Higher Risk
 
Medium Risk
 
Info n/a
 
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Bilateral exchange of information
Agreements in place?
    No
FATF Statement re AML Strategic Deficiencies:

Date:  16 February 2012


In February 2010, Morocco made a high-level political commitment
to work with the FATF and MENAFATF to address its strategic
AML/CFT deficiencies. Since then, Morocco has demonstrated
progress in improving its AML/CFT regime, including by adopting
amendments to extend the scope of the money laundering and
terrorist financing offences; to broaden customer due diligence
requirements and taking steps to operationalise the Financial
Intelligence Unit. However, the FATF has determined that certain
strategic AML/CFT deficiencies remain. Morocco should continue
to work on implementing its action plan to address these
deficiencies, including by adequately criminalising terrorist
financing (Special Recommendation II).

____________________________________________________

Sanctions:

November 28, 2011  -  The Arab League (comprising 22 Arab
member states), of which this country is a member, has approved
imposing sanctions on Syria. These include: -

* Cutting off transactions with the Syrian central bank
* Halting funding by Arab governments for projects in Syria
* A ban on senior Syrian officials travelling to other Arab countries
* A freeze on assets related to President Bashar al-Assad's
government

The declaration also calls on Arab central banks to monitor
transfers to Syria, with the exception of remittances from Syrians
abroad.

For further information, click here



The Arab League (comprising 22 Arab member states), of which
this country is a member, has boycotted Israel in a systematic
effort to isolate Israel economically in support of the Palestinians,
however, the implementation of the boycott has varied over time
among member states..

There are three tiers to the boycott. The primary boycott prohibits
the importation of Israeli-origin goods and services into boycotting
countries. The secondary boycott prohibits individuals, as well as
private and public sector firms and organizations, in member
countries from engaging in business with any entity that does
business in Israel. The Arab League maintains a blacklist of such
firms. The tertiary boycott prohibits any
entity in a member country from doing business with a company or
individual that has business dealings with U.S. or other firms on
the Arab League blacklist.

____________________________________________________

Offshore Jurisdiction Blacklists – Further Information:

As a recognised offshore finance jurisdiction this country may fall
under various country offshore jurisdiction blacklists.

____________________________________________________

US State Department Money Laundering Report - 2011:

Morocco is not a regional financial center but is well integrated
into the international financial system. Money laundering is a
concern due to Morocco’s international narcotics trade, vast
informal sector, trafficking in persons, and large level of
remittances from Moroccans living abroad. Cash-based
transactions in connection with cannabis trafficking are of
particular concern. Morocco remains the world’s second largest
producer of cannabis, with revenues estimated at over $13 billion
annually. While some of the narcotics proceeds are laundered in
Morocco, most proceeds are thought to be laundered in Europe.
The predominant use of cash, informal value transfer systems
and remittances from abroad help fuel Morocco’s informal sector.
Only three in ten Moroccans use banks; credible estimates of
Morocco’s informal sector place it at nearly 15 percent of GDP,
and potentially employing over a third of the urban workforce. In
2009, remittances from Moroccans living abroad were
approximately nine percent of GDP and drive household
consumption by large segments of the population.

Offshore banks are located in the Tangier free zone. They are
regulated by an interagency commission chaired by the Ministry of
Finance. The free trade zone also allows customs exemptions for
goods manufactured in the zone for export abroad. There have
been no reports of trade-based money laundering schemes or
terrorist financing activities using the Tangier free zone.

Criminal activities of particular risk include bulk cash smuggling,
and unverified reports of trade-based money laundering,
including under- and over-invoicing and the purchase of
smuggled goods. Most businesses are cash-based with little
invoicing or paper trails. Unregulated money exchanges remain a
problem in Morocco and were a prime impetus for Morocco’s anti-
money laundering legislation. Although the legislation targets
previously unregulated cash transfers, the country’s vast informal
sector creates conditions for this practice to continue.

DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: NO

CRIMINALIZATION OF MONEY LAUNDERING:

“All serious crimes” approach or “list” approach to predicate
crimes: List approach

Legal persons covered: criminally: YES civilly: YES

CRIMINALIZATION OF TERRORIST FINANCING:

Ability to freeze terrorist assets without delay: YES

UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES

(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)

KNOW-YOUR-CUSTOMER RULES:

Covered entities: Domestic and offshore banks, finance
companies, insurance industry, lawyers, accountants, real estate
intermediaries, and gaming operators

Enhanced due diligence procedures for PEPs: Foreign: NO
Domestic: NO

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: Domestic and offshore banks, finance
companies, insurance industry, lawyers, accountants, real estate
intermediaries, and gaming operators

Number of STRs received and time frame: 70 since October 2009

Number of CTRs received and time frame: Not available

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: Nine since October 2009

Convictions: Nine since October 2009

Assets forfeited: criminally: Not available civilly: Not available

RECORDS EXCHANGE MECHANISM:

With U.S.: YES

With other governments/jurisdictions: YES

Morocco is a member of the Middle East North Africa Financial
Action Task Force (MENAFATF), a Financial Action Task Force
(FATF)-style regional body. Its most recent mutual evaluation can
be found here: http://www.menafatf.org/TopicList.asp?cType=train

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

The Government of Morocco (GOM) has made considerable
progress since the promulgation of the 2007 AML law. The
juridical framework for countering illicit finance continues to be
refined, and a series of proposed amendments responds well to
Morocco’s practical experience. The establishment of Morocco’s
financial intelligence unit (FIU) in October 2009 was a
considerable mark of progress. Morocco’s ability to enforce its
anti-money laundering statutes should improve as the FIU
becomes operational. Proposed amendments, currently under
consideration by the Parliament, will further clarify and stipulate
STR processing requirements.

The size and adaptive nature of Morocco’s informal economy
presents serious concerns. Regulatory oversight and investigative
expertise must be developed that targets Morocco’s large money
remittance networks. Regional trade-based money laundering and
informal value transfer systems should be addressed.

____________________________________________________

US State Dept Narcotics Report 2012 (introduction):

Morocco is one of two countries – along with Afghanistan –
identified by the United Nations Office on Drugs and Crime
(UNODC) as a leading source for cannabis cultivation and
production. The country is also consistently cited as a primary
origin for cannabis seizures made in Europe, and several
seizures of multi-ton loads of cannabis in Morocco during 2011
underscore its continued role in cannabis production and
trafficking.

However, Morocco has made impressive inroads in reducing
overall cannabis cultivation, a traditional and lucrative, albeit
illegal, cash crop. According to the Government of Morocco
(GOM), the amount of land devoted to cannabis cultivation has
fallen by 65 percent from 2003 to 2010. No additional land was
targeted for crop substitution during 2011, with the GOM citing
several reasons for this policy, including the effectiveness of
ongoing surveillance of illicit crops.

Morocco’s centuries-old trade routes serve as a crossroads of two
continents, and have been exploited by narcotics traffickers for
the movement of cannabis, cocaine and other drug trafficking
from Africa to Europe.

Illicit drug use has generally not been a major concern for the
GOM in previous years, as narcotics consumption was viewed
primarily as a European problem. However, following a pattern in
other transit countries the GOM has reported an increase in the
domestic use of cocaine and ecstasy, and is taking more
proactive measures in drug treatment and demand reduction.

Morocco is a party to the 1988 UN Drug Convention.

For Full report, click here

____________________________________________________

US State Dept Trafficking in Persons Report 2011
(introduction):

(Tier 2)

Morocco is a source, destination, and transit country for men,
women, and children who are subjected to trafficking in persons,
specifically forced labor and forced prostitution. Children are
trafficked within the country from rural areas to urban centers to
work as maids or laborers, or for commercial sexual exploitation.
Moroccan men, women, and children are exploited for forced
labor and prostitution in European and Middle Eastern countries.
Young Moroccan girls from rural areas are recruited to work as
child maids in cities, but often experience non-payment of wages,
threats, and physical or sexual abuse, and sometimes face
restrictions on movement. These practices indicate that these
girls are subjected to involuntary servitude. Moroccan boys
experience forced labor as apprentices in the artisan and
construction industries and in mechanic shops. Moroccan women
are forced into prostitution in Gulf States – including the United
Arab Emirates and Bahrain – Jordan, Libya, Syria, and European
countries; some of them experience restrictions on movement,
threats, and emotional and physical abuse. Some Moroccan men
reportedly are promised jobs in the Gulf but experience
confiscation of their passports and are coerced into debt bondage
after arrival. A few Moroccan men and boys are lured to Europe
by fraudulent job offers, and are subsequently forced to sell
drugs. In addition, men and women from sub-Saharan Africa,
South Asia, and the Philippines enter Morocco voluntarily but
illegally with the assistance of smugglers; once in Morocco, some
of the women are coerced into prostitution or, less frequently,
forced into domestic service. Nigerian gangs, who engage in a
variety of criminal activities like people smuggling and drug
trafficking, compete to control the trafficking of sub-Saharan
Africans in Morocco.

The Government of Morocco does not comply with the minimum
standards for the elimination of trafficking; however, it is making
significant efforts to do so. The government convicted one person
who subjected a 13 year-old child domestic worker to forced
labor, though it continued to lack overall progress in the following
areas: convicting and punishing trafficking offenders with
punishments commensurate with the heinous nature of the
offense; proactively identifying trafficking victims among
vulnerable groups; and ensuring that foreign trafficking victims
are not subject to arrest and deportation. The government also
continues to conflate migrant smuggling and human trafficking.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2010

Overview: Morocco’s counterterrorism efforts were comprehensive
in 2010. The Moroccan government emphasized vigilant security
measures, regional and international cooperation, and counter-
radicalization policies. Indications from Moroccan authorities’
disruption of certain groups, and the common characteristics of
those groups, continued to support previous analysis that
Morocco’s threat of terrorist attack stemmed largely from the
existence of numerous small "grassroots" extremist cells. These
groups, referred to collectively as adherents of Moroccan Salafia
Jihadia ideology, remained isolated from one another, small in
size, and tactically limited. Their international connections were
also limited. The Government of Morocco’s counterterrorism
efforts have effectively reduced the threat, but the existence of
these relatively small groups pointed to the need for continued
vigilance.

Domestic Terrorism and Terrorist Incidents: Reports of Moroccans
either preparing to go or going to terrorist fronts in Somalia, Iraq,
and Afghanistan to receive training from al-Qa’ida (AQ) linked
facilitators and/or to conduct attacks suggest Morocco remained a
source for foreign fighter pipelines. With regard to al-Qa’ida in the
Islamic Maghreb (AQIM). The group remained unable to mount a
successful terrorist attack in Morocco. Nonetheless, Moroccan
authorities remained concerned about the ideological inspiration
and knowledge transfer that AQIM may have provided to
Moroccan extremists. AQIM repeatedly tried to incite Moroccans to
commit violence against their government through website
propaganda. The government remained concerned about
numbers of veteran Moroccan violent extremists returning from
Iraq to conduct terrorist attacks at home. A further cause of
concern was Moroccans who were radicalized during their stays in
Western Europe, such as those connected with the 2004 Madrid
train bombings.

Legislation and Law Enforcement: At a tactical law enforcement
level, the Moroccan Directorate General for National Security
created a new police special weapons and tactics unit in
cooperation with the French government. The new team is based
at the Royal Police Academy in Kénitra, and, once operational, its
primary responsibilities will be to dismantle terrorist cells and carry
out other high-risk urban interventions. With regard to legislation,
the Government of Morocco generally accorded terrorist suspects
and convicts their rights and due process of law, with more access
for defense lawyers and more transparent court proceedings than
in previous years.

Morocco’s counterterrorism efforts led to the following disruptions
of alleged terrorist cells:

* In April, the Moroccan security services arrested 38 members of
an AQ-linked terrorist cell who reportedly were planning to send
Moroccan volunteers to Somalia, Iraq, and the Sahel. Some cell
members, according to the Ministry of Interior, were planning acts
of sabotage within Morocco.
* In June, Moroccan authorities arrested 11 members of a
Palestinian-led cell that had planned to carry out attacks and
assassinations of Moroccan public figures and Jewish people of
Moroccan origin, in addition to attacks on tourism sites and police
stations.
* In August, Ministry of Interior officials arrested 18 individuals in
the Tangier area who were planning to carry out terrorist attacks
in several Moroccan cities, with a specific focus on Moroccan
military bases and tourist sites that typically attract foreigners.
* In October, Ministry of Interior officials dismantled an
international network of cocaine traffickers that reportedly had
links with AQIM. The arrests included 34 individuals, at least three
of whom were foreigners. The head of the organization in
Morocco was included in these arrests and was working closely
with another man involved in the network in Mali.

Countering Terrorist Finance: Morocco has a relatively effective
system through its Financial Intelligence Unit (FIU), which became
operational in late 2009, for disseminating U.S. government and
UNSCR terrorist freeze lists to its financial sector and legal
authorities. While Morocco is not a regional financial center, it is
well integrated into the international financial system. Money
laundering was a concern due to the illicit narcotics trade, vast
informal sector, trafficking in persons, and large level of
remittances from Moroccans living abroad.

The Government of Morocco estimated that Morocco’s informal
sector accounts for 15 percent of GDP. The predominant use of
cash, informal value transfer systems, and remittances from
abroad help fuel Morocco’s informal sector. Morocco pursued
aggressive anti-money laundering legislation and has taken steps
to act against violators. Although the legislation targets previously
unregulated cash transfers, the country’s vast informal sector
created conditions for this practice to continue. As of early
December, the Moroccan Parliament was debating a new anti-
money laundering law that is similar to U.S. anti-money laundering
legislation. In addition, Morocco signed an arrangement with the U.
S. Department of Treasury to receive technical assistance in the
form of a FIU advisor.

Regional and International Cooperation: Moroccan-U.S.
cooperation was particularly strong. Moroccan authorities
continued to disrupt plots to attack Moroccan, U.S., and other
Western-affiliated targets, and aggressively investigated
numerous individuals associated with international terrorist
groups, often in collaboration with international partners. Morocco
and the United States worked together extensively on
counterterrorism efforts at the tactical level and made plans to
begin joint counter-radicalization programs.

Morocco ratified the International Convention for the Suppression
of Acts of Nuclear Terrorism. Morocco has forged solid
cooperative relationships with European and African partners by
sharing information, conducting joint operations, and participating
in training maneuvers. Morocco participates in multilateral
peacekeeping operations on the continent and in training
exercises. These were important steps, yet the lack of consistent
cooperation among countries in the region remained a potential
weakness for terrorist groups such as AQIM to exploit.
Specifically, while Morocco and Algeria are members of the Trans-
Saharan Counterterrorism Partnership, the level of bilateral
cooperation on counterterrorism between the two countries did
not improve. Morocco was specifically excluded from the Algerian-
led Combined Operational Committee (CEMOC), formed at
Tamanrasset, Algeria. Algeria and Morocco’s political
disagreement over the Western Sahara territory remained an
impediment to deeper counterterrorism cooperation.

Countering Radicalization and Violent Extremism: In addition to
traditional security measures, Morocco's King Mohammed VI has
promoted significant efforts to reduce extremism and dissuade
individuals from becoming radicalized. At Ramadan, for example,
the King hosted a series of religious lectures, inviting Muslim
speakers from around the world to promote moderate and
peaceful religious interpretations. In the past decade, and
specifically following the Casablanca (2003) and Madrid (2004)
terrorist bombings, Morocco has increasingly focused on
countering youth radicalization, upgrading places of worship,
modernizing the teaching of Islam, and strengthening the Ministry
of Endowments and Islamic Affairs (MEIA). Begun in 2007 under
the MEIA, the pioneering experiment of training and using women
as spiritual guides continued. Morocco also formed a Council of
Ulema for Europe to train and send Moroccan imams and women
spiritual guides to counter extremist messages in Moroccan
expatriate communities in Europe. In 2010, the MEIA turned its
attention to the medium of television. On June 19, Morocco
connected its 2,000 largest mosques to a new television network
named “Assadisa,” whose goal is to broadcast a tolerant version
of Islam as part of the Ministry’s drive to fight radicalism.

In 2010, the Moroccan government continued to implement
internal reforms aimed at ameliorating the socio-economic factors
that terrorists exploit. The National Initiative for Human
Development, launched by the King in 2005, is a $1.2 billion
program designed to generate employment, combat poverty, and
improve infrastructure, with a special focus on rural areas.

With regard to Morocco’s efforts to counter youth radicalization,
Morocco has accelerated its rollout of education and employment
options for youth, and expansion of legal rights and political
empowerment for women. The United States worked closely with
the Government of Morocco and key Moroccan civil society
organizations to support this initiative through innovative
assistance programs including a new USAID/INL program to work
with youth in prison, recently released from prison, and
marginalized youth at-risk of going to prison. The program also
included a significant juvenile justice reform component.
____________________________________________________

Links:

Worldwide AML Legislation (International Bar Association)
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
N
?
Is it on FATF list of non-cooperative countries?
Y
?
Is it on OECD list of uncooperative Tax Havens?
N
?
OECD - Implementation status of Tax Standard
 
?
Is it on EU 'white' list of equivalent jurisdictions?
N
?
Offshore Finance Center (Original IMF List)?
Y -
Tangier
?
Is it on the US Secretary of Treasury list of jurisdictions of
Primary Money Laundering concern?
N
?
Is it on the US Secretary of State list of jurisdictions
identified to be supporters of International Terrorism?
N
?
Is it on US Department of State International Narcotics
Control Majors List?
N
?
US Dept of State Money Laundering assessment (INCSR)
C
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
Y
 
-  Criminalized Beyond Drugs?
Y
 
-  Record Large Transactions?
N
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Financial Intelligence Unit?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
Y
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
Y
 
-  Ability to Freeze Terrorist Assets w/o delay?
Y
 
-  Disclosure Protection "Safe Harbor"?
Y
 
-  Criminalized Financing of Terrorism?
Y
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
80 (out of
183)
85 (out of
178)
?
Ease of doing business (World Bank)
94 (out of
183)
114 (out of
183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2007
Further Tables
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
3
9
9
26
2
Legal Systems
 
1. Money Laundering Offence
P
 
14. Protection & no tipping-off
C
2. ML offence – mental element and
corporate liability
L
 
15. Internal controls,
compliance & audit
N
3. Confiscation and provisional
measures
N
 
16. DNFBP – R.13-15 & 21
N
4. Secrecy laws consistent with the
Recommendations
C
 
17. Sanctions
N
5. Customer due diligence
N
 
18. Shell banks
P
6. Politically exposed persons
N
 
19. Other forms of reporting
N
7. Correspondent banking
N
 
20. Other NFBP & secure
transaction techniques
N
8. New technologies & non
face-to-face business
N
 
21. Special attention for
higher risk countries
N
9. Third parties and introducers
N/A
 
22. Foreign branches &
subsidiaries
N
10. Record keeping
L
 
23. Regulation, supervision
and monitoring
P
11. Unusual transactions
P
 
24. DNFBP - regulation,
supervision and monitoring
N
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
N
 
25. Guidelines & Feedback
N
13. Suspicious transaction reporting
N
     
Institutional and other
measures
 
26. The FIU
N
 
31. National co-operation
N
27. Law enforcement authorities
P
 
32. Statistics
N
28. Powers of competent authorities
C
 
33. Legal persons – beneficial
owners
L
29. Supervisors
N
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
N
 
 
 
International Co-operation
 
35. Conventions
L
 
38. MLA on confiscation and
freezing
L
36. Mutual legal assistance (MLA)
L
 
39. Extradition
L
37. Dual criminality
L
 
40. Other forms of
co-operation
P
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
SR VI AML requirements for
money/value transfer services
N
SR.II Criminalise terrorist financing
P
 
SR VII Wire transfer rules
N
SR.III Freeze and confiscate terrorist
assets
P
 
SR.VIII Non profit
organisations
N
SR.IV Suspicious transaction
reporting
N
 
SR.IX Cross Border
Declaration & Disclosure
N
SR.V International co-operation
L
 
 
 
*Please note that FATF deems that a country has significant aml deficiencies if any
of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated either
Partially of Non-Compliant. These are marked in red.

For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -        

R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV

Please also note that any risk assessment should take into consideration all
follow-up reports.
MOROCCO
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
Y
 
-  KYC Provisions?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
Local AML News / Sanctions
Tax Information
Business Information
Last Updated:   16 April 2012