Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Morocco MA

Domains covered

8 of 8

Sources

140

Role actions

Horizon <90d

Jurisdiction profile

FATF status: Compliant Tier: B Risk direction: Stable Enablement vs enforcement: Mixed

Morocco's AML/CFT regime rests on Law 43-05 (as amended by Law 12-18) with UTRF (Unité de Traitement du Renseignement Financier) as FIU using goAML.

Removed from FATF grey list in Feb 2023; remains in MENAFATF enhanced follow-up with 39/40 Recommendations rated C/LC as of the 2024 follow-up cycle, but structural gaps persist on cash couriers, beneficial ownership, and virtual assets.

Key deficiencies

Recommendation 32 (cash couriers) remains only partially compliant; no effective cross-border currency/BNI declaration and interdiction system given a large informal, cash-based economy
Beneficial ownership public register decreed but electronic platform not fully populated/operational; nominee shareholder/director misuse not adequately mitigated
No operative virtual asset/VASP licensing regime despite a 2017 central-bank prohibition being widely disregarded in practice
Recommendation 38 (MLA freezing/confiscation) rated partially compliant; slow, non-time-bound response mechanisms to foreign freezing/confiscation requests
DNFBP supervision (lawyers, notaries, accountants, real estate) fragmented across multiple authorities with inconsistent risk-based application

Recent developments (18m)

MENAFATF continued Morocco in Enhanced Follow-Up; 6th Enhanced Follow-Up Report due to the 40th MENAFATF Plenary (May 2025), with FATF's Morocco follow-up page carrying a 'latest update: December 2025' revision
Bearer shares in Moroccan joint-stock companies prohibited from issuance and existing bearer shares required to convert to registered shares, aimed at closing a legal-entity opacity gap identified in Morocco's Mutual Evaluation
EU Commission's December 2025 high-risk third-country list update left Morocco off the list while Algeria (added June 2025) and other MENA neighbours were listed, widening the divergence within the region
European Court of Justice ruling (October 2024) invalidating elements of the EU-Morocco trade/fisheries protocols over Western Sahara-origin goods; a replacement protocol was provisionally applied from 3 October 2025, with implications for certificate-of-origin integrity and TBML exposure

Brief

Lead signal

Lead Signal

Morocco's 2027 draft finance law (PLF 2027) surfaces two linked commitments that bear on the country's financial-integrity posture. The budget presentation note commits to reinforcing the national anti-money-laundering and counter-terrorist-financing framework ahead of the Middle East and North Africa Financial Action Task Force's third mutual-evaluation cycle, which is scheduled to begin from November 2026. The same budget document lists adoption of a dedicated legal framework for crypto-assets, via draft law 42-25, among the government's 2027 capital-market work items. Both items are programmatic statements of intent in a budget document rather than enacted instruments: the AML/CFT reinforcement is a stated policy priority tied explicitly to the coming evaluation cycle, and the crypto-asset bill remains an unadopted draft. Separately, the Financial Action Task Force's October 2026 Plenary confirmed that Morocco was not named in the round of grey-list removals (Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo and Monaco were delisted), leaving Morocco off the list of jurisdictions under increased monitoring, where it has sat since February 2023.

Read full brief

Lead Signal

Read together, these developments describe a jurisdiction preparing its framework for external scrutiny while leaving its most consequential new instrument, the crypto-asset bill, in a pre-enactment state. The reinforcement commitment and the mutual-evaluation timeline are the more structurally significant pairing: a budget-driven push to tighten AML/CFT architecture ahead of an international peer review signals anticipated gap-closing rather than a reactive response to enforcement failure.

Other Developments

Grey-list status unchanged. The Financial Action Task Force's October 2026 Plenary outcomes confirm Morocco remains outside the list of jurisdictions under increased monitoring, a status unchanged since February 2023. The Plenary's removals this cycle were Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo and Monaco; Morocco was not part of that cohort and was not otherwise referenced in the outcomes.

Budget-note commitment to AML/CFT reinforcement. The PLF 2027 presentation note ties a reinforcement of Morocco's AML/CFT dispositif directly to the Middle East and North Africa Financial Action Task Force's third mutual-evaluation cycle, due to begin from November 2026. This is a budget-level statement of intent, not a promulgated instrument, and the specific reinforcement measures have not yet been independently confirmed against the primary finance-law text.

Crypto-asset legal framework programmed, not adopted. The same budget note lists adoption of the legal framework for crypto-assets, via draft law 42-25, as a 2027 work item. The bill remains an unadopted draft published for consultation; no parliamentary submission date has been confirmed. This is the same underlying development already carrying its own forward-looking read in the digital-assets space, but it also bears directly on the AML/CFT regime insofar as any licensing framework for crypto-asset service providers would extend obliged-entity status, and associated AML/CFT duties, to a sector presently governed only by a 2017 exchange-control position.

Cross-Monitor Connections

The crypto-asset bill's programmed adoption sits at the intersection of the AML/CFT regime and digital-asset market structure: a licensing regime for crypto-asset service providers under central-bank and market-authority dual supervision would, if enacted, bring a presently unregulated sector within the perimeter of AML/CFT obliged-entity obligations, closing a gap that mutual evaluators have previously flagged. The mutual-evaluation preparation itself is likely to generate findings relevant to a wider reading of Morocco's compliance posture, including technology-driven compliance capability, once the evaluation cycle produces its own outputs; no such findings exist yet this cycle.

Outlook

The period through the opening of the Middle East and North Africa Financial Action Task Force's third mutual-evaluation cycle, as scheduled from November 2026, is the near-term marker against which Morocco's reinforcement commitments should be read. Whether the AML/CFT measures referenced in the PLF 2027 note translate into enacted legal changes, and whether draft law 42-25 advances from consultation toward parliamentary submission, are the two concrete developments to track. Until either instrument is enacted, Morocco's standing position, grey-list absence since February 2023 and an AML/CFT framework operating under its existing legal architecture, remains unchanged in substance even as the government signals anticipatory reinforcement.

Earlier periodic briefs (4)

4 Nov 2026 · fim-2026-11-04

Lead Signal

Other Developments

Grey-list status unchanged. The Financial Action Task Force's October 2026 Plenary outcomes confirm Morocco remains outside the list of jurisdictions under increased monitoring, a status unchanged since February 2023. The Plenary's removals were Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo and Monaco; Morocco was not part of that cohort and was not otherwise referenced in the outcomes.

Cross-Monitor Connections

Outlook

3 Nov 2026 · fim-2026-11-01

Lead Signal

Morocco's 2027 budget note (PLF 2027) has surfaced two linked signals: a stated intent to reinforce anti-money-laundering and counter-terrorist-financing controls ahead of the MENAFATF third mutual-evaluation cycle scheduled to begin from November 2026, and a listed intention to adopt a legal framework for crypto-assets via draft law no. 42.25. Neither item is itself a new binding instrument. Both are policy-intent statements inside a budget document, corroborated so far only by secondary press and policy-commentary sources rather than by an independently opened primary legislative or regulatory text. The analytical significance lies in the pairing: Morocco is signalling that its anti-money-laundering posture and its approach to crypto-assets are being worked on together, in the same budget cycle, with the mutual-evaluation clock as the stated driver.

The draft crypto-asset bill remains an unenacted avant-projet. It has not passed into force, and the PLF 2027 reference to its adoption is a work-programme listing rather than a commencement date. Read against the mutual-evaluation timetable, the more probable reading is that Rabat is positioning a crypto licensing and supervision framework as part of the evidence base it will present to evaluators, rather than treating the bill as a freestanding reform.

Other Developments

Grey-list position unchanged. The Financial Action Task Force's October 2026 plenary removed four jurisdictions — Bulgaria, Cote d'Ivoire, the Democratic Republic of Congo, and Monaco — from the list of jurisdictions under increased monitoring. Morocco was not among them, because Morocco was not on that list to begin with: it has remained off the list of jurisdictions under increased monitoring since February 2023. The scrutiny that now matters for Morocco is not a grey-list review but the separate MENAFATF mutual-evaluation cycle, which tests the country's AML/CTF framework against the Financial Action Task Force standard directly rather than through list-status designation.

Virtual-asset standards acceleration. The same October 2026 plenary agreed to significantly accelerate effective implementation of the Financial Action Task Force standards on virtual assets globally. This is a structural signal rather than a Morocco-specific one, but it sets the backdrop against which Morocco's own draft crypto-asset framework will be read by evaluators: a jurisdiction moving toward licensed supervision of virtual-asset activity at the same moment the global standard-setter is pressing for faster implementation is better positioned than one that is not.

Cross-Monitor Connections

The draft crypto-asset bill sits at the intersection of two analytical lenses that this cycle treats separately but that will need to be read together going forward: the anti-money-laundering reinforcement signal and the financial-innovation signal share the same budget-document origin and the same evidentiary gap — neither has been verified against a primary legislative text, and both rest on the same class of Tier-3 budget and press commentary. Where the crypto-asset framework would introduce licensed supervision of virtual-asset service providers, any eventual enactment will carry direct consequences for how exposure to crypto-asset activity is assessed from a sanctions and illicit-finance perspective, since an unregulated, exchange-control-era prohibition environment and a licensed, dual-supervised environment carry materially different monitoring characteristics for the same underlying activity.

Outlook

The MENAFATF third mutual-evaluation cycle, scheduled to begin from November 2026, is the fixed point against which both signals should be read going forward. Whether the AML/CTF reinforcement remains at the level of budget-document intent or converts into enacted measures ahead of the evaluation, and whether draft law 42.25 is actually tabled and adopted within the 2027 window the budget note suggests, are both open questions that the evaluation cycle itself will put pressure on. As scheduled, the evaluation process should be expected to generate further primary-source material against which the press-sourced claims can be tested.

25 Oct 2026 · fim-2026-10-25

Lead Signal

A 21 October 2026 update to the OFAC Specially Designated Nationals list carries an entry listing Marrakech, Morocco as place of birth and Morocco as nationality, with the list describing a link to the IRGC-Qods Force network. The specific legal basis for the entry could not be fully isolated from the formatting of the published list, and the finding is carried at an uncertain confidence level. A single designation of this kind, confined so far to the United States list with no corresponding European Union or United Kingdom listing identified, does not on its own establish a change in jurisdiction-level risk direction for Morocco. It is best read as a data point about the architecture of sanctions designation that happens to touch a Moroccan-nationality individual, not as a finding about the Moroccan state, its institutions, or its financial sector.

The broader posture around Morocco remains one of standing architecture rather than fresh development. The country's beneficial-ownership register, administered by the industrial and commercial property office, its underlying legislative base, and its standing since the February 2023 exit from increased-monitoring status all continue unchanged, with no amending instrument identified in the period under review.

Other Developments

Divergence in sanctions coverage. The absence of a mirrored European Union or United Kingdom designation alongside the new United States listing is itself worth noting as a feature of how sanctions regimes diverge in practice. Where one jurisdiction designates and others do not yet follow, institutions operating across those jurisdictions face an uneven compliance picture for the same underlying individual, at least until or unless other regimes catch up.

Standing commentary on international standard-setting. Separately, commentary reviewed describes a hardening of tone from the Financial Action Task Force around the effectiveness of Recommendation 15, the standard covering new technologies including virtual assets. This commentary is treated as general international context rather than as a Morocco-specific finding, since it was not tied to a Morocco-specific assessment action in the material reviewed.

Commercial financing activity. The African Development Bank approved financing of approximately four hundred eighty seven million United States dollars for Morocco, reported as the third tranche of a reform-support programme running from 2024 to 2026. This is a commercial and development-finance data point rather than an integrity finding, and no sanctions, beneficial-ownership, or enforcement dimension attaches to it in the material reviewed.

Cross-Monitor Connections

The sanctions-designation data point touching a Moroccan-nationality individual has an evident payments and digital-infrastructure dimension to the extent any underlying commercial entity or financial channel is eventually tied to the designation in future reporting; readers tracking Morocco's payments and digital-money developments should watch for any cross-reference should further detail emerge. The absence of a mirrored European Union or United Kingdom listing also bears on correspondent banking and cross-border payment screening practices, where institutions serving Morocco-linked flows may encounter divergent risk ratings across regimes screening against different lists for the same individual.

Outlook

The immediate question is whether the 21 October 2026 designation remains an isolated United States-only data point or attracts corroborating detail, additional designations, or a mirrored listing from the European Union or United Kingdom. Until further information surfaces, this is being tracked as a watch item rather than as an established jurisdiction-level development. Morocco's standing beneficial-ownership and anti-money-laundering architecture is not implicated by this designation and continues on its established trajectory absent any amending instrument.

4 Oct 2026 · fim-2026-10-04

Lead Signal

Morocco this cycle registers two structurally distinct but related developments: continued drafting progress on a crypto-asset licensing regime, and the formal launch of the third-round mutual evaluation that will test whether the jurisdiction's technical-compliance standing holds up under an effectiveness lens through May 2028. Bank Al-Maghrib confirmed it has continued work since 2025 on finalizing Draft Bill 42.25, the long-awaited crypto-asset legislation intended to bring an estimated six million informal crypto users under a licensing, capital and governance regime; the bill remains unenacted. Separately, MENAFATF formally launched Morocco's third mutual-evaluation cycle via a high-level Presidency visit on 27 November 2025, a process that will extend until May 2028. The two threads intersect directly: Morocco sits off the FATF increased-monitoring list since 2023 and is rated Largely Compliant or Compliant on most Recommendations, but is Non-Compliant on Recommendation 15, which covers virtual assets. The mutual evaluation now underway will measure whether the jurisdiction converts that technical standing into demonstrated effectiveness, with the crypto-asset gap as a visible test case.

The structural read is one of capacity lagging behind practice. The current legal posture on crypto-assets traces to a 2017 exchange-control warning, not a supervisory licensing framework; the eight-year interval between that warning and todays estimated informal user base illustrates how an enforcement gap can persist even where there is no permissive policy choice behind it, only a drafting delay. Draft Bill 42.25 was published by the Ministry of Economy and Finance in November 2025, and Bank Al-Maghribs confirmation of continued work points to the legislation still moving, not stalled, but it has not reached enactment and no date earlier than 2027 is indicated.

Other Developments

An OFAC SDN designation carries a Moroccan nationality nexus. The OFAC Specially Designated Nationals list, in a snapshot dated 2 October 2026, carries an individual with place of birth in Marrakech and Moroccan nationality, designated under Executive Order 13224 as amended, in connection with an IRGC-Qods Force network. This is a designation-nexus finding rather than a Moroccan state sanctions-evasion architecture: it says something about an individuals nationality and birthplace on a US list, not about Moroccan state conduct or a Moroccan-origin sanctions programme.

Morocco continues to operate without an autonomous sanctions list. The jurisdiction implements United Nations Security Council sanctions measures only, with no independent Moroccan listing mechanism layered on top. This is a standing structural feature of the sanctions architecture rather than a new development, and it means any divergence between UN measures and the autonomous lists maintained by the EU, UK or US falls outside Moroccos own sanctions perimeter by design.

The mutual evaluation clock has formally started. MENAFATFs Presidency delegation visit on 27 November 2025 marked the official launch of the third-round evaluation, with the AMMCs 2026 priority-actions document independently confirming the end-2025 launch date. The evaluation will extend to May 2028, when a final report is due for discussion and adoption, giving the jurisdiction a multi-year window in which effectiveness findings, including on virtual assets, will be tested against the technical-compliance ratings already achieved.

Cross-Monitor Connections

The crypto-asset drafting delay connects most directly to compliance-technology and digital-asset monitors elsewhere in the fleet: a licensing regime that introduces capital, governance and white-paper requirements for crypto-asset service providers and issuers will, once enacted, create a new compliant population that did not previously exist in supervised form, with onboarding and screening implications for institutions serving that population. The OFAC designation-nexus finding is relevant to sanctions-screening and politically exposed person monitoring across any institution with Moroccan-nationality customer exposure, independent of Moroccan state action. The mutual-evaluation launch is the kind of structural, multi-year process that other jurisdiction-risk and enabler-jurisdiction trackers elsewhere in the fleet should anchor to as a dated milestone, since its May 2028 endpoint will produce an effectiveness verdict that re-rates the jurisdictions standing beyond the technical-compliance scores already on record.

Outlook

Two dated markers now frame Moroccos financial-integrity trajectory. Draft Bill 42.25 is not expected to reach enactment before 2027 at the earliest, as scheduled per the current drafting timeline, which leaves the eight-year-old informal crypto market operating under the 2017 exchange-control warning for at least one more cycle. The MENAFATF third-round mutual evaluation, running through May 2028, will be the more consequential marker: it will test whether Moroccos Largely Compliant and Compliant technical ratings translate into demonstrated effectiveness, with the standing Non-Compliant finding on Recommendation 15 as a specific pressure point that the eventual enactment of Bill 42.25 could help address, though the two processes are formally independent and the Bills passage is not a precondition the evaluation imposes.

Domain intelligence (D1–D8)

D1 Sanctions

no_changeno_changestanding position

Sanctions Architecture and Evasion

The sanctions-architecture picture for Morocco this cycle rests on a single data point: a 21 October 2026 update to the United States Office of Foreign Assets Control Specially Designated Nationals list contains an entry with place of birth Marrakech, Morocco and nationality Morocco, which the list associates with the IRGC-Qods Force network. The quoted listing text runs to place-of-birth, nationality, and gender fields alongside a secondary-sanctions-risk notation, a formatting style typical of the list's tabular presentation, and the specific legal or factual basis tying this individual to the Qods Force network could not be fully separated from that formatting in the material reviewed. The finding is accordingly carried at an uncertain confidence level rather than treated as an established fact about any Moroccan state or institutional nexus.

This matters architecturally, not incidentally. A designation naming an individual by birthplace and nationality is a feature of how the United States constructs its sanctions lists to capture ties, however indirect, between designated networks and the countries their members pass through or hold citizenship in. It is not, by itself, evidence that Morocco as a jurisdiction has any gap in its own sanctions-implementation architecture, nor that Moroccan financial institutions were used as a conduit. No enforcement action, licensing failure, or supervisory gap in Morocco has been identified in connection with this listing. The appropriate reading is that an individual with a Moroccan nexus appears on a foreign government's list, a data point for institutions conducting screening against that list, rather than a finding about Morocco's own sanctions compliance infrastructure.

A second architectural observation concerns divergence. No corresponding European Union or United Kingdom sanctions listing for the same individual has been identified in the material reviewed. Where lists diverge across major sanctioning jurisdictions, institutions with cross-border exposure face a genuinely uneven compliance landscape: a counterparty or transaction flagged under United States screening may pass cleanly under European Union or United Kingdom screening criteria for the same underlying person, at least until other regimes either designate independently or formally reference the United States action. This divergence is itself a structural feature of the current multipolar sanctions environment worth tracking, independent of whatever is eventually established about the individual concerned.

Separately, and unconnected to the designation itself, commentary reviewed this cycle describes a hardening of tone from the Financial Action Task Force concerning the effectiveness of Recommendation 15, the standard addressing new technologies and virtual assets. This is treated as general international standard-setting context rather than as a Morocco-specific development, since no Morocco-specific assessment action accompanies it in the material available. It is noted here because Recommendation 15 effectiveness is the kind of cross-cutting standard against which Morocco's own standing framework, including its 2023 exit from increased monitoring, continues to be measured by the international community, even absent any new country-specific action this cycle.

Outlook

The central open question is whether the Marrakech-linked designation remains an isolated, single-source data point or begins to attract corroboration: a parallel European Union or United Kingdom listing, additional designated individuals or entities with a clearer Moroccan nexus, or further detail from the United States Treasury clarifying the legal basis presently obscured by list formatting. Absent such corroboration, this is being tracked as a watch item rather than escalated to a jurisdiction-level finding. Institutions with Moroccan exposure conducting sanctions screening should note the current cross-regime divergence as a practical screening consideration rather than as evidence of any weakness in Morocco's own framework, and should expect this item to be revisited as further designations or official statements surface.

Judgment: No Morocco-specific Russian sanctions-evasion, dark-fleet, or Houthi/Yemen-channel material surfaced this cycle. Uncertain

D2 Beneficial Ownership

no_changeno_changestanding position

Beneficial Ownership and Corporate Transparency

Morocco sits outside the European Union entirely as a matter of jurisdiction, and its beneficial-ownership and corporate-transparency exposure this cycle is best read first through its own domestic reform trajectory and MENAFATF technical-compliance status, with the EU AML Package entering the picture only as external structural backdrop against which Moroccan reform can be benchmarked. The directly relevant development for Morocco itself is a genuine, if incomplete, structural improvement: Morocco has decreed a public register of ultimate beneficial ownership and prohibited the issuance of new bearer shares, with mandatory conversion of existing bearer shares to registered form. This addresses part of the Recommendation 24 and Recommendation 25 deficiencies identified in the 2019 Mutual Evaluation of Morocco, and represents a clear legislative-level closure of a historically significant corporate-opacity vector.

The gap, and the primary D2 finding this cycle, sits between that legislative reform and its operational implementation. MENAFATF Enhanced Follow-Up findings, most recently reflected in the fifth Enhanced Follow-Up Report of May 2024 and reaffirmed through the sixth Enhanced Follow-Up Report processed at the May 2025 Plenary, confirm that the electronic beneficial-ownership platform remains incompletely populated and not fully operational, and that no demonstrated safeguards against nominee shareholder or nominee director misuse have yet been established. Under FIM Tier-1/Tier-2 evidentiary doctrine, the persistence of this implementation gap alongside a genuine legal reform is itself the signal: the corporate-opacity channel the decree was designed to close remains partly open in practice, even where it has been closed on paper. Recommendation 38, governing the timeliness of mutual-legal-assistance responses to foreign freezing and confiscation requests, remains separately rated partially compliant, reflecting slow, non-time-bound response mechanisms that compound the beneficial-ownership gap by limiting the practical recoverability of assets even where ownership can eventually be traced.

Adjacent to this domestic reform trajectory, and illustrating the practical consequence of the platform gap, Pandora Papers reporting corroborated by the Moroccan outlet Le Desk documented Moroccan politically exposed persons and professional intermediaries using British Virgin Islands, Seychelles and Panama entities to hold foreign real estate and route dividends, including a British Virgin Islands company linked to a member of the Moroccan royal family holding London property, and a Panamanian foundation used by an accounting-firm partner to route dividends into a Spanish account. This is documented private wealth structuring rather than state-directed financial architecture, though its proximity to state power is noted as a cross-reference point rather than a finding in itself.

Globally, the EU AML Package sets the structural direction for beneficial-ownership supervision even though Morocco sits outside its perimeter. The Package comprises three distinct instruments: the directly applicable AML Regulation, Regulation (EU) 2024/1624, known as the AMLR; the sixth AML Directive, or 6AMLD, requiring transposition by each EU Member State; and the AMLA Regulation, Regulation (EU) 2024/1620, establishing the Anti-Money Laundering Authority, which is shifting supervision from purely national authorities toward a hybrid EU-level direct and indirect supervisory perimeter for high-risk cross-border obliged entities. Morocco, as a non-EEA third country, is not subject to AMLR direct applicability, 6AMLD transposition, or the AMLA supervisory perimeter; its principal EU AML-Package touchpoint remains the pre-AMLR Article 9 high-risk third-country mechanism, under which it is currently unlisted while Algeria has been listed since June 2025. This is standing structural context for reading Moroccan beneficial-ownership developments, not a Moroccan-specific finding, and it clarifies why the AMLA transition, however consequential for EU-domiciled obliged entities, has no direct supervisory bearing on the Moroccan reform trajectory described above.

Outlook

The next MENAFATF Enhanced Follow-Up Report and Plenary review of Morocco, expected around November 2026, will test whether the beneficial-ownership platform population gap and the Recommendation 38 mutual-legal-assistance timeliness deficiency move beyond partially compliant ratings. Absent sector-specific enforcement or supervisory-penalty data beyond aggregate technical-compliance ratings, the pace and depth of nominee-misuse safeguards remain difficult to verify independently, a coverage gap flagged for future review. The EU Article 9 review cycle expected in the fourth quarter of 2026 will separately determine whether the non-listing of Morocco persists, though this operates on a track distinct from the domestic beneficial-ownership reform trajectory described here.

Judgment: No Morocco-specific beneficial-ownership registry development surfaced this cycle. Uncertain

D3 Enabler Jurisdictions

no_changeno_changestanding position

Enabler Jurisdictions and Professional Facilitators

Morocco baseline coverage this cycle establishes a persistent professional-enablement architecture running in parallel with unresolved trade-integrity friction arising from the Western Sahara dimension of EU-Morocco relations. The clearest documented instance of professional-enablement architecture is Pandora Papers reporting, corroborated by the Moroccan outlet Le Desk, showing Moroccan politically exposed persons and professional intermediaries using British Virgin Islands, Seychelles and Panama entities to hold foreign real estate and route dividends into personal accounts. Of particular note is the involvement of an accounting-firm partner using a Panamanian foundation to route dividends into a Spanish account, a documented case of a professional-services provider, rather than the wealth-holder alone, structuring the offshore layer. This is the defining D3 characteristic: enablement architecture depends on professional intermediaries as much as on permissive incorporation regimes, and the accountant example here illustrates the facilitator role directly. This professional-enablement finding is read at Tier-2 evidentiary standard pending Tier-1 enforcement corroboration, consistent with FIM doctrine that documented investigative architecture can precede formal enforcement acknowledgement without diminishing its analytical significance.

That professional-enablement architecture is structurally supported by fragmented Moroccan supervision of the designated non-financial businesses and professions sector. Supervision of lawyers, notaries, accountants and real-estate agents remains fragmented across multiple Moroccan authorities with inconsistent risk-based application, a deficiency identified in the 2019 Mutual Evaluation of Morocco that has not been resolved through the Enhanced Follow-Up cycle. Under FIM enabler-jurisdiction doctrine, this fragmentation is read as a capacity-and-choice question rather than a purely episodic supervisory failure: it is the standing condition that made the professional-enablement architecture documented in the Pandora Papers case possible, and it remains unresolved independent of any individual enforcement action. No sector-specific DNFBP enforcement or supervisory-penalty data was available this cycle to substantiate the fragmentation finding at higher than assessed confidence, a sourcing gap noted for future review.

A separate but structurally adjacent D3 development concerns trade-integrity architecture rather than professional facilitation directly. The October 2024 European Court of Justice ruling invalidated elements of the EU-Morocco trade and fisheries protocols concerning goods originating in Western Sahara, and a replacement protocol has been provisionally applied from 3 October 2025 pending full ratification. This creates certificate-of-origin integrity questions relevant to trade-based money-laundering exposure in phosphate and agricultural export chains, a structural trade-integrity development rather than a sanctions or AML enforcement action in itself, but one that intersects with the broader D3 concern of Morocco functioning as a jurisdiction whose trade architecture carries documentation ambiguity exploitable for layering. This sits alongside the already-documented use of commercial trading companies, including food exporters, to layer proceeds from the Western Sahara drug-transit architecture covered under D4, reinforcing trade documentation as a recurring vulnerability across both licit-adjacent and clearly illicit flows.

Sourcing thinness compounds the picture. Available English-language data on Moroccan money-laundering prosecutions and convictions is sparse; historical MENAFATF Mutual Evaluation data records only two money-laundering convictions out of eight judgments between 2008 and 2016, with no comparable recent statistics located this cycle. This gap limits external verification of actual Moroccan enforcement intensity independent of the technical-compliance re-ratings that dominate available reporting, and is flagged for future review against Moroccan Ministry of Justice and financial-intelligence-unit sources not reviewed this cycle.

Outlook

Implementation of the replacement EU-Morocco trade protocol remains ongoing, with risk direction on certificate-of-origin integrity assessed as uncertain pending full ratification and observed enforcement practice; this is a distinct forward item from the DNFBP fragmentation question, which has no confirmed near-term resolution date and is expected to persist absent a dedicated supervisory-consolidation reform. Future cycles should prioritise Arabic and French-language Moroccan financial-intelligence-unit and Ministry of Justice sourcing to test whether enforcement intensity is understated by the technical-compliance-dominated evidence base currently available.

Judgment: No Morocco-specific enabler-jurisdiction development surfaced this cycle. Uncertain

D4 Conflict Finance

no_changeno_changestanding position

Conflict Finance and Extractive-Industry Integrity

Morocco baseline coverage identifies a single documented D4-relevant architecture this cycle: the use of Western Sahara ports, principally Dakhla and Laayoune, as transit nodes through which hashish produced in the Rif Mountains is routed south into Sahel drug markets, alongside cocaine shipments increasingly re-containerised for onward transit to Europe. Proceeds from this transit architecture are documented as layered through commercial trading companies, including food exporters, blending organised-crime proceeds with licit trade flows in a manner that complicates trade-based money-laundering detection.

This finding intersects with Sahel regional drug markets already covered under standing FIM D4 conflict-finance monitoring, and the transit corridor is pattern-consistent with the source-channel-deployment structure FIM applies under its conflict-finance filter: source in Rif cannabis and re-exported cocaine, channel through Western Sahara ports and trading-company layering, and deployment into Sahel markets. However, the direct financial link between this drug-transit architecture and armed-group or conflict-actor revenue is not established in current reporting, and this cycle assesses that linkage at Possible confidence pending corroboration from SCEM-sourced reporting on Sahel conflict-finance dynamics. This is a deliberately thin finding: FIM honesty-over-coverage doctrine requires flagging the gap between a pattern-consistent architecture and a confirmed conflict-finance nexus, rather than asserting the latter on the strength of the former alone.

Outlook

The D4 picture for Morocco depends materially on SCEM cross-reference to establish or rule out a direct armed-group revenue link to the Western Sahara transit corridor; absent that corroboration, this domain remains at limited signal for Morocco this cycle, reflecting a single documented scheme rather than a broader conflict-finance architecture. Future cycles should prioritise this cross-monitor reconciliation before upgrading confidence on the conflict-finance dimension of the Western Sahara transit architecture.

Judgment: No Morocco-specific conflict-finance development surfaced this cycle. Uncertain

D5 Crypto / Digital Assets / Financial Innovation

watchmaterial_change

Crypto / Digital Assets / Financial Innovation

Morocco's 2027 draft finance law lists adoption of the legal framework for crypto-assets, via draft law 42-25, among the government's 2027 capital-market work items. This is a budget-level statement of programmatic intent, not an enacted instrument: the bill remains a draft published for consultation, and no parliamentary submission date has been confirmed. The framing in the budget note situates the measure within capital-market policy rather than as a standalone AML/CFT initiative, but the financial-integrity implication is direct. Morocco presently has no dedicated legal regime governing crypto-asset activity; the operative position dates to a 2017 joint communique treating virtual-currency transactions as a breach of the country's exchange-control regulation. A licensing framework for crypto-asset service providers, were it to be enacted substantially as programmed, would extend formal obliged-entity status and associated anti-money-laundering and counter-terrorist-financing obligations to a sector that currently sits outside any dedicated compliance perimeter beyond the general exchange-control prohibition.

The financial-integrity reading of this development is therefore one of a potential gap-closing measure rather than a market-liberalisation story in isolation. Crypto-asset activity conducted outside a licensed, supervised perimeter is structurally more exposed to being used as a layering or value-transfer channel precisely because no obliged-entity reporting or customer-due-diligence regime currently attaches to it in Morocco. Adoption of draft law 42-25, when and if it proceeds beyond consultation, would be the kind of structural shift this analysis treats as more significant than any single enforcement action: it would reconstitute the perimeter of who is subject to AML/CFT obligations in the digital-asset space, rather than simply adding an enforcement data point against existing rules.

At the same time, the absence of enforcement activity connected to crypto-asset use in Morocco this cycle is itself worth registering. No development surfaced indicating Moroccan authorities have pursued cases under the 2017 exchange-control position, despite that position remaining the only binding rule in force. Whether that reflects limited observable activity, under-detection, or prosecutorial discretion cannot be determined from the material gathered this cycle, but the pairing of an unenforced existing prohibition with a programmed future licensing framework is a structurally relevant data point for assessing how exposed the jurisdiction's digital-asset sector currently is to illicit-finance risk in the gap between the old prohibition and any future regime.

Outlook

The trajectory to watch is whether draft law 42-25 advances from its current consultation status toward parliamentary submission within the 2027 window the budget note programs for it. Until enactment, Morocco's digital-asset sector continues to operate in the space between an unenforced 2017 exchange-control prohibition and an unadopted licensing framework, a gap that mutual evaluators are likely to examine as Morocco approaches the Middle East and North Africa Financial Action Task Force's third mutual-evaluation cycle, scheduled to begin from November 2026. Any confirmed parliamentary timetable, or any enforcement action under the existing exchange-control position, would be the next concrete markers of movement in either direction.

Judgment: PLF 2027's budget note programs adoption of crypto-asset bill 42-25 as a 2027 work item; the bill remains an avant-projet, not enacted. Probable

D6 Compliance Technology & Active Defence

no_changeno_changestanding position

Compliance Technology and Active Defence

No material RegTech, artificial-intelligence-monitoring, or perpetual-know-your-customer guidance development was identified for Morocco this cycle. The single D6-relevant finding is an absence rather than an event: given that no operative virtual-asset-service-provider licensing regime exists in Morocco and that the jurisdiction shows large-scale informal crypto-to-fiat activity, there is no evidence of any AML/CFT technology layer, know-your-customer tooling, transaction-monitoring analytics, or blockchain-forensic capability, applied to that activity. This is an interpretive inference drawn from the combination of the D5 licensing gap and the documented adoption scale, rather than a directly sourced negative finding, and it is flagged accordingly at assessed rather than higher confidence.

Under FIM enablement-as-signal doctrine, this absence is itself analytically significant: the scale of unsupervised peer-to-peer crypto activity documented under D5 means that the compliance-technology gap here is not a minor supervisory footnote but a structural condition running in parallel with, and reinforcing, the D5 virtual-asset supervision gap. No compliance-technology vendor engagement, supervisory-technology procurement, or perpetual-know-your-customer pilot was identified in Moroccan public reporting this cycle, and this domain remains at limited signal for Morocco pending future research into Moroccan financial-sector technology adoption more broadly.

Outlook

This domain is marked watch rather than active for Morocco this cycle, reflecting the absence of any confirmed development rather than a substantive finding. Future cycles should test whether enactment of the pending Moroccan crypto-asset and VASP licensing law, tracked under D5, brings with it any accompanying compliance-technology mandate or supervisory-technology build-out, which would be the first material D6 development for this jurisdiction.

Judgment: No Morocco-specific RegTech/active-defence development surfaced this cycle. Uncertain

D7 AML/CTF Regime

watchmaterial_change

AML/CTF Regime

Morocco's 2027 draft finance law commits, at the level of budget-presentation policy, to reinforcing the country's anti-money-laundering and counter-terrorist-financing framework. The note ties this reinforcement explicitly to the Middle East and North Africa Financial Action Task Force's third mutual-evaluation cycle, which is scheduled to begin from November 2026. This is a stated budget priority rather than a promulgated legal instrument, and the specific measures intended to satisfy the reinforcement commitment have not been independently confirmed against the primary finance-law text this cycle. The architectural reading is nonetheless significant: a government signalling anticipatory reinforcement ahead of a peer-review cycle, rather than reinforcement in response to a prior adverse finding, suggests the measure is being framed as preparation rather than remediation.

This development sits alongside confirmation from the Financial Action Task Force's October 2026 Plenary that Morocco was not part of the round of grey-list removals, which affected Bulgaria, Cote d'Ivoire, the Democratic Republic of the Congo and Monaco. Morocco has remained off the list of jurisdictions under increased monitoring since February 2023, and nothing in the Plenary outcomes this cycle changes that position. The two facts read together describe a jurisdiction with a stable international standing navigating toward a mutual-evaluation cycle from a position of no active grey-list designation, using the evaluation itself, rather than any current listing pressure, as the stated driver for framework reinforcement.

The three-pillar balance this analysis applies deserves explicit note here: the budget note's language is framed in anti-money-laundering and counter-terrorist-financing terms generally, without the material distinguishing which specific pillar, countering the financing of proliferation included, the reinforcement measures are intended to address. Absent further detail from the primary text, it would overstate the evidence to characterise the reinforcement as weighted toward any one of the three pillars. The coming mutual-evaluation cycle is the vehicle through which that balance, or imbalance, is likely to become visible, since Financial Action Task Force-style evaluations assess technical compliance and effectiveness across all three domains.

Outlook

The Middle East and North Africa Financial Action Task Force's third mutual-evaluation cycle, as scheduled from November 2026, is the structural marker against which Morocco's AML/CFT trajectory should be read over the coming period. What remains unconfirmed is the substantive content of the reinforcement measures referenced in the PLF 2027 note: whether they amount to legislative amendment, supervisory-capacity investment, or administrative measures within existing law is not yet established from the material available this cycle. Morocco's grey-list absence, maintained since February 2023 and unaffected by the October 2026 Plenary's removals, provides the baseline against which any evaluation findings will be measured once the new cycle produces outputs.

Judgment: PLF 2027 budget note commits to reinforcing Morocco's AML/CFT framework ahead of MENAFATF's third mutual-evaluation cycle beginning November 2026; this is a stated policy intent in a budget document, not a new instrument. Probable

D8 Commercial Activity

no_changeno_change

Judgment: No Morocco-specific financial-integrity commercial event surfaced this cycle. Uncertain

Regulatory horizon

Proposed2026-Q4 · ±half_year

MENAFATF (GAFIMOAN) 3rd mutual-evaluation cycle

A new MENAFATF mutual-evaluation cycle for Morocco is slated to begin from November 2026; the government cites it as the driver for AML/CFT reinforcement measures in the PLF 2027.

source not collected

Proposed2026-Q4 · ±half_year

MENAFATF 3rd mutual-evaluation cycle

A new MENAFATF mutual-evaluation cycle for Morocco is slated to begin from November 2026; government cites it as driver for AML/CFT reinforcement in PLF 2027.

source not collected

In Force2026-Q4 · ±quarter

Next EU Article 9 high-risk third-country list review cycle

The European Commission updates its high-risk third-country list roughly twice yearly following FATF Plenaries; the next cycle (post June 2026 FATF Plenary) will determine whether Morocco's continued non-listing persists given ongoing MENAFATF Enhanced Follow-Up findings.

Source

Consultation2027 · ±year

Crypto-asset bill no. 42-25

PLF 2027 programs legislative adoption of a dedicated crypto-asset legal framework (BAM/AMMC dual supervision) as a named 2027 capital-markets work item; no enactment date or parliamentary calendar is confirmed yet.

Source

Consultation2027 · ±year

Crypto-asset bill no. 42-25

PLF 2027 programs legislative adoption of a dedicated crypto-asset legal framework (BAM/AMMC dual supervision) as a named 2027 capital-markets work item; no enactment date confirmed.

Ministere de l'Economie et des Finances / SGG Source

5 dated · 3 pending date · baseline financial-integrity-2026-07-05

Role action cards

MLRO

Morocco signals AML/CFT reinforcement intent ahead of a new mutual-evaluation cycle, while remaining off the FATF grey list.

A budget-level commitment to reinforce the national AML/CFT framework is tied explicitly to the Middle East and North Africa Financial Action Task Force's third mutual-evaluation cycle, due from November 2026. No new reporting obligation or SAR trigger has yet been enacted; the measures described remain at the stage of budget policy intent.

2 evidence refs

Compliance

A programmed crypto-asset licensing framework would extend obliged-entity status to a presently unregulated sector.

Draft law 42-25, if enacted as programmed in the PLF 2027, would bring crypto-asset service providers within a licensed, supervised perimeter for the first time, carrying compliance-framework implications for any institution with exposure to Moroccan digital-asset counterparties. The bill remains unenacted.

1 evidence refs

Board

Morocco maintains a stable international standing while signalling anticipatory AML/CFT reinforcement ahead of external peer review.

The jurisdiction remains off the Financial Action Task Force's list of jurisdictions under increased monitoring, a position held since February 2023, while preparing budget-level reinforcement commitments ahead of a mutual-evaluation cycle from November 2026. This is a preparatory signal, not evidence of a current adverse finding.

2 evidence refs

CTO

A programmed crypto-asset licensing bill would introduce the first dedicated supervisory perimeter for Moroccan digital-asset infrastructure.

Draft law 42-25 is reported to propose dual central-bank and market-authority supervision for crypto-asset service providers; if enacted, this would require technical compliance infrastructure that does not currently exist under the operative 2017 exchange-control position. The bill remains at consultation stage.

1 evidence refs

Risk

An unenforced exchange-control prohibition and an unadopted licensing bill leave a structural gap in Morocco's digital-asset oversight.

The coexistence of a dormant 2017 exchange-control position and a non-enacted 2027-programmed licensing bill is a structural exposure concentration worth tracking, independent of any single enforcement event, pending the outcome of the new mutual-evaluation cycle.

2 evidence refs

Audit

Reinforcement commitments referenced in the PLF 2027 note have not yet been confirmed against primary legislative text.

The specific AML/CFT reinforcement measures and the crypto-asset bill's pinpoint provisions rest on budget-note and secondary-press description rather than independently opened primary text this cycle, a documented evidentiary gap relevant to audit scope going forward.

2 evidence refs

Scenario sketches

AMLA transition reshaping cross-border supervision architecture

Illustrative scenario for analytical orientation only: as the European Union's Anti-Money Laundering Authority assumes direct and indirect supervision of designated cross-border obliged entities under the AMLA Regulation, alongside the directly-applicable AML Regulation and per-state transposition of the sixth AML Directive, the European supervisory landscape could shift from a purely national patchwork toward a hybrid EU-level perimeter. For jurisdictions outside that perimeter, such as Morocco, this illustrative shift could alter correspondent-banking and cross-border due-diligence expectations placed on counterparties by EU-supervised institutions, independent of any domestic Moroccan legal change. This is an illustration of a possible structural mechanism, not an observed fact or a prediction about Morocco specifically.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker	Status	Note
T1 · Russian Sanctions-Evasion Architecture	no_change	No Morocco-specific Russian sanctions-evasion material surfaced this cycle.
T2 · EU AML Package / AMLA	no_change	Morocco is not an EEA member and is not directly bound by AMLR/6AMLD/AMLA.
T3 · FATF Grey List	no_change	FATF October 2026 Plenary removed Bulgaria, Cote d'Ivoire, DRC and Monaco from the grey list; Morocco was not named and remains off the list (delisted Feb 2023). Morocco's next scrutiny is MENAFATF's 3rd mutual-evaluation cycle from November 2026.
T4 · Beneficial-Ownership Register Status	no_change	No Morocco-specific beneficial-ownership registry development surfaced this cycle.
T5 · Crypto & Digital-Asset Integrity	watch	PLF 2027 budget note programs adoption of crypto-asset bill 42-25 (BAM/AMMC dual supervision, PSAC licensing, bank monopoly on stablecoin issuance) as a 2027 work item; MENAFATF's May 2024 5th Enhanced FUR rating of R.15 as Non-Compliant is unchanged.
T6 · Sanctions Regime Divergence	no_change	No Morocco-specific sanctions-regime divergence signal surfaced this cycle.

Registers

Enforcement actions

15 May 2025
1 Dec 2025
15 May 2025
Morocco submitted (and MENAFATF processed) its 6th Enhanced Follow-Up Report at the 40th MENAFATF Plenary (May 2025), continuing the enhanced-monitoring cycle established since the 2019 Mutual Evaluation, with re-rating requests tracking progress on Recommendations 15, 24, 25, 31, 32 and 38. 15 May 2025
FATF's published Morocco follow-up page was updated (page metadata dated December 2025), reaffirming continued enhanced-monitoring status and confirming that Recommendation 32 (cash couriers) and other outstanding items remain unresolved notwithstanding Morocco's 2023 removal from the grey list. 1 Dec 2025
Implementation continued of the decree establishing a 'Public Register of UBOs of Companies established in Morocco and Legal Arrangements' and the statutory prohibition on new bearer-share issuance (with mandatory conversion of existing bearer shares to registered form), addressing FATF Recommendation 24/25 deficiencies, though MENAFATF's 5th Enhanced FUR found the electronic BO platform still not fully operational. 15 May 2025

Sanctions changes

4 Dec 2025
24 Feb 2026
2 Oct 2026
The European Commission's December 2025 update to the EU high-risk third-country list added Bolivia and the British Virgin Islands and delisted several African jurisdictions, but did not add Morocco, even as regional neighbour Algeria had been added to the same list in June 2025 — a persistent divergence point within North Africa's AML risk classification. 4 Dec 2025
Following the UK's January 2024 shift to directly mirror the FATF 'Jurisdictions under Increased Monitoring' and 'Call for Action' lists in Schedule 3ZA of the MLRs, subsequent HM Treasury advisory notices (June 2025, October 2025, February 2026) have continued to exclude Morocco from the UK High-Risk Third Countries list, consistent with its non-listing by FATF. 24 Feb 2026

Regulatory horizon (register)

Next EU Article 9 high-risk third-country list review cycle
Draft Law 42.25 on crypto-assets
Crypto-asset bill no. 42-25
MENAFATF 3rd mutual-evaluation cycle
Crypto-asset bill no. 42-25
MENAFATF (GAFIMOAN) 3rd mutual-evaluation cycle
Enactment of Morocco's crypto-asset / VASP licensing law
Next MENAFATF Enhanced Follow-Up Report / Plenary review of Morocco
Implementation of revised EU-Morocco trade protocol on Western Sahara-origin goods
Next EU Article 9 high-risk third-country list review cycle

Active schemes

[HIGH] Hashish/cocaine transit via Western Sahara ports
PEP offshore structuring via BVI/Seychelles/Panama entities
Informal crypto adoption despite unresolved regulatory ban

Sources

Coverage gaps

fim-int-2026-07-07-G001: Arabic/French-language UTRF annual …

fim-int-2026-07-07-G001: Arabic/French-language UTRF annual reports and Moroccan Ministry of Justice ML conviction statistics were not reviewed this cycle, limiting verification of actual enforcement intensity independent of technical-compliance re-ratings. [resolved]

fim-int-2026-07-07-G002: No direct evidence establishes a fi…

fim-int-2026-07-07-G002: No direct evidence establishes a financial link between the Western Sahara drug-transit architecture and armed-group or conflict-actor revenue, leaving the D4 conflict-finance classification at Possible confidence pending SCEM-sourced corroboration. [resolved]

fim-int-2026-07-07-G003: No recent (post-2022) verifiable da…

fim-int-2026-07-07-G003: No recent (post-2022) verifiable date or draft text for Morocco's pending crypto-asset/VASP licensing law was located, limiting horizon-item date confidence to a bare year estimate. [resolved]

fim-int-2026-07-07-G004: No sector-specific DNFBP enforcemen…

fim-int-2026-07-07-G004: No sector-specific DNFBP enforcement or supervisory-penalty data (as opposed to aggregate MER/FUR technical-compliance ratings) was available to substantiate the fragmentation finding at higher than Assessed confidence. [resolved]

fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No MA-specific beneficial-ownership register development identified this cycle; not researched in depth this pass. [resolved]

fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No MA-specific conflict-finance (D4) development identified this cycle; this remains a thin-coverage area. [resolved]

fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D6'}): No MA-specific compliance-technology (D6) development identified this cycle; this remains a thin-coverage area. [resolved]

fim-int-2026-10-04-G004 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-04-G004 ({'scheme': 'financial_integrity', 'value': 'D5'}): Draft Bill 42.25's primary SGG text was not independently opened this pass; all crypto-bill findings rest on T3/T4 secondary commentary corroborating a single T3 press report. [resolved]

fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 enabler-jurisdiction material specific to Morocco was not located this cycle. [resolved]

fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D6'}): D6 compliance-technology material was not substantively researched for Morocco this cycle. [resolved]

fim-int-2026-10-25-G003: Tier D watch jurisdictions (KH, LA,…

fim-int-2026-10-25-G003: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively searched in this JID-bound Morocco dispatch. [resolved]

fim-int-2026-10-25-G004 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-25-G004 ({'scheme': 'financial_integrity', 'value': 'D1'}): Full OFAC SDN record context/legal basis for the Marrakech-linked entry could not be isolated from the PDF's tabular formatting. [resolved]

fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): Tier D watch jurisdictions (KH, LA, MX, CO) and the Houthi/Yemen standing collection were not independently re-checked this cycle. [open]

fim-int-2026-11-01-G004: D1 (Sanctions), D2 (Beneficial Owne…

fim-int-2026-11-01-G004: D1 (Sanctions), D2 (Beneficial Ownership), D3 (Enabler Jurisdictions), D4 (Conflict Finance), D6 (Compliance Technology) had thin coverage this cycle; Tier D watch (KH, LA, MX, CO) not independently re-checked. [open]

fim-int-2026-11-01-G001: The specific AML/CFT-reinforcement …

fim-int-2026-11-01-G001: The specific AML/CFT-reinforcement passage within the PLF 2027 primary text was not independently opened and quoted this cycle. [open]

fim-int-2026-11-01-G002: Draft law 42-25's primary SGG avant…

fim-int-2026-11-01-G002: Draft law 42-25's primary SGG avant-projet text was not independently opened to confirm pinpoint provisions this cycle. [open]

FIM-GAP-001 (D1): Morocco's cross-border currency/bearer-neg…

FIM-GAP-001 (D1): Morocco's cross-border currency/bearer-negotiable-instrument declaration system (FATF Recommendation 32) remains only partially compliant: customs authorities lack authority to request further information on discovery of false declarations, and no proportionate/dissuasive sanctions regime attaches to false declarations, in a heavily cash-based economy.

FIM-GAP-002 (D2): Despite a decree establishing a public UBO…

FIM-GAP-002 (D2): Despite a decree establishing a public UBO register for companies and legal arrangements, the electronic platform intended to host beneficial ownership declarations remains incompletely populated and not fully operational, and Morocco has not demonstrated safeguards against nominee shareholder/director misuse.

FIM-GAP-003 (D5): No operative VASP licensing/supervisory re…

FIM-GAP-003 (D5): No operative VASP licensing/supervisory regime exists in Morocco notwithstanding a 2017 central-bank ban; the ban is widely disregarded, evidenced by Morocco's ranking among the region's fastest-growing crypto-adoption markets with activity occurring entirely outside AML/CFT-supervised channels.

FIM-GAP-004 (D3): Publicly available, English-language repor…

FIM-GAP-004 (D3): Publicly available, English-language reporting on individual Moroccan money-laundering prosecutions, convictions, or supervisory financial penalties within the 18-month baseline window is sparse; MENAFATF's own historical MER data shows extremely low ML conviction rates (2 convictions out of 8 judgments over 2008-2016), and no comparable recent statistics were located in this research cycle.

Evidence

Confidence-tiered claims

Bank Al-Maghrib confirmed continued drafting progress since 2025; bill remains unenacted [Source 1]

Probable · 1 source

Formally launched via high-level Presidency visit on 27 Nov 2025; runs through May 2028 [Source 1]

Probable · 1 source

Designated under Executive Order 13224 as amended, linked to IRGC-Qods Force network [Source 1]

Probable · 1 source

Off the FATF increased-monitoring (grey) list since 2023 [Source 1]

Probable · 1 source

No autonomous sanctions list; implements UN Security Council sanctions only [Source 1]

Probable · 1 source

OFAC's 21 October 2026 SDN List update includes an entry with place of birth Marrakech, Morocco and nationality Morocco, described in the list as linked to the IRGC-Qods Force network; the specific legal basis for this entry could not be fully isolated from list formatting. [Source 1]

Uncertain · 1 source

Morocco's AML/CFT architecture, including the OMPIC-administered public beneficial ownership register (25% threshold, Law 12-18 amending Law 43-05, Decree 2-21-708) and its February 2023 FATF grey-list delisting, remains unchanged this cycle. [Source 1]

Probable · 1 source

AML/CFT reinforcement listed as budget priority ahead of MENAFATF 3rd mutual-evaluation cycle starting Nov 2026 [Source 1]

Probable · 1 source

PLF 2027 lists adoption of crypto-asset bill 42-25 among 2027 capital-market work items; bill remains avant-projet, not enacted [Source 1]

Probable · 1 source

Morocco not among the four jurisdictions removed from grey list (Bulgaria, Cote d'Ivoire, DRC, Monaco); Morocco remains off the list since Feb 2023 [Source 1]

Probable · 1 source

PLF 2027 budget note commits to reinforcing Morocco's AML/CFT dispositif ahead of MENAFATF's 3rd mutual-evaluation cycle, beginning November 2026. [Source 1]

Probable · 1 source

PLF 2027 budget note lists adoption of the legal framework for crypto-assets, via draft law 42-25, among 2027 capital-market work items; bill not enacted. [Source 1]

Probable · 1 source

FATF October 2026 Plenary (28-30 Oct) removed Bulgaria, Cote d'Ivoire, DRC and Monaco from the grey list; Morocco was not named and remains off the list since February 2023. [Source 1]

Probable · 1 source