Circular MOET/AML/001/2026 to real estate brokers, dealers in precious metals and stones, auditors, accountants and corporate services providers. It notifies National Committee Resolution No. 15 of 2025 updating the FATF high-risk and increased-monitoring lists, requires enhanced due diligence on relationships linked to those countries, bars branches, subsidiaries or third-party reliance in blacklisted countries, and recalls targeted financial sanctions duties.
Circular No. 1 of 2026 (reference MOET/AML/001/2026), issued by the Ministry of Economy and Tourism on 11 March 2026 and effective from the date of issue, tells the DNFBPs the Ministry supervises how to treat customers and transactions connected to the countries on the FATF lists. It is addressed to real estate brokers and agents, dealers in precious metals and stones, auditing and accounting firms and corporate services providers. It notifies National Committee Resolution No. 15 of 2025, which updated the national lists of high-risk countries and countries subject to increased monitoring, and states that it reaffirms and continues existing obligations rather than creating new ones.
The legal basis is Federal Decree-Law No. 10 of 2025, its implementing regulation Cabinet Resolution No. 134 of 2025 and Cabinet Decision No. 74 of 2020 on targeted financial sanctions; no article numbers are cited. The circular is in four sections. The first sets out the introduction and legal basis. The second states the obligations in three parts. Part 1, general obligations: monitor and review the updated lists issued by the FATF and the National Committee, and build them into the enterprise risk assessment, due diligence policies and the management of relationships and transactions. Part 2, high-risk countries (the FATF call-for-action or blacklist): apply enhanced due diligence to all business relationships and transactions related to such countries; refrain from establishing branches, representative offices or subsidiaries there; strengthen internal reporting and file suspicious transaction reports with the Financial Intelligence Unit through goAML where appropriate; refrain from relying on third parties located in high-risk countries to carry out customer due diligence; and apply targeted financial sanctions under the UN Security Council resolutions and Cabinet Decision No. 74 of 2020. Part 3, countries under increased monitoring (the grey list): apply enhanced due diligence proportionate to the risk arising from dealings with those countries, and take FATF updates into account when assessing risk and reviewing relationships and transactions.
The third section states that DNFBPs must comply with all the measures within the scope of their activities and that failure to comply results in administrative measures and penalties under the applicable laws, without prejudice to other liability. The fourth section gives the reference links: the FATF increased-monitoring and call-for-action lists in their February 2026 edition, and the National Committee's official high-risk countries page. The circular does not itself name the countries; the operative lists are those published by the FATF and the National Committee and they change at each FATF plenary, so the circular's practical effect is to require continuous monitoring rather than a one-off check. It is signed by the Director of the Anti-Money Laundering and Terrorist Financing Department.
Designated non-financial businesses and professions supervised by the Ministry of Economy and Tourism: real estate brokers and agents, dealers in precious metals and precious stones, auditing and accounting firms, and corporate services providers, in respect of any customer, beneficial owner, counterparty or transaction connected to a country on the FATF high-risk or increased-monitoring lists.
| Section First (Introduction and Legal Basis) | Notifies National Committee Resolution No. 15 of 2025 updating the national high-risk and increased-monitoring lists, cites Decree-Law No. 10 of 2025, Cabinet Resolution No. 134 of 2025 and Cabinet Decision No. 74 of 2020, and states that the circular reaffirms existing obligations and creates no new ones. |
| Section Second, Part 1 (General Obligations) | Monitor and review the updated FATF and National Committee lists and build them into the risk assessment, due diligence policies and the management of relevant relationships and transactions. |
| Section Second, Part 2 (High-Risk Countries) | Apply enhanced due diligence to all business relationships and transactions related to blacklisted countries, strengthen internal reporting and file suspicious transaction reports through goAML where appropriate. |
| Section Second, Part 2 (High-Risk Countries) | Refrain from establishing branches, representative offices or subsidiaries in high-risk countries and from relying on third parties located there to conduct customer due diligence; apply targeted financial sanctions under UN Security Council resolutions and Cabinet Decision No. 74 of 2020. |
| Section Second, Part 3 (Increased Monitoring) | Apply enhanced due diligence proportionate to the risk arising from dealings with grey-listed countries and take FATF updates into account when assessing risk and reviewing relationships and transactions. |
| Section Third (Compliance and Administrative Sanctions) | DNFBPs must comply with all the measures within their scope of activity; failure to comply results in administrative measures and penalties under the applicable laws without prejudice to other legal liability. |
| Section Fourth (Relevant Lists and Reference Links) | Points to the FATF increased-monitoring and call-for-action lists (February 2026 edition) and the National Committee's high-risk countries page as the operative sources; the circular is effective from its date of issue. |
The circular sets no fines of its own. Section Third states that failure to comply results in administrative measures and penalties under the applicable laws, which for Ministry-supervised DNFBPs means the sanctions in Article 17 of Decree-Law No. 10 of 2025 and the DNFBP penalty schedule in Cabinet Resolution No. 71 of 2024, without prejudice to other legal liability.
As a corporate services provider under Ministry supervision this circular is addressed to us directly. We keep the FATF list check as a dated step in our onboarding and periodic review procedures, so that any client, shareholder, beneficial owner or counterparty with nationality, residence, incorporation or transaction flows linked to a listed country is automatically rated high risk and moved to enhanced due diligence: source of funds and wealth evidence, senior management sign-off and closer transaction monitoring. We do not accept due diligence performed by an introducer based in a blacklisted country, and when a client proposes a branch or subsidiary in one we explain that the circular bars it for supervised businesses. Grey-list connections get a proportionate uplift rather than an automatic refusal, which is the balance the circular strikes. We also pass the same approach to the accounting, audit and real estate clients we license, since they are addressees too.
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