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Tunisia Struggles to Meet International Standards on Financial Institutions’ Compliance Obligations

A recent report by the Financial Action Task Force (FATF) has found that Tunisia has made significant progress in implementing international standards on combating money laundering and terrorist financing, but still has some way to go.

Progress Made

Tunisia has been rated as “largely compliant” (LC) in several areas, including:

Customer due diligence
Record-keeping
Internal controls

However, the country was found to be “partially compliant” (PC) in terms of national cooperation and coordination, with some weaknesses identified in this area.

Areas for Improvement

Tunisia was found to be “non-compliant” (NC) in certain key areas, including:

Confiscation and provisional measures required to combat money laundering
Regulation and supervision of financial institutions

The country also needs to improve its powers of supervisors.

Importance of Continued Efforts

The FATF report highlights the importance of Tunisia continuing to strengthen its efforts to implement international standards on combating money laundering and terrorist financing. The country’s financial institutions must be able to demonstrate a high level of compliance with these standards in order to maintain their reputation and prevent reputational risk.

Government Commitment

Tunisia’s government has committed to addressing the recommendations made by the FATF report, including:

Improving national cooperation and coordination
Strengthening regulation and supervision
Enhancing its powers of supervisors

The country will also be required to submit regular progress reports to the FATF to demonstrate its continued commitment to implementing international standards.

FATF Ratings

The following are the FATF ratings for Tunisia:

Risk Assessment and Application

R.1: Assessing risk & applying risk-based approach (LC)
R.2: National cooperation and coordination (PC)

R.3: Money laundering offence (C)
R.4: Confiscation and provisional measures (NC)
R.5: Terrorist financing offence (LC)
R.6: Targeted financial sanctions related to terrorism & terrorist financing (C)

Financial Institution Secrecy Laws and Customer Due Diligence

R.7: Targeted financial sanctions related to proliferation (LC)
R.8: Non-profit organisations (C)
R.9: Financial institution secrecy laws (C)
R.10: Customer due diligence (LC)
R.11: Record keeping (C)

Politically Exposed Persons and Correspondent Banking

R.12: Politically exposed persons (LC)
R.13: Correspondent banking (LC)
R.14: Money or value transfer services (LC)

New Technologies and Wire Transfers

R.15: New technologies (LC)
R.16: Wire transfers (LC)

Reliance on Third Parties and Internal Controls

R.17: Reliance on third parties (LC)
R.18: Internal controls and foreign branches and subsidiaries (LC)

Higher-Risk Countries and Reporting of Suspicious Transactions

R.19: Higher-risk countries (LC)
R.20: Reporting of suspicious transactions (C)
R.21: Tipping-off and confidentiality (C)

DNFBPs and Transparency

R.22: DNFBPs: Customer due diligence (LC)
R.23: DNFBPs: Other measures (PC)
R.24: Transparency and beneficial ownership of legal persons (LC)
R.25: Transparency and beneficial ownership of legal arrangements (LC)

Regulation and Supervision

R.26: Regulation and supervision of financial institutions (LC)
R.27: Powers of supervisors (LC)

Financial Intelligence Units and Responsibilities of Law Enforcement and Investigative Authorities

R.28: Regulation and supervision of DNFBPs (LC)
R.29: Financial intelligence units (LC)
R.30: Responsibilities of law enforcement and investigative authorities (C)

Other Areas

R.31: Powers of law enforcement and investigative authorities (LC)
R.32: Cash couriers (LC)
R.33: Statistics (PC)
R.34: Guidance and feedback (LC)
R.35: Sanctions (LC)
R.36: International instruments (LC)

Note: C = compliant, LC = largely compliant, PC = partially compliant, NC = non-compliant