Financial Crime World

Combating Money Laundering and Terrorist Financing in Syria

Introduction

Syria has taken steps to combat money laundering (ML) and terrorist financing (TF), including the establishment of the Combating Money Laundering and Terrorist Financing Commission (CMLTFC). The CMLTFC plays a crucial role in receiving suspicious transaction reports (STRs), conducting financial investigations, and providing information to competent authorities.

Law Enforcement

Syria has largely complied with Recommendation 27 and 28 related to law enforcement authorities, judicial lawsuits, and other competent authorities. However, there is no disclosure/declaration system for cash amounts and bearer financial instruments at borders, which hinders the effective implementation of AML/CFT measures.

Financial Institutions

Syrian financial institutions are subject to various regulations and supervision:

  • Banks: Controlled by the Council for Money and Credit (CMC) and supervised by the Banking Supervision Department (BSD), which conducts on-site and off-site monitoring, including verification of AML/CFT compliance.
  • Money changers: Also under the authority of the CMC but none have been registered yet.
  • Insurance sector: Regulated by the Insurance Supervisory Commission (ISC), which can suspend or notify official bodies in case of ML acts.

Preventive Measures

Syria has implemented some preventive measures:

  • CMLTFC Compliance Unit: Verifies implementation of AML/CFT measures through its Compliance Unit.
  • BSD monitoring: Conducts on-site and off-site monitoring of banks, including verification of AML/CFT compliance.
  • ISC regulation: Regulates and monitors the insurance sector, can suspend or notify official bodies in case of ML acts.

Recommendations

To enhance Syria’s AML/CFT regime:

  1. Establish a disclosure/declaration system for cash amounts and bearer financial instruments at borders.
  2. Enhance the CMLTFC’s human and technical resources to effectively fulfill its mission.
  3. Implement the forms provided in the Law on Combating Money Laundering and Terrorist Financing (LD No. 33 of 2005) to notify the CMLTFC of cash amounts exceeding a certain limit.

By implementing these recommendations, Syria can strengthen its AML/CFT regime and effectively combat ML/TF operations.