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Deficiencies in Syria’s Anti-Money Laundering and Combating the Financing of Terrorism Framework

Introduction

The Syrian Arab Republic has been assessed for its anti-money laundering (AML) and combating the financing of terrorism (CFT) framework. This report highlights various deficiencies in the country’s laws and regulations related to AML/CFT.

Key Deficiencies

Deficiency 1: Absence of Laws and Regulations Requiring FIs to Provide Customer Identification Records

• Article 5(c) of Legislative Decree No. 30 (2010) prohibits using bank secrecy when verifying compliance with AML/CFT measures.
• However, there is no legislative provision obligating financial institutions (FIs) to provide customer identification records to authorities.

Deficiency 2: Obligations Related to Customer Identification Verification for Dealing through Agents and Legal Persons

• Syria has addressed this deficiency through Article 2 of the executive instructions, which requires FIs to ensure that the person claiming to act on behalf of a customer is authorized and to identify and verify their identity.
• However, there are no supervisory instructions issued to insurance companies in this regard.

Deficiency 3: Absence of Legislative Provisions Obligating Insurance Companies, Exchange Institutions, and Other FIs

• The executive instructions of Legislative Decree No. 33 (2014) obligate all FIs to determine the owner of economic rights and verify their identity.
• However, there are no legislative provisions specifically requiring insurance companies, exchange institutions, and other FIs to:
  • Verify the identity of beneficial owners
  • Identify natural persons owning legal persons or exercising ultimate effective control over them
  • Perform ongoing supervision operations

Conclusion

The Syrian Arab Republic’s AML/CFT framework has several deficiencies that need to be addressed. These include the absence of laws and regulations requiring FIs to provide customer identification records, obligations related to customer identification verification for dealing through agents and legal persons, and the absence of legislative provisions obligating insurance companies, exchange institutions, and other FIs.

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