funds or other assets of natural persons, legal persons, organizations or groups of people that provide or attempt to provide funds or other assets for the benefit of terrorism and terrorist financing, including funds derived from acts of terrorism. 5. Transaction refers to any financial activity carried out on behalf of a customer, including but not limited to: purchase, sale, or payment for services; deposit, withdrawal, payment order, or transfer related to banking services, microfinance, insurance, securities, precious commodities, or virtual assets. The term also covers services provided by postal enterprises, accounting firms, audit firms, law firms, lawyers, pawnshops, leasing companies, payment service providers, fund management companies, investment funds, real estate business, and casino operations. 6. Seizure refers to the taking into custody of funds or other assets of natural person, legal persons, organizations, or groups of people designated in the list associated with terrorism and terrorist financing, pursuant to an order of the competent authority of the Ministry of Public Security (MOPS). 7. Freezing refers to the prohibition against the sale, transfer, assignment, conversion, pledge, mortgage, guarantee, disposal, alteration, destruction, movement, or any form of dealing in funds or other assets, whether movable or immovable, of natural persons, legal persons, organizations, or groups of people designated in the list associated with terrorism and terrorist financing, pursuant to an order of the competent authority of the Ministry of Public Security. 8. The National Coordination Committee for Anti-Money Laundering and Countering the Financing of Terrorism (NCC) refers to an ad hoc body established by appointment of the Prime Minister, composed of: the Deputy Prime Minister as Chairperson; the Governor of the Bank of the Lao PDR as Deputy Chairperson and Standing Member; Deputy Ministers or Deputy Heads of relevant organizations as Deputy Chairpersons; and other appointed members. The Anti-Money Laundering Intelligence Office (AMLIO) serves as the Secretariat.
3 Article 4 Policy on the Withholding, Seizing and Freezing Funds related to Terrorists or the Financing of Terrorism The Lao PDR shall implement measures to withhold, seizure or freeze the funds associated to terrorism and terrorist financing in accordance with the following principles:
4 In cases where a completed transaction or service, if funds or other assets are detected or identified as belonging to, or associated with, any natural persons, legal person, organization or group of people listed as designated persons and entities associated with terrorism and terrorist financing, the reporting entities and postal enterprises must withhold fund or other assets to prevent any movement, transfer or use, without prior notice to the customer, and immediately report to the MOPS and AMLIO. Article 8 Seizure and Freezing Upon receipt of a report from reporting entities and postal enterprises, the MOPS shall issue an order on seizing or freezing funds or other assets of designated persons and entities associated with terrorism and terrorist financing without delay. Funds or other assets that have been seized or frozen shall be preserved until the order of seizure and freezing is lifted, or amended, in accordance with the provisions set forth in Article 12 of this Decree. Article 9 Procedures Following Seizure or Freezing of Funds. Following the issuance of an order on seizing or freezing funds, the MOPS shall promptly undertake the collection of information and evidence to determine whether the suspected person and the funds or other assets concerned are associated with, or not associated with, terrorism and terrorist financing. Such verification must be completed within thirty days. Where the collection of information and evidence involves multiple parties or is complex, this period may be extended for an additional thirty days. In cases where the collection of information and evidence requires cooperation with foreign jurisdictions, the verification must be completed within ninety days. If it is established that the funds or other assets are not associated with terrorism and terrorist financing, or where the UNSC removes the name of the owner of the funds from the list of designated persons and entities associated with terrorism and terrorist financing, the order of seizure or freezing shall be immediately lifted. The MOPS shall notify the relevant reporting entities, postal enterprises, natural persons, legal person, organization or group of people concerned of the lifting of the administrative measures and shall ensure the prompt return of the funds or other assets without delay. Article 10 Reporting of Transactions or Activities of Designated Persons and Entities Associated with Terrorism and Terrorist Financing Natural persons, legal person or organization that encounter any transaction or activity of natural persons, legal persons, organizations or groups of people associated with list of terrorism and terrorist financing must immediately report such activities to the AMLIO or the MOPS in order to tenably take appropriate action and apply measures to freeze such transactions or activities. Reporting entities, if they suspect a transaction, service or customer to be a designated person, entity or otherwise linked to terrorism and terrorist financing, must immediately file a
5 report with the AMLIO. For postal enterprises, such reports must be submitted without delay to the relevant authority of the MOPS. Article 11 Screening and Verification of Potential False Positive Match Reporting entities, postal enterprises, and other relevant parties must conduct screening and verification of information relating to natural persons, legal persons, organization or groups of people whose names are identical or similar to those of persons or entities designated on the list relating to terrorism and terrorist financing. This includes verifying identifiers such as name, surname, date of birth, and other identification documents, on an ongoing basis, to ensure that such persons are not involved in terrorism and terrorist financing activities. In cases where reporting entities, postal enterprises, or other relevant parties are unable to confirm whether a natural persons, legal persons, organizations or group of people with an identical or similar name is in fact a designated person or entity, they must refer the matter to the MOPS and AMLIO for verification immediately. Upon confirmation that the person or entity is only a name match (a “false positive”) and not the designated person, reporting entities, postal enterprises, and other relevant parties must immediately lift any suspension or withholding measures applied to the funds or assets. Chapter 3 Measures to Mitigate the Consequences of Withholding, Seizing or Freezing Funds with respect to Natural Persons, Legal Persons, and Organizations or Groups of People Article 12 Legal Remedies, Exemptions and Procedures for Access to Frozen or Seized Funds Natural persons, legal persons, and organizations designated or associated with terrorism and terrorist financing, who are adversely affected by the seizing or freezing funds, have the right to submit a request or petition to the MOPS for consideration of remedies. The remedying of consequences from the seizing or freezing of funds in accordance with the UN Sanctions List shall be carried out as follows:
6 3. Authorize the receipt of interest or other earnings arising from contracts, agreements, or obligations established prior to freezing by the frozen accounts, which shall remain frozen. Regarding the consideration of requests for access to or use of funds or other assets that are frozen or seized, pursuant to the UN Sanctions List, the MOPS shall coordinate with the Ministry of Foreign Affairs (MOFA) to seek authorization from the relevant UNSC Committee, and provide all necessary supporting documentation to the said Committee. The consideration of remedies related to funds frozen or seized under the Domestic Designation List shall be carried out as follows:
7 UN Sanctions List, in coordination with the MOFA, AMLIO, relevant ministries and organizations, based on the basic information as specified in Article 18, Paragraph 1, Clause 1 of this Decree and the criteria for designation as specified in the UNSCR. After consideration, if it is concluded that there is evidentiary standard or reasonable grounds whether such a natural person, legal person, organization or group of people have or have not engaged in behaviors or activities related to terrorism and financing terrorism, the MOPS shall propose to the MOFA to submit the requesting to the UNSC for consideration. Upon review, if it is concluded that there is sufficient and reliable information or evidence to determine whether a natural person, legal person, entity, or group of people is involved or not involved in terrorist acts or the financing of terrorism, the MOPS shall submit a recommendation to the MOFA, which will then forward the request to the UNSC for further consideration. Article 15 Requesting to the United Nations Security Council The MOFA shall propose the de-listing of natural person, legal person and organizations or groups of people that have not engaged in behaviors or activities related to terrorism and the financing of terrorism, to the UNSC, using the standard forms specified by the UNSC through the United Nations Office of the Ombudsperson. In addition, the MOPS shall also inform natural persons, legal persons, organizations or groups of people designated in UN Sanctions List, of their rights and details of procedures for submitting a delisting request as well as the United Nations Office of the Ombudsperson. Article 16 Communicating of the UN Sanctions List After the MOFA receives the UN Sanctions List, it is not necessary to conduct further investigation or consideration, but it shall immediately communicate such list to the MOPS, the Ministry of Technology and Communications (MTC), and AMLIO. The MOPS, the MTC, and AMLIO shall notify the reporting entities, postal enterprises, and other relevant parties of the UN Sanctions List, in order to suspend transactions or services and to withhold funds, and shall propose to the MOPS to issue an Order to seize or freeze such funds related to the listed persons or those related to terrorism and the financing of terrorism within twenty-four hours after the UNSC approves or updates the list. The updated list shall be published immediately through the government website or the website of the relevant organization. The MOPS, the MTC, AMLIO, reporting entities, postal enterprises, natural persons, legal persons, organizations, and other relevant parties may access the UN Sanctions List through the electronic system and other available channels. Chapter 5 Requesting Listing and De-listing on the Domestic Designation List Article 17 Listing on the Domestic Designation List The proposal for designation of the Domestic Designation List shall be guided by the sources of information as follows:
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9 Article 19 Requests of the Lao PDR to Foreign Jurisdiction After consideration, if the MOPS finds that there is evidentiary standard or reasonable grounds that can verify that natural persons, legal persons, organizations or groups of people have engaged in behaviors or activities as stipulated under the Law on Anti-Money Laundering and Combating the Financing of Terrorism and other relevant laws and regulations of the Lao PDR, the MOPS must propose to the MOFA to submit a request on behalf of the Lao PDR to foreign jurisdictions for consideration to designate such names in the terrorist and terrorism financing list of those states. In the event of changes in the information of a person listed on the Domestic Designation List that are related to the terrorist and terrorism financing lists of foreign jurisdictions, the MOPS must immediately notify the relevant foreign jurisdictions of such changes without delay. Article 20 De-Listing from the Domestic Designation List Any natural person, legal person, organization or group of people who have verifiable information confirming that they themselves have not engaged in behaviors or activities related to terrorism and the financing of terrorism may submit a request to the MOPS to consider the removal of their names from the Domestic Designation List. The MOPS must review the information and evidence related to the request for removal from the list, in coordination with the MOFA, AMLIO, relevant ministries, and organizations. In cases where, upon consideration, it is confirmed with information and evidence that such natural person, legal person, organization or group of people requesting removal from the list have not engaged in behaviors or activities related to terrorism and the financing of terrorism as prescribed in Article 18, Paragraph 1 of this Decree, the MOPS shall immediately propose to the NCC the removal of their names from the Domestic Designation List. Article 21 Notification of the results of requests to foreign jurisdictions The MOPS shall notify the results the requesting foreign jurisdictions of the result concerning the designation, non-designation or de-listing of names from the Domestic Designation List through the MOFA. Article 22 Communicating on the Domestic Designation List After the NCC has approved the Domestic Designation List, the MOPS shall communicate the lists to the MTC and AMLIO to notify reporting entities, postal enterprises, and other relevant sectors, as well as to publish the said lists on the government website or on the website of the relevant organization without delay. The MOPS, the MTC, AMLIO, reporting entities, postal enterprises, natural persons, legal persons, organizations, and other relevant sectors may access the Domestic Designation List through the electronic system or other available channels. The MTC and AMLIO shall notify the Domestic Designation List to reporting entities and postal enterprises to suspend transactions or services and to withhold funds, and shall propose to the MOPS to issue an order to seize or freeze the funds of those listed or associated
10 with terrorism and terrorist financing, within twenty-four hours after the NCC has approved or updated the Domestic Designation List. Chapter 6 Prohibitions Article 23 General Prohibitions Natural persons, legal persons and organisations are prohibited from the following behaviors:
11 2. Dealing with banks in countries that do not have laws or regulations regarding the seizure, seizure and freezing of funds of persons and entities on the list of those involved in terrorism and terrorist financing. 3. Conducting business or transactions with natural person, legal persons, organisations or group people designated in the list of persons and entities associated with terrorism and terrorist financing. 4. Bribery of the relevant staff or officer concerned or acting as an intermediary therein. 5. Other activities that contravene laws and regulations. Article 25 Prohibitions for relevant staffs and authorities The relevant staffs and authorities are prohibited from the following behaviours:
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13 7. Issue an order to seize or freeze funds immediately based on the report from the reporting entities, including postal enterprises, natural person, legal person, or any organization currently utilizing administrative measures. 8. Propose to NCC to consider adding or removing a name from the Domestic Designation List. 9. Notify to reporting entities to update them and terminate the application of provisional measure in the case of the fund that not associated with the list of persons associated with terrorism and terrorist financing. 10. Coordinate with the relevant ministries, organisations, and local governments in withholding, seizing or freezing funds related to terrorists or the financing of terrorism. 11. Summarise and report on withholding, seizing or freezing funds related to terrorists or the financing of terrorism. 12. Deploy rights and duties as defined in the laws and regulations. Article 29 Rights and Duties of the Ministry of Foreign Affairs MOFA has the rights and duties with supervising and inspecting works of withholding, seizing or freezing funds related to terrorists and the financing of terrorism as the followings:
14 Article 31 Rights and duties of the Anti-Money Laundering Intelligence Office AMLIO has the rights and duties with supervising and inspecting the activities of withholding, seizing or freezing funds related to terrorists and the financing of terrorism as the followings:
15 In carrying out inspections on the activities of withholding, seizing or freezing funds related to terrorists and the financing of terrorism must be conducted strictly in accordance with the law. Chapter 8 Policies for Outstanding Achievers and Penalties for Violators Article 35 Policies for Outstanding Achievers Natural person, legal persons and organisations making outstanding achievements in their implementation and enforcement of this this decree will be commended or benefit from the policies in accordance with laws and regulations. Article 36 Penalties for Violators Natural person, legal persons and organisations violating this decree shall be warnings, educated, disciplined, fined, compensatory damages, and/or criminal punishment, depending on the severity of the case. Chapter 9 Final Provisions Article 37 Implementation The Bank of the Lao PDR is responsible for organizing and implementing this decree effectively and efficiently. Ministries, organisations, local government, and other relevant are to recognise and strict implementation of this decree. Article 38 Entry into Force This Decree enters into force from the date of signature. Government of the Lao PDR The Prime Minister