The U.S. Department of State (DoS), in its report "International Narcotics Control Strategy Report 2007," states that the draft anti-money laundering law in Morocco "adheres to international standards." The International Monetary Fund (IMF), in a 2007 report, notes that Morocco has adopted and published this anti-money laundering draft legislation, and that it will allow the country to establish a Financial Intelligence Unit (FIU). According to the 2007 U.S. DoS report, in June 2003, Morocco enacted a counterterrorism bill which allows for information gathering on suspected terrorists, the freezing of funds used for terrorist activities, and the confiscation of such funds. Moreover, per the 2007 U.S. DoS report, the Central Bank of Morocco issued Memorandum No. 36, which requires banks and other financial institutions to have internal controls such as reporting suspicious transactions, retaining these reports and instituting Know Your Customer (KYC) requirements. However, the anti-money laundering legislation in Morocco is fairly new, so it is still too early to measure its effectiveness. Other than the 2007 U.S. DoS report, there is very little information publicly available as to Morocco's compliance with the Financial Action Task Force's Forty plus Nine recommendations and special recommendations.

General Overview

The U.S. Department of State (DoS), in its report "International Narcotics Control Strategy Report 2007," states that the draft anti-money laundering law in Morocco "adheres to international standards." In a 2007 report, the International Monetary Fund (IMF) notes that Morocco has adopted and published this draft anti-money laundering legislation, and that it will allow the country to establish a Financial Intelligence Unit (FIU). Morocco adopted a comprehensive counterterrorism bill in June 2003 which allows for the freezing and confiscation of suspected terrorists' funds and brought Morocco into compliance with requirements of United Nations Security Council Resolution (UNSCR) 1373 for the criminalization of the financing of terrorism.

According to the 2007 U.S. DoS report, unregulated money exchanges are very common in Morocco and that there is much opposition from this sector towards the new money laundering legislation. According to this report, the Central Bank of Morocco (Bank Al-Maghrib, or BAM), has taken measures to control money laundering in the financial sector. For example, the BAM issued Memorandum No. 36 which requires banks and other financial institutions introduce such internal controls as the reporting of suspicious transactions, the retention of these reports, and the application of Know Your Customer (KYC) requirements.

Morocco is party to the 1988 United Nations (UN) Drug Convention, the UN International Convention for the Suppression of Financing of Terrorism, and the UN Convention against Transnational Organized Crime. According to the 2007 U.S. DoS report, Morocco "has ratified or acceded to 11 of the 12 UN and international conventions and treaties related to counterterrorism."

The Principles

1. Legal Systems and Related Institutional Measures

II

There is insufficient information publicly available regarding Morocco's compliance with this Principle. Per the U.S. DoS's 2007 report on Morocco, the country was in the process of adopting anti-money laundering (AML) legislation which is, to a large extent, based on the recommendations made by the Financial Action Task Force (FATF). A subsequent report by the IMF in 2007 notes that this law has been adopted and published. According to the 2007 U.S. DoS report, the new legislation will require the reporting of suspicious financial transactions by all responsible parties, public and private, who, in the exercise of their work, carry out or advise on the movement of funds possibly related to drug trafficking, human trafficking, arms trafficking, corruption, terrorism, tax evasion, or forgery.

The 2007 U.S. DoS report further states that "in June 2003, Morocco adopted a comprehensive counterterrorism bill. The bill provided the legal basis for lifting bank secrecy to obtain information on suspected terrorists, allowed suspect accounts to be frozen, and permitted the prosecution of terrorist finance-related crimes." According to the same report, the 2003 counterterrorism bill also provides for confiscation rules on suspected terrorists funds, and brought Morocco into compliance with UNSCR 1373 requirements for the criminalization of the financing of terrorism. Furthermore, the bill allows Moroccan authorities to freeze terrorist funds as and if requested by foreign government agencies.

2. Preventive Measures - Financial Institutions

II

There is insufficient information publicly available regarding Morocco's compliance with this Principle. The 2007 U.S. DoS report notes that the BAM has taken measures to control money laundering in the financial sector. For example, the BAM issued Memorandum No. 36, which requires banks and other financial institutions to establish internal controls such as reporting suspicious transactions, retaining these reports, and instituting Know Your Customer (KYC) requirements. However, according to the 2007 U.S. DoS report, unregulated money exchanges are very common in Morocco, which has given rise to much opposition from this sector towards the new money laundering legislation.

3. Preventive Measures - Designated non-Financial Business and Professions

II

There is insufficient information publicly available regarding Morocco's compliance with this principle.

4. Legal Person and Arrangements & Non-Profit Organizations

II

There is insufficient information publicly available regarding Morocco's compliance with this principle.

5. National and International Co-operation

II

There is insufficient information publicly available regarding Morocco's compliance with this principle. Morocco is party to the 1988 United Nations (UN) Drug Convention, the UN International Convention for the Suppression of Financing of Terrorism, and the UN Convention against Transnational Organized Crime. According to the 2007 U.S. DoS report, Morocco "has ratified or acceded to 11 of the 12 UN and international conventions and treaties related to counterterrorism."