Financial Crime World

Title: Tunisia’s Financial Crime Reporting Requirements: A Comprehensive Overview of Identity Verification Procedures

Subtitle

Understanding the Regulations, Requirements, and Best Practices for Identity Verification in Tunisia

January 2019: Tunisian Government Amends Anti-Money Laundering (AML) and Know Your Customer (KYC) Regulations

In January 2019, the Tunisian government passed Organic Law No. 2019-9, which introduced new regulations and responsibilities for legal and natural persons in preventing and detecting money laundering and terrorist financing in Tunisia. Businesses and individuals operating within the country must adhere to these regulations, especially regarding customer screening, identity verification, and reporting unusual transactions.

Scope

This article provides a comprehensive overview of the Tunisian AML and KYC identity verification requirements based on recommendations from the Tunisian Financial Analysis Committee (CTAF) and the recently amended Tunisian law.

Definitions

  • Client: Shufti Pro’s customer
  • Customer: The client’s customer subjected to KYC-AML checks
  • End-user: The client’s customer, as perceived by Shufti Pro
  • Document Verification: The process of verifying the authenticity of a government-issued identity document
  • Identity Verification: The process of verifying the identity of a client’s customer
  • Proof of Identity: Any government-issued identity document that can identify an individual
  • Enhanced Due Diligence (EDD): A process with a greater level of scrutiny concerning potential business relationships
  • Third-Party Due Diligence: Outsourcing the due diligence process to an external party
  • Politically Exposed Person (PEP): A person with a higher risk for potential involvement in bribery or corruption

Introduction

With the increasing complexity of AML and KYC procedures in Tunisia, it is essential for businesses and individuals to understand the guidelines and measures for conducting proper and satisfactory identity verification procedures. In the following sections, we will discuss the Tunisian regulations and best practices for identity verification.

Requirements for Identity Verification in Tunisia

The regulations require identity verification for natural persons in Tunisia in the following aspects:

  1. Full Name
  2. Address

To ensure regulatory compliance, businesses may adopt various methods to verify the identity of their clients’ customers.

Compliant Customer Due Diligence (CDD) Methods

Shufti Pro offers the following CDD methods for identity verification in Tunisia:

  1. End-user Identity Verification: Shufti Pro performs identity verification of the end-user using independent-sourced documents. These documents are reliable and confirm the end-user’s identity in Tunisia.
  2. Document Verification: Shufti Pro ensures document authenticity through specialized document verification services to guarantee the validity of the submitted identity documents.

Documents Required for Verification

Various documents serve as proof of identity and address in Tunisia, such as:

  • Identity cards
  • Driving licenses
  • Passports

Timing of Verification

Identity verification is not a one-time process but a requirement at multiple stages, as per regulations:

  1. Upon onboarding a new customer
  2. During specific transactions as required

Politically Exposed Persons (PEPs) and EDD Measures

Enhanced due diligence (EDD) regulations require that businesses determine if their customers are PEPs or hold public offices in Tunisia. Shufti Pro’s AML Screening service aids in fulfilling these obligations by screening individual ID attributes (Name and DOB) against global regulatory authorities’ watchlists, foreign and domestic databases, compromised PEPs, and sanctioned individuals. The service highlights the category of PEP based on the degree of risks they pose, as well as any immediate family member or close associates of the PEP.

Reliance on External Services

Though not explicitly regulated, businesses may choose to rely on third-party services like Shufti Pro for fulfilling AML and KYC obligations. It is important to remember that the ultimate responsibility for regulatory compliance and fulfilling AML and KYC obligations lies with the client.

Record Retention

Businesses in Tunisia are required to retain data for a minimum of ten years under the Tunisian Act. In cases where the information is processed, collected, and managed by a third party, businesses are responsible for collecting all necessary due diligence data from the third party without undue delay.