--- title: "Tunisia (TN) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/tunisia/ source_html: /jurisdictions/tunisia/index.html description: "Financial integrity intelligence for Tunisia (TN): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 40cede531c1eeda6853685b739344c87074532f447a7e064a3dd1275b058a3aa generator: "fe-fleet/md-twin@1.0" --- # Tunisia (TN) — Financial-Integrity Intelligence · Sentinel 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 # Tunisia TN Domains covered 8 of 8 Sources 153 Role actions 8 Horizon <90d 1 Jurisdiction profile FATF status: Clean Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed Tunisia's AML/CFT regime rests on Organic Law No.26 (2015) and CTAF (Commission Tunisienne des Analyses Financieres) as FIU. More Tunisia exited FATF's ICRG monitoring in 2019 after a 2016 MENAFATF Mutual Evaluation and multiple enhanced follow-up re-ratings. A 5th-round MER is now pending. Beneficial-ownership rules for trusts exist (CTAF Decision No.3/2017) but lack punitive teeth, and asset-recovery capacity remains structurally weak. Key deficiencies - Beneficial-ownership declaration duties for trustees/fiduciaries carry no punitive sanction for non-compliance - Asset recovery from Ben Ali-era looted state funds remains almost entirely unrealised despite a decade of parallel EU/Swiss/French freezes and a 2022 domestic reconciliation commission - Independent anti-corruption institutional capacity has been dismantled/instrumentalised since the 2021 emergency-powers seizure, undermining credible AML enforcement - No dedicated virtual-asset/VASP licensing or supervisory framework has been identified - Persistent informal/TBML-adjacent cross-border trade with Libya and Algeria, particularly in subsidised fuel Recent developments (18m) - Tunisian court convicted former PM Youssef Chahed and businessman Marouan Mabrouk (Ben Ali's son-in-law) on money-laundering and embezzlement charges (2026) - Former National Anti-Corruption Authority head Chawki Al-Tabib jailed on money-laundering/embezzlement charges seen by rights groups as retaliatory (April 2026) - OFAC updated Tunisian-national counter-terrorism SDGT designations with secondary-sanctions risk tags (Nov 2025, May 2026) - EU presented a Pact for the Mediterranean Action Plan covering Tunisia (April 2026) with governance/financial dimensions - Tunisia's 5th-round FATF/MENAFATF Mutual Evaluation moved onto the assessment calendar with possible plenary discussion around November 2026 Brief ## Lead signal #### Lead Signal Tunisia moved through a dense cluster of anti-money-laundering instruments in the window around January 2026, pointing to a structural strengthening of the compliance perimeter rather than an isolated correction. The Conseil du Marche Financier (CMF) published a new risk-based AML/CFT/PF implementing regulation in JORT n9 of 23 January 2026, replacing the formal-compliance model that previously governed market intermediaries and, for the first time, extending CMF supervisory perimeter to crowdfunding platforms. The same week, a tripartite ministerial order (arrete n13/2026, JORT 29-30 January 2026) replaced 2018-era casino rules with a risk-based regime requiring mandatory risk audits, a 10,000 TND enhanced-vigilance threshold, escalation of politically exposed person relationships to general management, and mandatory transaction blocking combined with suspicious-transaction reporting to the Commission Tunisienne des Analyses Financieres (CTAF) where client identity cannot be authenticated. Taken together, these instruments close gaps in cash-intensive and previously under-regulated sectors flagged in Tunisia's 2016 MENAFATF mutual evaluation, and the architecture reading is that this is a coordinated sectoral extension of AML perimeter rather than a single-agency initiative. Read full brief #### Lead Signal Tunisia moved through a dense cluster of anti-money-laundering instruments in the window around January 2026, pointing to a structural strengthening of the compliance perimeter rather than an isolated correction. The Conseil du Marche Financier (CMF) published a new risk-based AML/CFT/PF implementing regulation in JORT n9 of 23 January 2026, replacing the formal-compliance model that previously governed market intermediaries and, for the first time, extending CMF supervisory perimeter to crowdfunding platforms. The same week, a tripartite ministerial order (arrete n13/2026, JORT 29-30 January 2026) replaced 2018-era casino rules with a risk-based regime requiring mandatory risk audits, a 10,000 TND enhanced-vigilance threshold, escalation of politically exposed person relationships to general management, and mandatory transaction blocking combined with suspicious-transaction reporting to the Commission Tunisienne des Analyses Financieres (CTAF) where client identity cannot be authenticated. Taken together, these instruments close gaps in cash-intensive and previously under-regulated sectors flagged in Tunisia's 2016 MENAFATF mutual evaluation, and the architecture reading is that this is a coordinated sectoral extension of AML perimeter rather than a single-agency initiative. The governing statutory basis remains Organic Law n2015-26 of 7 August 2015, as amended by Organic Law n2019-9 of 23 January 2019, with CTAF functioning as the financial intelligence unit and the CMF and Banque Centrale de Tunisie (BCT) operating as sectoral supervisors. Tunisia has remained off the FATF grey list since exiting it in October 2019, a status confirmed as of the 19 June 2026 Plenary, and a MENAFATF mutual evaluation on-site visit is understood to be scheduled for February 2026 with plenary discussion possible in November 2026 -- Tunisia's first re-rating opportunity since 2016. #### Other Developments Bureau-de-change governance tightened. A BCT circular (n2026-02) strengthens AML/CFT and proliferation-financing governance, transparency and operational compliance obligations for manual foreign-exchange bureaux, explicitly aligning the regime with FATF standards; licence withdrawal is now a stated consequence of breach, although exchange-rate and currency ceilings for tourists are unchanged. Precious-metals dealers brought into sanctions screening. A late-January 2026 JORT order imposes immediate UN and national asset-freeze list screening on jewellery and precious-metals dealers for transactions at or above 30,000 TND, with instant transaction blocking where a client appears on a freeze list and a ten-year record-retention duty. This sourcing currently rests on a single press account and has not been corroborated against a primary JORT text, so it is carried at an uncertain confidence tier pending further sourcing. Compliance technology investment. An August 2026 CTAF tender for IT-infrastructure modernisation points to an intent to strengthen the FIU's analytical capacity, though no further RegTech or AI-monitoring development beyond the tender itself has been identified this cycle. A conviction with wider resonance. A Tunisian court is reported, via a secondary aggregator citing Reuters, to have sentenced migrant-rights activist Saadia Mosbah to eight years' imprisonment on money-laundering and illicit-enrichment charges on 19 March 2026. Human-rights observers have characterised the case as part of a broader pattern; this sits at an uncertain confidence tier because only a tertiary source has been retrieved and the underlying Reuters reporting has not been independently located. A pending exchange-control overhaul with a digital-asset dimension. A cross-party bill to replace the 1976 exchange-control law, deposited in October 2025 and still under Finance Committee review through 2026, would permit resident foreign-currency accounts without prior BCT authorisation and, under its Title V, would require residents to declare to the BCT any foreign holdings and crypto-assets above a decree-set threshold, alongside a mandatory repatriation duty for related conversion proceeds. This remains at bill stage and is not yet law. #### Cross-Monitor Connections The January 2026 AML/CFT cluster and the pending exchange-control bill both touch ground that the World Payments Monitor and the Crypto Monitor are tracking independently: the BCT's broader payment-institution circular programme intersects with the same institution's AML/CFT circular on bureaux de change, and the Code des Changes crypto-declaration provisions are the same draft instrument the Crypto Monitor is watching for its effect on Tunisia's current blanket prohibition on unauthorised crypto activity. The Saadia Mosbah conviction, flagged here only as a financial-integrity data point under state-capture-adjacent monitoring rather than as a confirmed finding, is the kind of episodic signal that would warrant cross-referencing against any parallel civil-society or rule-of-law tracking were such a monitor in scope this cycle. #### Outlook The near-term marker to watch is the MENAFATF mutual evaluation cycle: an on-site visit understood to be scheduled for February 2026, with plenary discussion possible in November 2026, would be Tunisia's first re-rating since the 2016 mutual evaluation report that first flagged casino and precious-metals-sector gaps now being addressed. A positive evaluation would validate the January 2026 regulatory cluster as effective implementation rather than paper compliance; a critical one would suggest the new instruments have not yet translated into supervisory practice. Separately, the draft Code des Changes remains in committee as of early October 2026, and its eventual fate will determine whether Tunisia's crypto-asset posture shifts from blanket prohibition toward a declared, threshold-based holding regime -- a structural change relevant to both the AML perimeter and digital-asset architecture more broadly. Disclaimer: This brief characterises publicly reported, in-progress developments. It offers analytical orientation and is not legal advice, investment advice or a definitive statement of any entity's compliance status. Earlier periodic briefs (2) 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Tunisia's central bank has moved to tighten, not loosen, the supervisory architecture around payment institutions. Banque Centrale de Tunisie Circular 2026-10, published on 25 September 2026, repeals and replaces the prior Circular 2018-16 and overhauls payment-institution governance, customer identification and cybersecurity requirements, with a three-month transition window that runs to approximately 25 December 2026. The circular is confirmed on the BCT's own site and corroborated by independent Tunisian press reporting on its substance. Among the confirmed elements are a board-level audit-and-risk committee requirement and, on probable but not yet primary-sourced grounds, an annual cybersecurity audit certified by the national cybersecurity agency (ANCS). The structural reading is that Tunisia's payment sector is being pulled toward a more codified, audited compliance posture at the same time digital-KYC and onboarding identification rules are tightened. This sits squarely within the AML/CTF regime (D7) as a standing-record update rather than a new legal base, since the country's foundational AML/CFT law remains Organic Law No. 2015-26, with CTAF continuing as the designated financial intelligence unit. #### Other Developments A January 2026 joint ministerial order brought casinos fully inside the AML/CFT perimeter. A joint order of the Ministers of Tourism, the Interior and Finance, dated 29 January 2026, applies the full Organic Law 2015-26 regime to licensed casinos, requiring risk assessment, a compliance officer, staff training, independent audit, ten-year record retention and immediate suspicious-transaction reporting to CTAF. This repeals a narrower 2018 casino-specific order and is corroborated by a single trade-press source rather than a retrieved primary gazette text, which caps the finding at a probable tier. Tunisia remains outside the FATF grey list. As of the FATF's 19 June 2026 Plenary statement, Tunisia is not among the jurisdictions under increased monitoring, consistent with the country's 2019 follow-up mutual evaluation report rating it compliant or largely compliant on the substantial majority of the FATF's forty recommendations. #### Cross-Monitor Connections The payment-institution circular's digital-KYC and cyber-audit provisions carry a direct read-across to the World Payments Monitor's operational-resilience and licensing tracks, where the same instrument drives tightening findings. The casino order's extension of suspicious-activity reporting obligations is a conflict-finance-adjacent development only in the general sense that gaming-sector AML gaps are a recognised layering vector; no Tunisia-specific conflict-finance nexus was identified this cycle. No Tunisia nexus was found in the ongoing Houthi-network sanctions-designation stream reviewed this cycle. #### Outlook The near-term marker is the circular's compliance deadline around 25 December 2026, when payment institutions must demonstrate full conformity with the new governance, cyber-audit and digital-identification requirements. Separately, a draft Foreign Exchange Code reform (Bill 115/2025), which would permit BCT-authorised crypto holding and exchange under declared thresholds, remained in Finance and Budget Committee hearings with business organisations through at least June 2026, with no floor vote reported; current law continues to prohibit most crypto dealing in the meantime. Confirmation of the primary gazette text for both the payment-institution circular and the casino order would raise both findings above their current source-tier ceiling. 28 Aug 2026 · fim-2026-08-21 #### Lead Signal Tunisia's most consequential financial-integrity development this cycle sits in the crypto and digital-assets space rather than in sanctions architecture proper. A draft law revising the country's exchange-control regime, registered before the Assembly of the Representatives of the People on 20 October 2025 as proposition de loi n°2025/115 and known as the new Code des Changes, would introduce a declare-and-hold framework for virtual and digital assets under rules to be defined by the Banque Centrale de Tunisie. This represents a structural departure from the position Tunisia has held since 2018, when digital-asset trading, exchange services and crypto-payment acceptance were placed under outright prohibition absent state authorisation. Article 74 of the draft would impose criminal penalties, running from one month to three years' custody with fines of three to five times the value of the infraction, for failure to declare digital-asset holdings or to repatriate related revenue. The bill remains at consultation stage and is not yet enacted, so it registers a structural shift in intent rather than a change in force. The Tunisian parliamentary process is reported to be actively engaged with the text: the business federation CONECT submitted forty-one proposed amendments on 1 June 2026, and the Finance and Budget Committee of the Assembly of the Representatives of the People has stated an ambition to move the bill to a vote before the 2026 summer recess. #### Other Developments Sanctions renewal status unresolved. A Tier-4 secondary source describes European Union targeted restrictive measures against individuals connected to historic Tunisian state-fund misappropriation as valid at least until 31 January 2026, with the renewal or lapse status of those measures past that date unverified this cycle. No Tier-1 European Council confirmation was retrieved to settle the question either way, and this item is accordingly carried at Low confidence rather than presented as a finding. The claim's affected-firm-type tagging spans banks and cross-sector obliged entities generally, and its customer-typology flag marks the exposure as linked to politically exposed persons, meaning institutions with correspondent or client relationships tied to the historic Tunisian state-fund matter should treat continued enhanced due diligence as warranted pending resolution of the renewal question. The underlying restrictive-measures architecture is described as structural rather than episodic, and its status past January 2026 is precisely the kind of gap a sanctions-divergence tracking function should continue to chase toward primary-source resolution rather than treat as closed by a secondary characterisation. #### Cross-Monitor Connections Two adjacent monitors carry material that intersects with, but does not duplicate, the digital-asset finding above. The crypto consumer's dedicated coverage owns the detailed licensing, token-classification, and cross-border-transfer analysis of the Code des Changes reform under its own D5-subscribed module; this brief's D5 framing is confined to the AML/CTF-relevant declaration-and-repatriation architecture rather than the licensing mechanics or product-level detail that sit properly with that coverage. Separately, the World Payments Monitor's W12 correspondent-banking and settlement-access coverage tracks the same exchange-control overhaul from the perspective of cross-border payment infrastructure and settlement access rather than financial-crime architecture; the two readings of the same instrument are complementary rather than overlapping. #### Outlook The draft Code des Changes is the single item most likely to move Tunisia's financial-integrity posture in the coming cycles. Its stage remains consultation, its committee process is active, and its sponsors have stated an intent to reach a vote before the 2026 parliamentary summer recess; passage would formalise a declare-and-hold regime for digital assets that has no current analogue in Tunisian law, a change the interpreter reads as improving Tunisia's risk direction on implementation. The unresolved EU sanctions-renewal question is the other thread to watch: absent a Tier-1 confirmation of either renewal or lapse, it remains an open question logged for tracking rather than a confirmed divergence, and institutions relying on Tunisia's otherwise clean and improving FATF and EU standing should treat the PEP-linked asset-freeze status as a distinct and still-unresolved exposure. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Tunisia sanctions exposure this cycle is defined by an architecture-level divergence between jurisdiction status and individual-designation maintenance rather than by any new country-level measure. At the jurisdiction level, Tunisia is not listed on the FATF Jurisdictions Under Increased Monitoring list as of the June 2026 statement, is absent from the European Union high-risk third-country delegated regulation update of December 2025, and does not appear on the United Kingdom high-risk third-country advisory of June 2026. This absence is cross-corroborated across three independent tier-one institutional sources, a stronger evidentiary basis than a single-source finding would provide, but it is explicitly contingent on the outcome of the pending fifth-round FATF/MENAFATF Mutual Evaluation, with a possible plenary discussion around November 2026. That evaluation is conducted under the FATF 2022 effectiveness-focused Methodology, a materially harder test than the technical-compliance standard under which Tunisia exited ICRG monitoring in October 2019, and it is the single mechanism by which the current off-list architecture could shift. Continue reading Beneath the jurisdiction-level picture, individual sanctions maintenance tells a different story. The United States Office of Foreign Assets Control updated the SDN/SDGT designations of two Tunisian nationals within the eighteen-month baseline window, in both cases adding secondary-sanctions risk language under amended Executive Order 13224. Mounir Ben Habib Jarraya was designated within a broader Iran and counter-terrorism package in November 2025, and Ayadi Chafiq Bin Muhammad, a long-standing Al-Qaida financier operating a network spanning Germany, the United Kingdom, Belgium and Austria, had his listing updated in May 2026, more than a decade after his original designation. Both actions demonstrate that active list maintenance for Tunisian-national counter-terrorism financing targets continues irrespective of jurisdiction-level sanctions status, and both illustrate a persistent asynchronicity between OFAC maintenance cycles and the parallel European Union autonomous and United Nations 1267 listings of the same individuals, a timing friction that creates correspondent-banking screening risk independent of country-level exposure. The separate, longer-standing sanctions instrument affecting Tunisia is the European Union and United Kingdom asset freeze targeting Ben Ali-era wealth under Council Regulation 101/2011 and the mirrored UK Tunisia (Asset-Freezing) Regulations 2011, which has been renewed annually since 2011 with no reported delisting. This is a state-level architecture in form but a beneficial-ownership-recovery mechanism in function, and its fifteen-year duration without meaningful asset recovery is a sanctions-effectiveness data point in its own right: the freeze has been sustained without producing the recovery outcome it was designed to enable. This layered picture also carries correspondent-banking screening implications: banks maintaining Tunisia-nexus relationships must screen against three distinct sanctions layers simultaneously, jurisdiction-level list absence, individual OFAC and parallel EU and UN designations, and the standing asset-freeze annex, each updated on its own cycle and each resting on a different obligation basis, OFAC regulations, the OFSI Tunisia (Asset-Freezing) Regulations 2011, and EU autonomous measures respectively. Read together, these three layers, jurisdiction-level absence from high-risk lists, individually maintained counter-terrorism designations, and a durable but under-delivering asset freeze, describe a sanctions architecture in which formal status and substantive risk diverge in more than one direction simultaneously. The jurisdiction-level absence understates institutional-erosion risk that the pending Mutual Evaluation may or may not surface; the individual-level designations show that targeted sanctions infrastructure functions independently of jurisdiction status; and the asset freeze shows that even sustained multilateral sanctions pressure does not guarantee recovery absent functioning beneficial-ownership transparency and mutual legal assistance follow-through. #### Outlook The fifth-round FATF/MENAFATF Mutual Evaluation plenary, possible around November 2026, is the pivotal sanctions-architecture event for Tunisia over the coming two quarters: an effectiveness-focused finding of deficiency would be the first concrete mechanism by which the current off-list status could be revisited, feeding directly into the European Commission next high-risk third-country delegated regulation update expected in the fourth quarter of 2026. Continued OFAC maintenance activity on Tunisian-national counter-terrorism designations should be expected to proceed on its own schedule, independent of the jurisdiction-level review, sustaining the asynchronous-listing friction already observed between United States, European Union and United Nations sanctions instruments. This is scenario framing rather than a forecast of any specific listing outcome. Judgment: No Tunisia-specific sanctions-evasion development found this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency Tunisia sits outside the European Union direct regulatory perimeter as a non-EU third country; the AML Regulation, the sixth Anti-Money Laundering Directive and the AMLA Regulation transposition and supervisory architecture do not apply to Tunisia directly, and its relevance to that architecture runs instead through candidacy for the EU high-risk third-country list and through the governance conditionality attached to the EU-Tunisia Pact for the Mediterranean. The directly relevant beneficial-ownership developments for Tunisia this cycle are domestic and structural. Tunisia has no centralised public beneficial-ownership register. The closest instrument, CTAF Decision No.3/2017, imposes a fiduciary and trustee declaration duty, but that duty carries no punitive sanction for non-compliance, a gap identified in FATF follow-up reporting and unresolved in the current eighteen-month window. Against that structural backdrop, the Ben Ali-clan asset-concealment architecture remains the defining Tunisia beneficial-ownership case: an estimated 4.6 billion US dollars in misappropriated state funds concealed through nominee-held accounts and trust-like arrangements layered across Switzerland, France and the United Arab Emirates, frozen under EU and UK measures since 2011 with no reported delisting, and still largely unrecovered despite the March 2026 convictions of former Prime Minister Youssef Chahed and businessman Marouan Mabrouk on money-laundering and embezzlement charges. The parallel reconciliation commission established to pursue recovery has, per the assessed-tier record, failed to collect any substantial sums, illustrating that a decade-plus of unresolved beneficial-ownership opacity has outlasted freezing orders, prosecutions and a dedicated recovery mechanism alike. Continue reading Globally, the EU AML Package sets the structural direction against which this kind of durable opacity is increasingly measured, even for jurisdictions like Tunisia that sit outside its direct perimeter. The Package comprises three distinct instruments: the AML Regulation, or AMLR (Regulation (EU) 2024/1624), which is directly applicable across member states without national transposition; the sixth Anti-Money Laundering Directive, or 6AMLD, which each member state transposes individually; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority and creates a direct and indirect supervisory perimeter that shifts a defined set of higher-risk, cross-border obliged entities from purely national supervision toward a hybrid EU-level regime. That architecture is standing structural context rather than a Tunisia-specific finding this cycle: Tunisia beneficial-ownership exposure is read against it as an illustration of the gap between an emerging centralised-supervision model inside the EU and the absence of any comparable enforcement mechanism, punitive or supervisory, in a non-EU jurisdiction whose own opacity case has proven exceptionally durable. The combined picture is a beneficial-ownership regime defined less by any single new development than by persistence: a fifteen-year-old freeze, a declaration duty without teeth, and a recovery commission without results, unfolding in a jurisdiction structurally outside the supervisory model that the EU is currently building for exactly this kind of cross-border concealment case. #### Outlook The near-term Tunisia beneficial-ownership picture is unlikely to shift mechanically; no scheduled domestic reform to the CTAF declaration-sanction gap has been identified, and the reconciliation commission recovery record gives no basis for expecting a change in outcome absent renewed mutual-legal-assistance pressure from Switzerland, France or the United Arab Emirates. The more consequential external variable is the pending FATF/MENAFATF Mutual Evaluation, whose effectiveness-focused findings could, indirectly, increase pressure on the Tunisia beneficial-ownership framework if assessors treat the unsanctioned declaration duty as a technical-compliance deficiency. This is illustrative framing, not a prediction of the Mutual Evaluation outcome. Judgment: No new beneficial-ownership registry development found for Tunisia this cycle. Uncertain #### Enabler Jurisdictions Tunisia's January 2026 regulatory cluster is best read through the enabler-jurisdiction lens as a deliberate closing of gaps in sectors that have historically operated with lighter AML oversight than banks. The Conseil du Marche Financier published a risk-based AML/CFT/PF implementing regulation in JORT n9 of 23 January 2026, replacing the prior formal-compliance model for market intermediaries and, notably, extending CMF supervisory perimeter to crowdfunding platforms for the first time. Crowdfunding has been a gap across many MENA jurisdictions precisely because it sits outside traditional banking-sector AML programmes while still moving pooled retail capital; bringing it inside CMF supervision closes a route that could otherwise have functioned as an under-supervised channel into the formal financial system. Continue reading The same week produced a tripartite ministerial order from the Ministries of Tourism, Interior and Finance replacing 2018 casino rules with a materially more demanding risk-based regime: mandatory risk audits, a 10,000 TND enhanced-vigilance threshold, escalation of politically exposed person relationships to general management, and mandatory transaction blocking combined with CTAF suspicious-transaction reporting where client identity cannot be authenticated. Casinos are a classic cash-intensive sector flagged in Tunisia's 2016 MENAFATF mutual evaluation report as a facilitation risk, and the new order is a direct structural response to that historic finding rather than a response to a specific recent incident -- the architecture-over-incident distinction matters here, because it signals the regulator closing a known structural weakness proactively. A parallel late-January 2026 order extends immediate UN and national asset-freeze list screening duties to jewellery and precious-metals dealers for transactions at or above 30,000 TND, with instant transaction blocking for listed clients and ten-year record retention. Precious metals and gems are a well-documented layering and value-storage vehicle for illicit proceeds precisely because they can move value across borders without the transaction trail a banking product leaves; bringing dealers into a sanctions-screening and record-retention duty narrows that channel. This finding currently rests on a single secondary source, so its precise contours -- particularly whether enforcement mechanisms match the stated obligations in practice -- should be treated as provisional pending corroboration. Finally, Banque Centrale de Tunisie circular n2026-02 tightens AML/CFT and proliferation-financing governance for manual foreign-exchange bureaux, explicitly citing alignment with FATF standards and threatening licence withdrawal for breaches. Bureaux de change are a recurring enabler-jurisdiction weak point globally because they can provide cash-to-cash or cash-to-foreign-currency conversion with comparatively thin institutional compliance infrastructure relative to banks; tightening governance and transparency requirements here, while leaving tourist-facing exchange-rate and currency ceilings untouched, suggests the BCT is targeting the compliance architecture specifically rather than the commercial function of the bureaux. Read together, these four instruments -- CMF/crowdfunding, casinos, precious-metals dealers, and bureaux de change -- constitute a coordinated sectoral extension of AML perimeter across precisely the cash-intensive and alternative-value-transfer channels that a facilitation-risk assessment would prioritise. This is a stronger signal of structural intent than any single instrument alone, because the breadth and near-simultaneous timing (all dated within the same JORT window in January 2026) suggests centrally coordinated policy rather than agency-by-agency incrementalism. #### Outlook The test of whether this January 2026 cluster represents durable structural change rather than a paper exercise will come through the MENAFATF mutual evaluation cycle, with an on-site visit understood to be scheduled for February 2026 and plenary discussion possible in November 2026. This would be Tunisia's first re-rating since the 2016 mutual evaluation report that originally flagged casino and precious-metals-sector gaps, making the evaluation a direct referendum on whether the new instruments have produced measurable supervisory practice rather than remaining unimplemented on paper. A positive finding on effectiveness (as distinct from mere technical compliance) would be the strongest available evidence that Tunisia's enabler-jurisdiction profile has genuinely shifted; a critical finding on implementation would suggest the regulatory architecture has outpaced supervisory capacity. Readers monitoring Tunisia for enabler-jurisdiction exposure should treat the current cluster as a positive structural signal while withholding a final assessment until evidence of actual enforcement -- audits conducted, licences withdrawn, suspicious-transaction reports filed under the new casino and precious-metals regimes -- becomes available. Disclaimer: Illustrative and analytical only; not legal advice or a compliance determination. Judgment: The CMF's risk-based AML/CFT/PF regulation (JORT n°9, 23 Jan 2026) extends supervisory perimeter to crowdfunding for the first time, and the joint ministerial order on casinos closes a previously under-regulated cash-intensive sector flagged by MENAFATF's 2016 MER. Probable #### Conflict Finance and Extractive-Industry Integrity Tunisia conflict-finance exposure runs through a single, well-evidenced channel this cycle: the informal cross-border fuel and goods trade with Libya and Algeria. World Bank research finds that subsidised fuel and goods smuggling accounts for more than half of recorded Tunisia-Libya trade, driven by price differentials between the Tunisia and Libya domestic fuel-subsidy regimes and by weak customs enforcement along the border. This is not incidental leakage from an otherwise formal trading relationship; it is, per the tier-one sourcing behind this finding, the majority mode of bilateral exchange, which places trade-based value transfer at the structural centre of Tunisia-Libya commercial activity rather than at its margin. Continue reading The conflict-finance significance of this corridor comes from its adjacency to the Libyan war economy. Migrant-smuggling networks operating the same fuel and goods routes have diversified into arms and drug trafficking, meaning the physical and financial infrastructure built to move subsidised fuel across the border is reused, with limited additional friction, to move a wider set of illicit and conflict-adjacent goods. This overlap is consistent with, though not identical to, the documented Russian-linked fuel-smuggling activity operating through Libya more broadly, an approximately five-billion-US-dollar-per-year trade that FIM standing tracker T1 notes does not identify Tunisia as a primary transit or dark-fleet basing jurisdiction, but for which Tunisia represents indirect regional exposure via the same North African and Mediterranean smuggling corridors. A second, adjacent financial-facilitation layer serving this same conflict-adjacent geography is hawala-based value transfer. United Nations Office on Drugs and Crime research, including direct hawala-broker interviews conducted in Tunisia, documents the settlement of migrant-smuggling fee income through informal value-transfer systems that avoid formal banking rails. While this finding is catalogued primarily as an enabler-jurisdiction and professional-facilitator signal elsewhere in this baseline, its conflict-finance relevance is direct: the same corridors used for fuel and goods smuggling adjacent to the Libyan conflict economy generate fee income that hawala networks then settle outside any formal, traceable payment rail, compounding the difficulty of tracing conflict-adjacent financial flows through either the trade or the payments channel. This corridor also carries indirect ERM and SCEM significance: the commodity-flow dimension of subsidised-fuel arbitrage is a pattern ERM tracks in its commodity-evasion remit, while the conflict-adjacency dimension is a natural SCEM cross-reference point given proximity to the Libyan conflict economy. Cross-monitor flags raised this cycle are routing signals only, not joint findings. Neither element of this corridor is new in the sense of a discrete this-cycle event; both are structural and longstanding features of the Tunisia border economy. Their significance in this baseline is architectural: informal trade and informal payments together constitute a durable, dual-channel financial-facilitation infrastructure sitting directly adjacent to an active regional conflict economy, exploited by actors, migrant-smuggling networks foremost among them, whose criminal-diversification pattern demonstrates that the infrastructure is fungible across illicit-goods categories. #### Outlook No specific regulatory or enforcement horizon item targets this corridor directly this cycle; its persistence is a function of the underlying fuel-subsidy price differential and border-enforcement capacity constraints rather than any pending legal instrument. The corridor should be watched for enforcement-gap signal alongside any change in Libyan Security Council sanctions-regime renewal or Libyan Government fuel-subsidy policy, either of which could alter the price differential that currently sustains the smuggling volume. This is illustrative orientation rather than a forecast of any specific policy change. Judgment: Thin coverage; no conflict-finance finding for Tunisia this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation From a financial-integrity standpoint, Tunisia's digital-asset posture remains defined by the tension between a still-unenacted reform bill and an operative exchange-control prohibition. A cross-party bill to replace Tunisia's 1976 exchange-control law -- deposited in the Assembly of the Representatives of the People in October 2025, backed by 40 deputies, and still under Finance Committee review as of a 7 October 2026 report -- would permit resident foreign-currency accounts without prior BCT authorisation and, under its Title V, would require residents to declare to the BCT any foreign holdings and crypto-assets above a decree-set threshold, with mandatory repatriation of proceeds from their conversion. This is a materially different model from blanket prohibition: it would create a formal declaration channel for crypto-assets rather than treating all unauthorised crypto activity as a prohibited act, which is the posture under the BCT's 2018 directive that remains the operative legal baseline while the bill is pending. Continue reading The financial-integrity significance of this pending shift is that a declaration-and-repatriation regime, if enacted, would give Tunisian authorities formal visibility into resident crypto holdings that currently exists in a grey or unregulated space -- precisely the kind of visibility gap that FATF's virtual-asset standards are designed to close globally. At present, cross-border crypto-related conversion and transfer activity in Tunisia sits outside any declared reporting channel, which from an AML/CFT perspective represents an information gap rather than a confirmed illicit-finance channel; the gap itself, not any specific finding of abuse, is the analytically relevant point under an enablement-as-signal framing. Absence of an enforcement record here should not be read as absence of risk -- it may equally indicate that supervisory visibility into the sector is currently limited. The bill's progress has been slow and incremental: deposited in October 2025, it remained under committee review through the first three quarters of 2026 with no confirmed timeline for a floor vote or presidential assent as of the most recent sourcing. This is characteristic of a legislative process moving cautiously on a politically and economically sensitive reform (the broader exchange-control liberalisation agenda extends well beyond crypto, touching resident foreign-currency account access generally), and the crypto-declaration provisions are a relatively small component of that wider bill rather than a standalone crypto law. This matters for sequencing: even once the broader Code des Changes passes, the crypto-specific declaration mechanics would likely depend on a further implementing decree to set the reporting threshold, meaning a material lag between enactment and the regime becoming operationally meaningful is plausible. #### Outlook The committee-review status as of October 2026 gives no firm signal on an enactment date, and the threshold-setting decree referenced in Title V has not yet been published even in draft form, so the practical contours of any future declaration regime remain undefined. Readers should treat Tunisia's crypto-asset financial-integrity exposure as currently resting on the 2018 BCT prohibition baseline, with the pending bill representing a directional signal toward eventual visibility and declaration rather than a change that has yet taken effect. The MENAFATF mutual evaluation cycle, with a possible plenary discussion in November 2026, may also surface views on virtual-asset-related gaps in Tunisia's broader AML/CFT framework, which would be a useful corroborating signal to watch alongside the bill's own legislative progress. Disclaimer: Illustrative and analytical only; not legal advice or a compliance determination. Judgment: A draft Code des Changes bill, pending since October 2025 and still under Finance Committee review as of a 7 October 2026 report, would create a crypto-asset declaration/repatriation regime; the BCT's 2018 directive criminalising unauthorised crypto transactions remains the operative prohibition. Uncertain #### Compliance Technology and Active Defence No RegTech, artificial-intelligence or machine-learning transaction-monitoring, or perpetual-know-your-customer development specific to Tunisia was identified in this baseline research cycle. The domain tracker record for this domain carries the global compliance-technology thesis forward unchanged rather than asserting any Tunisia-specific finding, and no jurisdiction field is populated against this domain this cycle, reflecting an absence of retrievable primary-source evidence rather than a substantive judgment about the state of compliance-technology adoption among Tunisia obliged entities. Continue reading This absence is analytically notable when read against several other findings in this baseline rather than in isolation. Tunisia informal value-transfer exposure, documented through hawala-broker interviews conducted by the United Nations Office on Drugs and Crime, and the durable Ben Ali-era beneficial-ownership concealment architecture both describe illicit-finance channels that modern transaction-monitoring and perpetual-KYC tooling is, in other jurisdictions, increasingly deployed to surface. Whether Tunisia obliged entities, banks, money-service businesses, or others currently have access to comparable tooling is simply unknown from this cycle research rather than confirmed absent; the gap is evidentiary, not substantive. #### Outlook Future cycles should continue to check for Central Bank of Tunisia or CTAF guidance on transaction-monitoring technology standards, AI/ML screening tools, or perpetual-KYC requirements applicable to Tunisia obliged entities; none is currently known to be pending. Given the absence of any horizon item touching compliance technology for Tunisia, this domain remains on watch status pending future primary-source retrieval rather than active escalation. This watch-status classification is distinct from the enforcement-gap and jurisdiction-risk findings elsewhere in this baseline; it reflects a research-coverage limitation, not an assessed weakness in the Tunisia compliance-technology posture. Judgment: An August 2026 CTAF IT-infrastructure tender aims to modernise analytical capacity; no further RegTech/AI-monitoring development this cycle. Uncertain #### AML/CTF Regime Tunisia's AML/CTF regime rests on Organic Law n2015-26 of 7 August 2015, as amended by Organic Law n2019-9 of 23 January 2019, with the Commission Tunisienne des Analyses Financieres (CTAF) functioning as the financial intelligence unit and the Conseil du Marche Financier (CMF) and Banque Centrale de Tunisie (BCT) operating as the principal sectoral supervisors. This statutory architecture has not changed this cycle, but its implementing layer has moved substantially: the CMF published a new risk-based AML/CFT/PF implementing regulation in JORT n9 of 23 January 2026 that replaces a formal-compliance model with a risk-based one and, for the first time, extends CMF supervisory perimeter to crowdfunding platforms. This is a significant implementation-level development because it operationalises the risk-based approach that FATF standards require at the level of a specific regulated sector, rather than remaining a general statutory principle. Continue reading Alongside the CMF regulation, a tripartite ministerial order addressing casino AML obligations and a BCT circular (n2026-02) tightening bureau-de-change governance both entered into force in the same January 2026 window, each confirmed against the same statutory base and each extending risk-based supervision into a specific sector. The breadth of this implementing activity across three distinct regulatory bodies (CMF, joint ministries, BCT) in close succession is a stronger indicator of coordinated regime strengthening than any single instrument would be on its own, consistent with an architecture-over-incident reading of the cycle's significance. On the international-standing dimension, Tunisia has remained off the FATF grey list since exiting it in October 2019, with that status confirmed as current at the 19 June 2026 FATF Plenary among the 22 jurisdictions presently listed, none of which is Tunisia. This durable off-list status is itself the backdrop against which the January 2026 implementing cluster should be read: Tunisia is not responding to a grey-list action-plan deadline but appears to be pursuing proactive technical-compliance strengthening, plausibly in anticipation of its forthcoming MENAFATF mutual evaluation. That mutual evaluation is the single most consequential near-term event for Tunisia's AML/CTF regime. A MENAFATF on-site visit is understood to be scheduled for February 2026, with plenary discussion of the resulting mutual evaluation report possible in November 2026 -- Tunisia's first re-rating since its 2016 mutual evaluation, which is understood to have flagged casino and precious-metals-sector gaps that the January 2026 instruments now directly address. The timing suggests the implementing cluster was deliberately sequenced ahead of the on-site assessment, which if borne out would itself be a notable piece of regime-strengthening evidence, separate from the content of the instruments themselves. #### Outlook The MENAFATF mutual evaluation result, expected to crystallise through 2026, will be the decisive test of whether Tunisia's technical-compliance strengthening in January 2026 translates into an effectiveness rating that reflects genuine implementation. A positive effectiveness finding would validate the sequencing read above; a critical finding would suggest a gap between the newly published rules and operational supervisory capacity at CTAF, CMF and BCT. Separately, an August 2026 CTAF tender for IT-infrastructure modernisation suggests the FIU itself is investing in analytical capacity, which would support stronger implementation of the new risk-based obligations if the investment materialises into deployed capability ahead of or during the mutual evaluation window. No grey-list risk is currently indicated; the relevant risk axis for Tunisia's AML/CTF regime over the coming cycles is mutual-evaluation outcome and implementation depth, not grey-list re-entry. Disclaimer: Illustrative and analytical only; not legal advice or a compliance determination. Judgment: The governing instrument remains Organic Law n°2015-26 of 7 August 2015 as amended by Organic Law n°2019-9 of 23 January 2019, with CTAF as the FIU and CMF/BCT as sectoral supervisors; Tunisia remains off the FATF grey list since October 2019, with a MENAFATF mutual evaluation possible (onsite Feb 2026, plenary Nov 2026) that would be Tunisia's first re-rating since 2016. Probable Judgment: No financial-integrity-market commercial event (AML/KYC vendor M&A, de-risking exits) involving Tunisia found this cycle. Uncertain Regulatory horizon Proposed 2026-Q4 · ±year ### Draft law criminalizing unlicensed online/digital gambling platforms If enacted, use and promotion of unlicensed digital gambling platforms would become a criminal offence carrying 1-5 years' imprisonment and substantial fines. [Source](https://tribuna.com/en/casino/news/2026-01-28-tunisia-lawmakers-propose-sweeping-crackdown-on-online-and-offline-gambling/) 1 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Three parallel AML/CFT instruments (CMF, casino, precious-metals) entered into force in Tunisia in late January 2026, each with transaction-screening and SAR implications. MLRO functions with Tunisia exposure in crowdfunding, casino-adjacent, or precious-metals-dealing relationships should note new enhanced-vigilance thresholds (10,000 TND casino; 30,000 TND precious metals) and mandatory asset-freeze-list screening now in force. 3 evidence refs Compliance ### CMF extended its supervisory perimeter to crowdfunding platforms for the first time under a new risk-based AML/CFT/PF regulation. Compliance functions overseeing Tunisia-linked crowdfunding or market-intermediary relationships face a changed supervisory perimeter and should confirm counterparties are operating under the new risk-based model rather than the prior formal-compliance regime. 1 evidence refs Legal ### A pending Code des Changes bill would create a crypto-asset declaration and repatriation duty, but remains unenacted as of October 2026. Legal counsel advising on Tunisia exchange-control exposure should track the bill's committee-review status; current law remains the existing exchange-control framework, not the proposed declaration regime. 1 evidence refs Board ### Tunisia is undergoing a coordinated AML/CFT strengthening cycle ahead of a MENAFATF mutual evaluation expected through 2026. Board-level oversight of Tunisia country risk should note the regime is tightening structurally, with Tunisia's first re-rating since 2016 pending; this is a reputational and regulatory-relationship consideration rather than an immediate sanctions exposure. 1 evidence refs CTO ### A draft exchange-control bill would introduce a BCT crypto-asset declaration threshold, a structural change to Tunisia's digital-asset data and reporting architecture if enacted. Technology functions building compliance tooling for Tunisia exposure should monitor for the decree setting the declaration threshold, as it would define new data-capture and reporting requirements not currently specified. 1 evidence refs Risk ### A dense sequence of AML/CFT instruments across CMF, BCT and casino/precious-metals sectors indicates a structural, not episodic, strengthening of Tunisia's financial-integrity regime. Risk functions should adjust Tunisia country-risk models to reflect a tightening trajectory rather than static baseline risk, while noting one single-sourced claim (precious-metals screening) remains to be corroborated. 4 evidence refs Audit ### A single-source claim on precious-metals-dealer sanctions screening has not been corroborated against a primary JORT text. Audit functions reviewing evidence trails for Tunisia AML findings should flag that the precious-metals-dealer screening obligation rests on one T3 source and has not been confirmed against the underlying legal instrument. 1 evidence refs Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture stable No material change found in UN Panel / OFAC / OFSI Russia or Yemen/Houthi channels specific to Tunisia this cycle. T2 · EU AML Package / AMLA no_change Tunisia is not an EEA/EU member and is not bound by AMLR/6AMLD/AMLA; no change to monitor. T3 · FATF Grey List stable Tunisia exited the FATF grey list in October 2019 and remains off it as of the 19 June 2026 Plenary. A MENAFATF mutual evaluation on-site is possible Feb 2026, plenary discussion possible Nov 2026. T4 · Beneficial-Ownership Register Status stable No new BO-registry development for Tunisia found this cycle. T5 · Crypto & Digital-Asset Integrity watch The draft Code des Changes (pending since October 2025, still under committee review as of 7 Oct 2026) would introduce a crypto-asset declaration/repatriation regime, while the 2018 BCT directive criminalising unauthorised crypto transactions remains in force. T6 · Sanctions Regime Divergence stable No Tunisia-specific EU/US/UK autonomous-listing divergence found this cycle; Tunisia is not currently subject to UN/EU/US/UK comprehensive sanctions. Registers ### Enforcement actions - 3 Mar 2026 - 15 Apr 2026 - 20 Nov 2025 - 21 May 2026 - 3 Mar 2026 - 19 Mar 2026 - A Tunisian court sentenced ex-PM Youssef Chahed to six years and businessman Marouan Mabrouk (Ben Ali's son-in-law) to 20 years on money-laundering, embezzlement and unlawful-benefit charges tied to a 2018 lifting of an asset freeze on Mabrouk's funds. Each defendant was also fined roughly 800 million dinars. 3 Mar 2026 - An investigating judge ordered the imprisonment of Chawki Al-Tabib, former head of Tunisia's National Anti-Corruption Authority, on money-laundering, abuse-of-office and embezzlement charges dating to his 2016-2020 tenure, with an accompanying asset freeze. Rights groups characterise the charges as retaliatory. 15 Apr 2026 - OFAC updated its SDN List entries for Mounir Ben Habib Jarraya, a Tunisian national resident in Italy, adding secondary-sanctions risk language under Executive Order 13224 as amended, as part of a broader Iran/counter-terrorism designation package. 20 Nov 2025 - OFAC issued an updated SDGT designation for Ayadi Chafiq Bin Muhammad, a Tunisian national long linked to Al-Qaida financing across Germany, UK, Belgium and Austria, adding secondary-sanctions risk under amended Executive Order 13224. 21 May 2026 ### Sanctions changes - 31 Jan 2025 - 31 Jan 2025 - 20 Nov 2025 - 21 May 2026 - 30 Jan 2026 - The EU's Council Regulation (EU) No 101/2011 freezing assets of persons responsible for misappropriation of Tunisian state funds (the Ben Ali-era freeze) has been renewed annually since 2011 via successive Council Implementing Regulations. The most recent renewal cycle within the review window was not independently re-verified against a primary 2025/2026 implementing regulation in this research pass, though no delisting or wind-down has been reported. 31 Jan 2025 - OFAC added secondary-sanctions risk language to the SDN List entry for Tunisian national Mounir Ben Habib Jarraya as part of a wider Iran/counter-terrorism designation package touching multiple jurisdictions. 20 Nov 2025 - OFAC updated the SDGT designation of Tunisian national Ayadi Chafiq Bin Muhammad, adding secondary-sanctions risk tags under amended Executive Order 13224, alongside a broader package including Hizballah/IRGC-linked designations. 21 May 2026 ### Regulatory horizon (register) - Draft law criminalizing unlicensed online/digital gambling platforms - Code des Changes reform (proposition de loi n°2025/115) - Tunisia's 5th-round FATF/MENAFATF Mutual Evaluation plenary - Next EU high-risk third-country delegated regulation update - EU-Tunisia Pact for the Mediterranean Action Plan implementation ### Active schemes - [HIGH] Ben Ali-clan looted-asset concealment via offshore/nominee structures - Cross-border fuel and goods smuggling, Tunisia-Libya-Algeria corridor - Hawala-based migrant-smuggling payment networks via Tunisia Sources - [Sanctions - consilium.europa.eu - European Union](https://www.consilium.europa.eu/en/topics/sanctions/) - [EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=LEGISSUM%3A4330725&rid=2) - [Global Sanctions](https://globalsanctions.com/region/tunisia/) - [Global Affairs Canada](https://international.canada.ca/en/global-affairs/corporate/transparency/acts-regulations/regulatory-reviews/sor-2016-42) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Tunisia.html) - [Checklynx](https://checklynx.com/en/resources/knowledge-base/fatf-grey-list) - [Wikipedia](https://en.wikipedia.org/wiki/2026_in_Tunisia) - [TechAfrica News](https://techafricanews.com/2026/05/07/tunisia-launches-tunpay-to-unify-mobile-payment-system-nationwide/) - [News Tunisia (Tunisie Numerique)](https://news-tunisia.tunisienumerique.com/tunpay-toward-a-big-bang-in-mobile-payments/) - [GamblingMaps.org](https://gamblingmaps.org/map/regulations/tunisia) - [BusinessDataGuide](https://www.businessdataguide.com/blog/jurisdictions/tunisia-company-search-guide) - [Open Ownership](https://www.openownership.org/en/map/country/tunisia/) - [https://www.fatf-gafi.org/en/countries/detail/Tunisia.html](https://www.fatf-gafi.org/en/countries/detail/Tunisia.html) - [https://www.fatf-gafi.org/en/countries/global-network/middle-east-and-north-africa-financial-action-task-force--menafa.html](https://www.fatf-gafi.org/en/countries/global-network/middle-east-and-north-africa-financial-action-task-force--menafa.html) - [https://www.iomfsa.im/fsa-news/2026/jun/amlcft-country-lists-update-june-2026](https://www.iomfsa.im/fsa-news/2026/jun/amlcft-country-lists-update-june-2026) - [https://www.global-amlcft.eu/where-we-work-old/tunisia-aml-cft/](https://www.global-amlcft.eu/where-we-work-old/tunisia-aml-cft/) - [https://www.knowyourcountry.com/tunisia/](https://www.knowyourcountry.com/tunisia/) - [https://payments.gi/jurisdictions/tunisia/](https://payments.gi/jurisdictions/tunisia/) - [https://www.lapresse.tn/2026/02/20/comptes-en-devises-crypto-actifs-simplification-ce-que-prevoit-le-nouveau-code-des-changes/](https://www.lapresse.tn/2026/02/20/comptes-en-devises-crypto-actifs-simplification-ce-que-prevoit-le-nouveau-code-des-changes/) - [https://www.lapresse.tn/2026/03/29/tribune-vers-un-nouveau-code-des-changes-la-tunisie-engage-une-reforme-structurelle-de-sa-legislation-financiere/](https://www.lapresse.tn/2026/03/29/tribune-vers-un-nouveau-code-des-changes-la-tunisie-engage-une-reforme-structurelle-de-sa-legislation-financiere/) - [Banque Centrale de Tunisie](https://www.bct.gov.tn/) - [allAfrica](https://fr.allafrica.com/stories/202609280258.html) - [Challenges.tn](https://www.challenges.tn/economie/paiement-mobile-en-tunisie-la-bct-resserre-les-regles-avec-sa-nouvelle-circulaire-n2026-10/) - [iGaming Times](https://igaming-times.com/countries/tunisia) - [Voveid](https://blog.voveid.com/aml-compliance-in-tunisia-a-2025-guide-for-fintechs-and-regulated-businesses/) - [Financial Action Task Force](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Tunisie Numérique](https://news-tunisia.tunisienumerique.com/today-in-parliament-conect-heard-on-the-exchange-code/) - [https://kapitalis.com/tunisie/2026/01/24/tunisie-nouveau-reglement-pour-lutter-contre-le-blanchiment-dargent/](https://kapitalis.com/tunisie/2026/01/24/tunisie-nouveau-reglement-pour-lutter-contre-le-blanchiment-dargent/) - [https://www.challenges.tn/economie/tunisie-le-cmf-publie-un-nouveau-reglement-anti-blanchiment-et-etend-la-surveillance-au-crowdfunding/](https://www.challenges.tn/economie/tunisie-le-cmf-publie-un-nouveau-reglement-anti-blanchiment-et-etend-la-surveillance-au-crowdfunding/) - [https://www.lapresse.tn/2026/02/03/ce-quon-doit-retenir-du-nouvel-arrete-concernant-les-casions-et-jeu-de-paris/](https://www.lapresse.tn/2026/02/03/ce-quon-doit-retenir-du-nouvel-arrete-concernant-les-casions-et-jeu-de-paris/) - [https://managers.tn/2026/01/29/a-partir-de-30-000-dinars-les-commercants-de-bijoux-soumis-a-de-nouvelles-obligations/](https://managers.tn/2026/01/29/a-partir-de-30-000-dinars-les-commercants-de-bijoux-soumis-a-de-nouvelles-obligations/) - [https://www.lapresse.tn/2026/01/31/touristes-etrangers-ce-qui-change-dans-les-bureaux-de-change-tunisiens/](https://www.lapresse.tn/2026/01/31/touristes-etrangers-ce-qui-change-dans-les-bureaux-de-change-tunisiens/) - [https://en.wikipedia.org/wiki/2026_in_Tunisia](https://en.wikipedia.org/wiki/2026_in_Tunisia) - [https://www.tuniscope.com/article/415796/tunisie/actualites/bitcoin-480212](https://www.tuniscope.com/article/415796/tunisie/actualites/bitcoin-480212) - [Mutual Evaluation of Tunisia](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoftunisia.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Tunisia](https://www.fatf-gafi.org/en/countries/detail/Tunisia.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [Documents - Financial Action Task Force (FATF)](https://www.fatf-gafi.org/publications/mutualevaluations/documents/mutualevaluationoftunisia.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [Tunisia's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-tunisia-2016.html) - [Tunisia's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-tunisia-2020.html) - [Middle East and North Africa Financial Action Task Force (MENAFATF)](https://www.fatf-gafi.org/en/countries/global-network/middle-east-and-north-africa-financial-action-task-force--menafa.html) - [Tunisia Jails Ex Prime Minister and Billionaire in Major Corruption Ruling | OCCRP](https://www.occrp.org/en/news/tunisia-jails-ex-prime-minister-and-billionaire-in-major-corruption-ruling) - [Tunisia Jails Former Anti-Corruption Chief in Move Decried as ‘Judicial Harassment’ | OCCRP](https://www.occrp.org/en/news/tunisia-jails-former-anti-corruption-chief-in-move-decried-as-judicial-harassment) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Middle East and North Africa Financial Action Task Force](https://www.fatf-gafi.org/media/fatf/content/images/MENAFATF-3rd-FUR-Tunisia.pdf) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [ECSH31555 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh31555) - [Questions and answers on the Pact on Migration and Asylum - Migration and Home Affairs](https://home-affairs.ec.europa.eu/policies/migration-and-asylum/pact-migration-and-asylum/questions-and-answers-pact-migration-and-asylum_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [Asylum policy: Council and European Parliament agree on EU list of safe countries of origin - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/18/asylum-policy-council-and-european-parliament-agree-on-eu-list-of-safe-countries-of-origin/) - [Countries / Jurisdictions](https://fatf-gafi.org/countries/#Tunisia) - [Counter Terrorism Designations; Administrative List Updates: Addition of Secondary Sanctions Information | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250328) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions) - [Counter Terrorism Designation | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20201211_44) - [SDGT Designations Updates | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20060727) - [International Criminal Court-related Designation; Issuance of International Criminal Court-related General License | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250709_33) - [Iran-related Designations; Counter Terrorism Designations, Updates, and Removals; Balkans-related Designation Removal | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251120) - [Counter Narcotics and Counter Terrorism Designations; Report for Licensing Activities Undertaken Pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250806) - [Home | Office of Foreign Assets Control](https://ofac.treasury.gov/) - [Counter Terrorism Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260521) - [2nd Enhanced Follow-Up Report for Tunisia](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/FUR2-Tunisia-Dec-2017.pdf) - [4th Enhanced Follow-Up Report for The Republic of Tunisia](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/MENAFATF-FUR-Tunisia-2020.pdf.coredownload.pdf) - [Fatf-gafi](https://www.fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/Tunisia_MER_2016_EN.pdf) - [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports) - [Countries / Jurisdictions](http://www.fatf-gafi.org/countries/#Tunisia) - [Tunisia's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-tunisia-2019.html) - [1 BY OPIATE TRAFFICKERS AND MIGRANT SMUGGLERS The Hawala System](https://www.unodc.org/documents/data-and-analysis/AOTP/Hawala_Digital.pdf) - [MONEY LAUNDERING AND TERRORIST FINANCING RISKS ARISING FROM MIGRANT SMUGGLING](https://www.fatf-gafi.org/content/dam/fatf-gafi/brochures/Migrant-smuggling-handout.pdf) - [Comprehensive Update on Terrorist Financing Risks FATF REPORT July 2025](https://www.fatf-gafi.org/content/dam/fatf-gafi/publications/Comprehensive-Update-on-Terrorist-Financing-Risks-2025.pdf.coredownload.inline.pdf) - [Tracking illicit financial flows linked to human trafficking and migrant smuggling](https://www.unodc.org/unodc/human-trafficking/Webstories2023/tracking-illicit-financial-flows-linked-to-human-trafficking-and-migrant-smuggling.html) - [UK sanctions notorious people-smuggling gangs and their enablers in global crackdown - GOV.UK](https://www.gov.uk/government/news/uk-sanctions-notorious-people-smuggling-gangs-and-their-enablers-in-global-crackdown) - [The role of Hawala and other similar service providers in money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Role-hawalas-in-ml-tf.html) - [Who, Where, How and Why? A data-driven look behind migrant smuggling around the world](https://www.unodc.org/unodc/en/frontpage/2026/June/who--where--how-and-why-a-data-driven-look-behind-migrant-smuggling-around-the-world.html) - [FinCEN Issues Report on Informal Value Transfer Systems | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-report-informal-value-transfer-systems) - [Stories from UNODC](https://www.unodc.org/unodc/frontpage/) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Central bank digital currency (CBDC)](https://www.trmlabs.com/glossary/central-bank-digital-currency) - [2025 Crypto Adoption and Stablecoin Usage Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2025-crypto-adoption-and-stablecoin-usage-report) - [Current State of Central Bank Digital Currencies (CBDCs)](https://www.chainalysis.com/blog/central-bank-digital-currencies-cbdc/) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [FSB thematic review 2025: Global crypto regulation remains fragmented despite market growth](https://www.elliptic.co/blog/fsb-thematic-review-2025) - [Tunisia Looks to Central Bank to Repay Debt as Economy Reels - Bloomberg](https://www.bloomberg.com/news/articles/2024-12-02/tunisia-looks-to-central-bank-to-repay-debt-as-economy-flails) - [Tunisian Lawyer Arrested After Criticizing Mass Sentencing of Opposition Figures | OCCRP](https://www.occrp.org/en/news/tunisian-lawyer-arrested-after-criticizing-mass-sentencing-of-opposition-figures) - [Tunisia: Former President’s Brother-in-Law Charged with Corruption](https://www.occrp.org/en/daily/14013-tunisia-former-president-s-brother-in-law-charged-with-corruption) - [Jailed Tunisian Opposition Leader Sentenced to Life in Prison - Bloomberg](https://www.bloomberg.com/news/articles/2026-06-02/jailed-tunisian-opposition-leader-sentenced-to-life-in-prison) - [Tunisia declares “War on Corruption”; Arrests Four | OCCRP](https://www.occrp.org/en/news/tunisia-declares-war-on-corruption-arrests-four) - [Tunisia Fires Energy Top Officials in High-Profile Graft Scandal - Bloomberg](https://www.bloomberg.com/news/articles/2018-08-31/tunisia-fires-energy-top-officials-in-high-profile-graft-scandal) - [Tunisia: Former President’s Brother-in-Law Charged with Corruption | OCCRP](https://www.occrp.org/en/news/tunisia-former-presidents-brother-in-law-charged-with-corruption) - [Country policy and information note: security situation, Libya, April 2025 (accessible) - GOV.UK](https://www.gov.uk/government/publications/libya-country-policy-and-information-notes/country-policy-and-information-note-security-situation-libya-april-2025-accessible) - [Trafficked and Tortured: Shocking Report Links EU Aid to Migrant Exploitation | OCCRP](https://www.occrp.org/en/news/trafficked-and-tortured-shocking-report-links-eu-aid-to-migrant-exploitation) - [Russia Is Benefiting From Libya’s $5 Billion Smuggled-Fuel Trade](https://www.bloomberg.com/features/2024-libya-russia-oil-smuggling/) - [Links Between Smuggling of Migrants and Other Forms of ...](https://www.unodc.org/romena/uploads/documents/2024/Links_between_smuggling_of_migrants_and_organized_crime_along_the_Central_and_Western_Mediterranean_routes_Digital_1.pdf) - [Security Council Updates Sanctions Regime on Libya, Extends Mandate until May 2026, Adopting Resolution 2769 (2025) with 14 Members in Favour, 1 Abstaining | UN Meetings Coverage and Press Releases](https://press.un.org/en/2025/sc15967.doc.htm) - [On the Edge? Trafficking and Insecurity at the Tunisian- ...](https://assets.publishing.service.gov.uk/media/5a7c5480e5274a1b004230aa/SAS-WP17-Tunisia-On-the-Edge.pdf) - [Policy Research Working Paper 6731 Estimating Informal Trade across Tunisias](https://assets.publishing.service.gov.uk/media/5a7cab6b40f0b6629523b104/Estimating_Informal_Trade_across_Tunisia_s_Land_Borders.pdf) - [Iraqi Forces Seize 400,000 Captagon Pills Near Syrian Border in Major Drug Bust | OCCRP](https://www.occrp.org/en/news/iraqi-forces-seize-400000-captagon-pills-near-syrian-border-in-major-drug-bust) - [FUEL TRAFFICKING IN THE SAHEL](https://www.unodc.org/documents/data-and-analysis/tocta_sahel/TOCTA_Sahel_fuel_2023.pdf) - [observatory_som_maps](https://www.unodc.org/unodc/en/data-and-analysis/observatory_som_maps.html) - [Tunisia: Council extends freeze on the assets of 48 persons for another year - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2017/01/27/sanctions-tunisia/) - [Press advisory: Global Witness spokespeople available for comment on banking of politicians’ funds | Global Witness](https://www.globalwitness.org/en/archive/press-advisory-global-witness-spokespeople-available-comment-banking-politicians-funds/) - [Tunisia Asks to Join HSBC Case to Get Embezzled Ben Ali Cash - Bloomberg](https://www.bloomberg.com/news/articles/2015-03-19/tunisia-asks-to-join-hsbc-swiss-case-to-recover-ben-ali-funds) - [Governments should name banks that took corrupt money from Gaddafi, Mubarak and Ben Ali | Global Witness](https://www.globalwitness.org/en/archive/governments-should-name-banks-took-corrupt-money-gaddafi-mubarak-and-ben-ali-0/) - [FATF releases detailed guidance to help practitioners recover criminal assets](https://www.fatf-gafi.org/en/publications/Methodsandtrends/asset-recovery-guidance-best-practices-2025.html) - [Asset Recovery](https://www.fatf-gafi.org/en/topics/asset-recovery.html) - [Assets Freeze | Security Council](https://main.un.org/securitycouncil/en/sanctions/1970/exemptions_measures/assets-freeze) - [Switzerland’s Frozen Russian Assets Continue to Climb | OCCRP](https://www.occrp.org/en/news/switzerlands-frozen-russian-assets-continue-to-climb) - [Foreign Illicit Assets Act (FIAA) of 18 December 2015](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2016-August-25-26/V1605154e.pdf) - [Timeline - Sanctions against terrorism - consilium.europa.eu](https://www.consilium.europa.eu/en/policies/sanctions-against-terrorism/timeline-sanctions-against-terrorism/) - [Sanctions - consilium.europa.eu - European Union](https://www.consilium.europa.eu/en/topics/sanctions/) - [Tunisia - Economy and Finance - European Commission](https://economy-finance.ec.europa.eu/international-economic-relations/candidate-and-neighbouring-countries/neighbouring-countries-eu/neighbourhood-countries/tunisia_en) - [ISIL/Da’esh and Al-Qaeda: Council renews sanctions regime by another year - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/10/27/isilda-esh-and-al-qaeda-council-renews-sanctions-regime-by-another-year/) - [Tunisia - Middle East, North Africa and the Gulf - European Commission](https://north-africa-middle-east-gulf.ec.europa.eu/countries/tunisia_en) - [The European Union continues to implement the Memorandum of Understanding with Tunisia with the disbursement of EUR 150 million in financial support](https://ec.europa.eu/commission/presscorner/detail/en/ip_24_1301) - [Tunisia - Enlargement and Eastern Neighbourhood - European Commission](https://enlargement.ec.europa.eu/european-neighbourhood-policy/countries-region/tunisia_en) - [The Sanctions (Amendment) (EU Exit) (No 2) Regulations 2019](https://www.legislation.gov.uk/uksi/2019/380/regulation/23/made) - [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [What are FATF mutual evaluations?](https://www.fatf-gafi.org/content/dam/fatf-gafi/methodology/Handout-5th-Round-Methodology.pdf.coredownload.pdf) - [2022 Procedures for the FATF AML/CFT/CPF Mutual Evaluations, Follow-Up and ICRG](https://www.fatf-gafi.org/en/publications/Mutualevaluations/5th-Round-Procedures.html) - [FATF Procedures for AML/CFT/CPF Mutual Evaluations, Follow-up and ICRG](https://www.fatf-gafi.org/content/dam/fatf-gafi/methodology/5th-Round-Procedures.pdf) - [The 2022 and 2013 Methodologies for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT/CPF Systems](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fatf-methodology.html) - [The Tunisia (Asset-Freezing) Regulations 2011](https://www.legislation.gov.uk/uksi/2011/888/made) - [Council Regulation (EU) No 101/2011 of 4 February 2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Tunisia](https://www.legislation.gov.uk/eur/2011/101/adopted) - [Council Implementing Regulation (EU) 2020/115 of 27 January 2020 implementing Regulation (EU) No 101/2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Tunisia](https://www.legislation.gov.uk/eur/2020/115/annex?view=plain) - [Council Implementing Regulation (EU) 2019/132 of 28 January 2019 implementing Regulation (EU) No 101/2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Tunisia](https://www.legislation.gov.uk/eur/2019/132/annexes) - [Council Implementing Regulation (EU) 2017/149 of 27 January 2017 implementing Regulation (EU) No 101/2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Tunisia](https://www.legislation.gov.uk/eur/2017/149/annexes?timeline=false&view=plain) - [Council Implementing Regulation (EU) 2016/111 of 28 January 2016 implementing Regulation (EU) No 101/2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Tunisia](https://www.legislation.gov.uk/eur/2016/111/annexes?timeline=false) - [The Tunisia (Restrictive Measures) (Overseas Territories) Order 2011](https://www.legislation.gov.uk/uksi/2011/748/made) - [list of persons and entities referred to in article 2](https://www.legislation.gov.uk/eur/2011/101/annex/2017-01-28/data.xht) - [FATF / MENAFATF](https://www.fatf-gafi.org/en/countries/detail/Tunisia.html) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [European Commission](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [HM Treasury](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [OCCRP](https://www.occrp.org/en/news/tunisia-jails-ex-prime-minister-and-billionaire-in-major-corruption-ruling) - [OCCRP](https://www.occrp.org/en/news/tunisia-jails-former-anti-corruption-chief-in-move-decried-as-judicial-harassment) - [US Treasury OFAC](https://ofac.treasury.gov/recent-actions/20251120) - [US Treasury OFAC](https://ofac.treasury.gov/recent-actions/20260521) - [EU Council / legislation.gov.uk](https://www.legislation.gov.uk/eur/2011/101/adopted) - [World Bank](https://assets.publishing.service.gov.uk/media/5a7cab6b40f0b6629523b104/Estimating_Informal_Trade_across_Tunisia_s_Land_Borders.pdf) - [UNODC](https://www.unodc.org/unodc/en/frontpage/2026/June/who--where--how-and-why-a-data-driven-look-behind-migrant-smuggling-around-the-world.html) - [MENAFATF](https://www.fatf-gafi.org/en/countries/global-network/middle-east-and-north-africa-financial-action-task-force--menafa.html) Coverage gaps fim-int-2026-07-07-G001: Independent primary-source re-verif… fim-int-2026-07-07-G001: Independent primary-source re-verification of the current EU implementing regulation renewing the Ben Ali-era asset freeze for 2025/2026 was not established this cycle. [resolved] fim-int-2026-07-07-G002: Direct English-language primary dis… fim-int-2026-07-07-G002: Direct English-language primary disclosures from CTAF or the Central Bank of Tunisia on current AML/CFT supervisory statistics or DNFBP sanctions were not retrievable this cycle. [resolved] fim-int-2026-07-07-G003: No Central Bank of Tunisia guidance… fim-int-2026-07-07-G003: No Central Bank of Tunisia guidance or legislative proposal on virtual assets was identified, leaving Tunisia's crypto-AML regulatory posture unconfirmed for future-cycle comparison. [resolved] fim-int-2026-07-07-G004: Independent corroboration of rights… fim-int-2026-07-07-G004: Independent corroboration of rights-group characterisations of the Al-Tabib prosecution as politically retaliatory, beyond the single OCCRP report, would strengthen the State Capture Filter (F1) judgment. [resolved] fim-int-2026-08-04-G001: No independent Tier 1-3 corroborati… fim-int-2026-08-04-G001: No independent Tier 1-3 corroboration located for the 2026 AI-driven payment-blocking mechanism targeting offshore crypto-gambling sites beyond a single Tier 4 aggregator (gamblingmaps.org). [resolved] fim-int-2026-08-04-G002: D3 (enabler jurisdictions) and D4 (… fim-int-2026-08-04-G002: D3 (enabler jurisdictions) and D4 (conflict finance) were not substantively evaluated for Tunisia this cycle given single-jurisdiction dispatch scope. [resolved] fim-int-2026-08-04-G003: Tier D jurisdictions (Cambodia, Lao… fim-int-2026-08-04-G003: Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not searched this cycle; tier_D_check fields logged null rather than a false no-signal claim. [resolved] fim-int-2026-08-04-G004: No primary BCT source (circular tex… fim-int-2026-08-04-G004: No primary BCT source (circular text) located for Circular No. 2026-132; reliance on two independent Tier 3 press accounts only. [resolved] fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): EU Council's own consolidated sanctions list was not queried directly this cycle; renewal/lapse status of Tunisia-linked asset-freeze measures past 31 Jan 2026 is unverified. [resolved] fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Tunisia-specific beneficial-ownership registry source was retrieved this cycle. [resolved] fim-int-2026-08-21-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): No Tunisia-specific enabler-jurisdiction or conflict-finance material was retrieved this cycle; Tier-D watch (KH/LA/MX/CO) was out of scope for this Tunisia-bound run. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Full primary text of BCT Circular 2026-10 was not retrieved directly from bct.gov.tn this cycle; existence and date confirmed on the regulator homepage but substantive provisions rely on secondary Tunisian press corroboration. [open] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No T1 primary gazette text was retrieved for the 29 January 2026 joint ministerial order placing casinos under the full AML/CFT regime; single T3 trade-press source only. [open] fim-int-2026-10-04-G003: Tier D jurisdiction sweep (Cambodia… fim-int-2026-10-04-G003: Tier D jurisdiction sweep (Cambodia, Laos, Mexico, Colombia) was not substantively refreshed this cycle within the research budget allocated to this TN-bound union pass. [open] fim-int-2026-10-04-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G004 ({'scheme': 'financial_integrity', 'value': 'D1'}): No material coverage for D1 (Sanctions), D2 (Beneficial Ownership), D3 (Enabler Jurisdictions), D4 (Conflict Finance) specific to Tunisia this cycle. [open] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No primary CMF/JORT text for the January 2026 risk-based AML/CFT/PF regulation was retrieved this cycle; secondary press reporting only. [open] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No primary JORT text for arrêté n°13/2026 on casino AML obligations was retrieved this cycle. [open] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): Only a T4 aggregator source was available for the Saadia Mosbah conviction; underlying Reuters reporting not independently retrieved. [open] FIM-GAP-001 (D2): Despite an estimated ~13.5 billion dinar (… FIM-GAP-001 (D2): Despite an estimated ~13.5 billion dinar ($4.6bn) looting estimate by President Saied in 2021 and a dedicated 'criminal reconciliation' commission established in 2022, recovery of Ben Ali-era assets remains negligible; the commission's own leadership was dismissed by Saied a year after founding for lack of results. FIM-GAP-002 (D3): Since the 2021 dissolution of the National… FIM-GAP-002 (D3): Since the 2021 dissolution of the National Anti-Corruption Authority and parliament, Tunisian authorities have increasingly deployed money-laundering and embezzlement charges against critics and former anti-corruption officials (e.g., Chawki Al-Tabib), which rights groups characterise as instrumentalisation of AML/CFT legal tools for political ends rather than genuine financial-integrity enforcement. FIM-GAP-003 (D3): Direct, English-language primary disclosur… FIM-GAP-003 (D3): Direct, English-language primary disclosures from CTAF (Tunisia's FIU) or the Central Bank of Tunisia on current AML/CFT supervisory statistics, enforcement penalties, or DNFBP sanctions were not retrievable in this research cycle; baseline relies on FATF/MENAFATF secondary hosting and NGO/press investigative reporting for enforcement specifics. FIM-GAP-004 (D5): No FATF-confirmed VASP registration regime… FIM-GAP-004 (D5): No FATF-confirmed VASP registration regime, Central Bank of Tunisia crypto-asset directive, or dedicated digital-asset AML framework for Tunisia was identified via available primary or Tier-2 sources in this research pass, in contrast to neighbouring Algeria's explicit 2025 crypto-activity criminalisation. ## Evidence #### Confidence-tiered claims BCT Circular 2026-10 (25 Sept 2026) repeals and replaces Circular 2018-16, overhauling payment-institution governance, KYC and cybersecurity rules, with a 3-month transition to compliance (~25 Dec 2026). [[Source 1]](#sec-sources) Probable · 1 source Payment institutions must form a board-level audit-and-risk committee and undergo an annual ANCS-certified cybersecurity audit. [[Source 1]](#sec-sources) Probable · 1 source Places licensed casinos under the full Organic Law 2015-26 AML/CFT regime -- risk assessment, compliance officer, staff training, independent audit, ten-year record retention, immediate CTAF suspicious-transaction reporting -- repealing a narrower 2018 casino-specific order. [[Source 1]](#sec-sources) Probable · 1 source AML/CFT regime governed by Organic Law No. 2015-26 (as amended by 2019-9); CTAF (housed at BCT) is the designated FIU; BCT Circular 2017-08 (as amended by 2025-17) operationalises sector controls including goAML filing and 10-year retention. Not on the FATF grey list; 2019 follow-up MER rated Compliant/Largely Compliant on 36 of 40 Recommendations. [[Source 1]](#sec-sources) Probable · 1 source off_list_unaffected_by_oct_2026_plenary [[Source 1]](#sec-sources) Probable · 1 source Remains in Finance and Budget Committee hearings with business organisations through at least June 2026; no floor vote reported. Would permit BCT-authorised crypto holding/exchange under declared thresholds if enacted. [[Source 1]](#sec-sources) Probable · 1 source CMF published a new risk-based AML/CFT/PF implementing regulation in JORT n°9 of 23 January 2026, replacing the formal-compliance model and extending its supervisory perimeter to crowdfunding platforms for the first time. [[Source 1]](#sec-sources) Probable · 1 source A tripartite order (arrêté n°13/2026, JORT 29-30 Jan 2026, 35 articles) replaced 2018 rules with a risk-based casino AML regime: mandatory risk audits, 10,000 TND enhanced-vigilance threshold, PEP escalation to general management, mandatory transaction blocking plus CTAF suspicious-transaction reporting where identity cannot be authenticated. [[Source 1]](#sec-sources) Probable · 1 source A late-January 2026 JORT order imposes immediate UN/national asset-freeze list screening on jewellery and precious-metals dealers for transactions at or above 30,000 TND, with instant transaction blocking for listed clients and 10-year record retention. [[Source 1]](#sec-sources) Uncertain · 1 source BCT circular n°2026-02 strengthens AML/CFT/proliferation-financing governance, transparency and operational compliance for manual foreign-exchange bureaux, aligning with FATF standards; licence withdrawal is threatened for breaches, while exchange-rate and currency ceilings are unchanged. [[Source 1]](#sec-sources) Probable · 1 source On 19 March 2026 a Tunisian court sentenced migrant-rights activist Saadia Mosbah to eight years' imprisonment on money-laundering and illicit-enrichment charges; human-rights observers have characterised the case as part of a wider crackdown. [[Source 1]](#sec-sources) Uncertain · 1 source A cross-party bill (40 deputies, deposited October 2025, under Finance Committee review through 2026) would replace the 1976 exchange-control law, permit resident foreign-currency accounts without prior BCT authorisation, and under Title V require residents to declare to the BCT foreign holdings and crypto-assets above a decree-set threshold, with mandatory repatriation of conversion proceeds. [[Source 1]](#sec-sources) Uncertain · 1 source