Higher Risk
 
Medium Risk
 
Info n/a
 
Lower Risk
Bilateral exchange of information
Agreements in place?
    No
Sanctions:

The EU have adopted restrictive measures against individuals
responsible for misappropriation of State funds. These individuals
will be members of the ousted Tunisian President Zine el-Abidine
Ben Ali's government and family members.

For further information, please click on the following link: -

http://www.europa-eu-un.org/articles/en/article_10614_en.htm


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:

Tunisia is not considered an important regional financial center.
Tunisia has strict currency exchange controls which authorities
believe mitigate the risk of international money laundering. There
is a low level of crime in Tunisia. The primary domestic criminal
activities that generate laundered funds are clandestine
immigration, trafficking in stolen vehicles, and narcotics. There
also is informal economic activity involving smuggled goods.
However, there is no evidence to suggest significant levels of
narcotics are involved or that smuggling generates funds that are
laundered through the financial system.

As of yearend 2009, Tunisia had eight offshore banks and a
considerable number of offshore international business
companies. Tunisia also has two free trade zones, in Bizerte and
Zarzis, with a limited number of companies manufacturing
products for export. There are no offshore financial institutions
located in either free trade zone.

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: All serious crimes

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 2009 Country Reports
on Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/2009/140886.htm)

KNOW-YOUR-CUSTOMER RULES:

Covered entities: All financial institutions

Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: All financial institutions and financial
intermediaries

Number of STRs received and time frame: Not available

Number of CTRs received and time frame: Not available

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: Not available

Convictions: Not available

Assets forfeited: criminally: Not available civilly: Not available

RECORDS EXCHANGE MECHANISM:

With U.S.: NO

With other governments/jurisdictions: YES

Tunisia is a member of the Middle East North Africa Financial
Action Task Force (MENAFATF), a Financial Action Task Force-
style regional body. Its most recent mutual evaluation can be
found here: http://www.menafatf.
org/images/UploadFiles/MENAFATF.7.07.E.P5R2%20_with%
20response_.pdf

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

The Government of Tunisia (GOT) should continue to implement
and enhance its anti-money laundering/counter-terrorist financing
(AML/CFT) regime. GOT authorities should disseminate statistics
and benchmarks such as prosecutions and convictions that will
aid in measuring progress. Since Tunisia has strict currency
controls, in all likelihood informal remittance systems such as
hawala are prevalent. Authorities should examine underground
finance and its possible link to money laundering and extremist
finance. Regionally, invoice manipulation and customs fraud is
often involved in hawala counter-valuation. As a result, authorities
should be aware of trade-based laundering and value transfer.

All offshore financial institutions are held to the same regulatory
standards as onshore financial institutions. Offshore financial
institutions undergo the same due diligence process as onshore
banks and are licensed only after the Central Bank investigates
their references and the Ministry of Finance approves their
applications. Anonymous directors are not allowed. Offshore
international business companies are subject to all regulatory
requirements, except for tax requirements and currency
convertibility restrictions. Bearer financial instruments or shares
are strictly prohibited.

____________________________________________________

US State Dept Narcotics Report 2011 (introduction):

No report available

____________________________________________________

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

(Tier 2 Watch List)

Tunisia is a source, destination, and possible transit country for
men, women, and children subjected to forced labor and sex
trafficking. Some Tunisian girls in domestic work in Tunis and
other governorates are trafficking victims. In northwest Tunisia, a
network of brokers and hiring agencies facilitates child domestic
work and domestic servitude, sometimes via weekly markets. One
study and information from an NGO indicate that 30 percent of
the girls enter domestic work before the age of 14; some enter as
early as ages 6 or 7. The majority has no vacation, no work
contracts, and the ones who live in their employers’ homes have
neither set hours of work nor freedom of movement. Almost all of
the girls in the study admitted ill-treatment, including forced
starvation and physical abuse; approximately one-fifth of the girls
surveyed have been sexually abused as well. Thirty percent were
forced to leave school, two-thirds want to change jobs, and almost
all were unaware of labor laws. Fathers take and have control of
the salary until the girls reach about 16 or 17. These are
indicators of potential forced labor.

In 2010 and 2009, seven Tunisian females were rescued from
forced prostitution in Lebanon and a female from Cote D’Ivoire
was forced into domestic servitude by a senior staff member of
the African Development Bank in Tunis. In that same period, an
online magazine alleged that dozens of children under 16 were
victims of forced labor and prostitution for Libyan tourists. In 2008,
two women were rescued from forced prostitution in Jordan and
three men from forced labor in Italy.

The Government of Tunisia does not fully comply with the
minimum standards for the elimination of trafficking and has been
placed on Tier 2 Watch List for the last three consecutive years.
Tunisia was not placed on Tier 3 per Section 107 of the 2008
Trafficking Victims Protection Reauthorization Act, however, as
the government has a written plan that, if implemented, would
constitute making significant efforts to bring itself into compliance
with the minimum standards for the elimination of trafficking and is
devoting sufficient resources to implement that plan. Under the
leadership of former Tunisian President Ben Ali, the government
did not show evidence of progress in prosecuting and convicting
trafficking offenders, proactively identifying or protecting
trafficking victims, or raising public awareness of human trafficking
over the last year. Victims of trafficking likely remain undetected
because of a lack of the previous government’s effort to identify
them among vulnerable groups. However, in January 2011, Ben
Ali was removed from power after 24 years of rule as the result of
a popular revolution. The interim Government of Tunisia that
replaced the Ben Ali regime has indicated their commitment to
fight human trafficking through important initial steps. Most
notably, the current government has established a National
Commission to Combat Trafficking in Persons and is drafting
comprehensive counter-trafficking legislation.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2010

Overview: The Government of Tunisia placed a high priority on
countering terrorism, using tight border and internal security
controls to deter the formation of terrorist groups and block any
potential for terrorist actions; social programs to reduce the
impact of high unemployment and help prevent radicalization; and
prosecution to punish potential terrorists. Domestically, the
Tunisian government had a strong internal security apparatus
through which it provided a tight security net across the country
including check points, and unannounced identity document
checks. It provided extensive security for those events or persons
that could potentially attract terrorist attention, such as the annual
Jewish pilgrimage to the island of Djerba, soccer games, and
public demonstrations.

Legislation and Law Enforcement: The Tunisian government
prosecuted at least 40 separate terrorism-related cases in 2010,
many including multiple defendants. Of those cases, two involved
people accused of joining a terrorist group outside the country,
one case included charges of providing weapons, two cases
involved receiving training for terrorist purposes, and several
cases included charges of recruiting. The majority of charges,
however, related to collecting money without authorization, joining
a terrorist group, setting up an illegal group, holding unauthorized
meetings, neglecting to inform the authorities of terrorist acts,
and/or downloading prohibited material.

Countering Terrorist Finance: Tunisia is a member of the Middle
East and North Africa Financial Action Task Force (MENAFATF).
The head of Tunisia's Financial Intelligence Unit served as
MENAFATF’s President in 2010. The Tunisian government has
complied with UNSCRs 1267 and 1373 in many respects,
generally concerning the implementation of effective financial
controls in Tunisia. There were at least four court cases in 2010
where individuals were charged with collecting or donating money
with intent to support terrorist goals.

Regional and International Cooperation: The principal focus of
Tunisian government counterterrorism efforts was to secure its
territory. Thus, it worked with its neighbors Libya, Algeria, France,
and Italy to seek information on migration and smuggling issues
and to improve its border security. In December, the Tunisian
government signed a new security agreement with Mauritania.
Tunisia is a Mediterranean Partner for Cooperation in the OSCE.
The Tunisian government participated in the October OSCE
Mediterranean Conference on European Security, and in the
December OSCE Summit in Kazakhstan. In his presentation at the
OSCE Summit, Secretary of State for Maghreb, Arab, and African
Affairs Harguem emphasized Tunisia's commitment to countering
terrorism, expressed concern that unilateral security measures
have reached the limits of their effectiveness, and called for
greater international mobilization to create a global response to
the phenomena of marginalization, exclusion, and poverty that
encourage violent extremism. Tunisia is also host to the Arab
League's Arab Interior Ministers' Council, which meets annually. In
the December meeting, the ministers focused on combating
terrorist use of the Internet. Tunisia acceded to the International
Convention for the Suppression of Acts of Nuclear Terrorism, as
well as the 2005 Amendment to the Convention on the Physical
Protection of Nuclear Material.

Countering Radicalization and Violent Extremism: The Tunisian
government continued to maintain tight control over the religious
establishment, appointing imams, dictating Friday sermons,
closing mosques between prayer times, refurbishing mosques in
need of repair, and keeping watch at the local level over who
attends services. The Tunisian government promoted a moderate
form of Islam through the educational system and the media.
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
73 (out of
183)
59 (out of
178)
?
Ease of doing business (World Bank)
46 (out of
183)
55 (out of
183)
?
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
9
13
17
9
1
Legal Systems
 
1. Money Laundering Offence
L
 
14. Protection & no tipping-off
L
2. ML offence – mental element and
corporate liability
L
 
15. Internal controls,
compliance & audit
N
3. Confiscation and provisional
measures
C
 
16. DNFBP – R.13-15 & 21
N
4. Secrecy laws consistent with the
Recommendations
C
 
17. Sanctions
L
5. Customer due diligence
N
 
18. Shell banks
P
6. Politically exposed persons
N
 
19. Other forms of reporting
P
7. Correspondent banking
P
 
20. Other NFBP & secure
transaction techniques
L
8. New technologies & non
face-to-face business
P
 
21. Special attention for
higher risk countries
P
9. Third parties and introducers
P
 
22. Foreign branches &
subsidiaries
L
10. Record keeping
C
 
23. Regulation, supervision
and monitoring
P
11. Unusual transactions
P
 
24. DNFBP - regulation,
supervision and monitoring
P
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
P
 
25. Guidelines & Feedback
N
13. Suspicious transaction reporting
P
     
Institutional and other
measures
 
26. The FIU
P
 
31. National co-operation
P
27. Law enforcement authorities
C
 
32. Statistics
N
28. Powers of competent authorities
C
 
33. Legal persons –
beneficial owners
L
29. Supervisors
L
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
L
 
 
 
International Co-operation
 
35. Conventions
P
 
38. MLA on confiscation and
freezing
P
36. Mutual legal assistance (MLA)
L
 
39. Extradition
C
37. Dual criminality
C
 
40. Other forms of
co-operation
P
Nine Special
Recommendations
 
SR.I Implement UN instruments
N
 
SR VI AML requirements for
money/value transfer services
L
SR.II Criminalise terrorist financing
C
 
SR VII Wire transfer rules
N
SR.III Freeze and confiscate
terrorist assets
N
 
SR.VIII Non profit
organisations
C
SR.IV Suspicious transaction
reporting
P
 
SR.IX Cross Border
Declaration & Disclosure
L
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.
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2008
Further Tables
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
EU
?
Is it on FATF list of non-cooperative countries?
N
?
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
?
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)
M
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
Y
 
-  Criminalized Beyond Drugs?
Y
 
-  Record Large Transactions?
Y
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Financial Intelligence Unit?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
N
 
-  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
 
TUNISIA
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
Y
 
-  Report Suspected Terrorist Financing?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
________________________________________________________

AML News / Updates

February 1, 2011  -  EU adopts restrictive measures against individuals
responsible for misappropriation of State funds in Tunisia

Read Summary....

January 28, 2011  -  EU set to freeze assets of Tunisia's Ben Ali

Read more.....

January 23, 2011  -  US Treasury issues guidance to financial
institutions on recent events in Tunisia.

Read report.....


Links:

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Last Updated:   16 April 2012