CMF Releases Expanded Practical Guide to Strengthen AML/CFT/CPF Compliance

The Financial Market Council (CMF) has recently published an expanded practical guide aimed at reinforcing the prevention of money laundering, terrorist financing, and the proliferation of weapons. Targeted at stockbrokers and portfolio management companies, this document outlines the specific due diligence and control measures expected from these financial professionals.

Beyond Transaction Monitoring: A Holistic Approach

In the face of risks associated with the circulation of illicit capital, prevention cannot be limited to simple transaction monitoring. It also requires knowing your customers (KYC), tracing the origin of funds, and detecting unusual operations. With this in mind, the CMF intends to provide professionals with a concrete framework to better apply current legal and regulatory requirements.

According to the official communiqué, this guide is based primarily on:

Organic Law No. 2015-26 of August 7, 2015, as amended and supplemented by Organic Law No. 2019-9 of January 23, 2019.
Legislation related to the financial market.
The CMF Regulation of January 23, 2026.

Risk-Based Approach and Enhanced Due Diligence

At the heart of this initiative is a risk-based approach. Specifically, the concerned institutions are called upon to identify and assess vulnerabilities related to:

Their clients.
The operations carried out.
The products and services offered.
Distribution channels.
Relevant geographic zones.

This risk mapping must evolve in response to changing risks, particularly when launching new products or services.

However, this vigilance must translate into daily practices. The guide emphasizes the verification of the identity of clients and beneficial owners—the natural persons who ultimately own or control an entity. When risk is deemed high, controls must be strengthened, including:

Collecting additional information.
Verifying the origin of funds and assets.

Governance and Internal Controls

The CMF also places strong emphasis on internal governance. The board of directors, general management, compliance function, and internal audit must operate with a clear division of responsibilities. In this regard, the compliance function must have the necessary independence and resources to fulfill its missions effectively.

Detecting Suspicious Operations and Sanctions Compliance

Detecting suspicious operations is another essential component of the framework. Unusual transactions must be examined in light of the client’s profile and activity. If the collected elements give rise to suspicion, a report may be required, strictly respecting confidentiality and without informing the client or any third party.

The guide also recalls obligations regarding targeted financial sanctions, including:

Verifying applicable lists.
Freezing relevant assets in accordance with current legislation.

Continuous Improvement and Cooperation

Finally, the regulator highlights that the effectiveness of these measures also relies on:

Continuous staff training.
Traceability of operations.
Independent internal audits.

The CMF calls on the concerned institutions to review their procedures and cooperate with competent authorities, including the Tunisian Financial Analysis Commission (CTAF).