Morocco’s Exchange Office has published a Circular, introducing new vigilance and internal monitoring obligations for offshore holding companies operating within the kingdom’s offshore financial center framework.
Economy and Finance Minister Nadia Fettah signed the circular on July 23, and it took effect immediately, applying under the law on combating money laundering and the law governing offshore financial centers. The Exchange Office said the rules form part of its supervisory role and follow a risk-based approach that accounts for each company’s size, activity and risk profile.
Companies must identify and know their clients and beneficial owners, verify the origin and destination of funds, keep client records current, and monitor transactions according to risk level, while also screening clients and transactions against international sanctions lists and those issued by Morocco’s national commission responsible for applying UN Security Council sanctions.
Each offshore holding company must appoint a dedicated compliance officer responsible for managing the vigilance system, examining unusual or complex transactions, overseeing higher-risk relationships, and maintaining contact with the National Financial Intelligence Authority. Companies must also conduct periodic risk assessments covering transactions, client profiles, geographic exposure and new technologies, with stricter checks required for politically exposed persons and clients from high-risk jurisdictions.
Any transaction raising suspicion of money laundering or terrorist financing must be reported to the National Financial Intelligence Authority without delay, and records related to transactions and vigilance measures must be kept for 10 years. The circular provides for disciplinary or financial sanctions when obligations are breached, while shielding companies and staff from liability for good-faith suspicious activity reports.
