Insight · Morocco · AML/CFT compliance
Morocco approaches the end of 2026 facing a milestone that businesses would be unwise to underestimate. The third round of mutual evaluations of its anti-money laundering and counter-terrorist financing framework (AML/CFT, referred to in French as LBC/FT or LCB-FT), conducted by the Middle East and North Africa Financial Action Task Force (MENAFATF), was officially launched in November 2025, and the evaluation of the Kingdom has been announced for the end of 2026. Having been removed from the FATF “grey list” in February 2023, the country must now demonstrate that its legal framework delivers tangible results.
This focus on effectiveness is not confined to the authorities. It extends to banks, to regulated professions and, in turn, to the companies and investors that use their services.
This article first sets out the Moroccan framework as consolidated since 2021 (I), then the developments that reinforce its significance in 2026 (II), before offering practical recommendations for investors and in-house legal teams (III).
I. An AML/CFT framework consolidated since 2021
1. Law No. 43-05 as amended by Law No. 12-18
The cornerstone of the framework remains Law No. 43-05 on combating money laundering, enacted in 2007. It was substantially overhauled by Law No. 12-18, promulgated by Dahir (royal decree) No. 1-21-56 of 8 June 2021 and published in the official translation edition of Official Bulletin (Bulletin officiel) No. 7018 of 2 September 2021.
The reform, aligned with the FATF Recommendations, notably broadened the range of predicate offences to money laundering, increased the fines applicable to natural persons, strengthened the due diligence and internal control obligations of obliged entities, and provided for disciplinary sanctions imposed by the supervisory authorities. Implementing texts published the same year organised the National Financial Intelligence Authority (Autorité nationale du renseignement financier, ANRF), which succeeded the Financial Intelligence Processing Unit (Unité de traitement du renseignement financier), established the committee responsible for targeted financial sanctions, and designated the courts of Casablanca, Fez and Marrakesh, alongside that of Rabat, to hear money laundering cases.
2. The public register of beneficial owners
Adopted pursuant to Article 13-3 of Law No. 43-05, Decree No. 2-21-708 of 8 September 2021 established a public register of the beneficial owners of companies incorporated in Morocco and of legal arrangements, kept by the finance department (département des finances). Published in Arabic in Official Bulletin No. 7024 of 23 September 2021, and subsequently in official translation in Official Bulletin No. 7144 of 17 November 2022, the decree comprises 17 articles covering the keeping of the register, filing obligations, conditions of access and penalties. The register became operational in July 2023.
3. Removal from the grey list
Placed under increased monitoring following the mutual evaluation conducted in 2018, the report of which was adopted in April 2019, Morocco agreed an action plan with the FATF on 25 February 2021. Following an on-site visit from 16 to 18 January 2023, the FATF plenary meeting held in Paris from 20 to 24 February 2023 decided unanimously to remove the Kingdom from the grey list. This was not a first: the country had previously been on the list from February 2010 to October 2013. Experience shows that removal from the list consolidates a position without guaranteeing it.
II. 2026: from the statute book to proof of effectiveness
1. An evaluation focused on results
The third round of mutual evaluations was launched in Rabat in November 2025, at a meeting chaired by the Head of Government in the presence of the President of MENAFATF. According to the Moroccan Capital Markets Authority (Autorité marocaine du marché des capitaux, AMMC), this round will focus on the effectiveness of the national framework and on the roll-out of the risk-based approach across the various segments of the financial sector.
Supervisors have mobilised accordingly. The Insurance and Social Welfare Supervisory Authority (Autorité de contrôle des assurances et de la prévoyance sociale, ACAPS) convened insurers in February 2026 with the evaluation in mind, and in April 2026 the AMMC held a seminar for brokerage firms, asset management companies and financial investment advisers, attended by the ANRF and the national committee responsible for United Nations sanctions. Rabat also hosted the 42nd MENAFATF plenary meeting in May 2026.
For businesses, the consequence is direct. An effectiveness evaluation measures what obliged entities actually do: the quality of customer identification, the relevance of suspicious transaction reports and the reliability of beneficial ownership information. Banks and accounting and legal professionals therefore have every reason to document their due diligence, and they are turning to their clients for more complete and better-substantiated information.
III. Practical implications for investors and legal departments
1. Getting to grips with the beneficial ownership filing obligation
The obligation is broad. It covers all Moroccan companies, whatever their legal form, branches of foreign companies, and foreign legal arrangements (trusts, fiducies) that carry out financial or real estate transactions or provide services in Morocco, or that have an administrator resident in Morocco.
Beneficial owners include, in particular, natural persons who ultimately hold, directly or indirectly, at least 25% of the share capital or voting rights, as well as those who exercise control by other means. The threshold is therefore not the end of the analysis: a shareholders’ agreement, veto rights or a power of appointment may identify a person who does not reach 25%.
Deadlines are short. The filing is in principle due within one month of registration with the trade register (registre du commerce) and within one month of any change to the information. For a legal arrangement, the period runs from its first transaction in Morocco or from the appointment of a resident administrator. The information and supporting documents are retained for ten years after deregistration.
Penalties are dissuasive: failure to comply with the obligations under the decree carries a fine of MAD 5,000 to 50,000, and the provision of false, inaccurate or outdated information a fine of MAD 10,000 to 100,000.
2. The practitioner’s view: five points to watch
- Mergers and acquisitions frequently change beneficial ownership. Changes in beneficial ownership, in particular with banks, should therefore be anticipated.
- Multi-jurisdictional ownership chains require a look-through analysis. Intermediate holding companies, funds and foreign vehicles must be traced up to the natural persons, with the corresponding supporting documents.
- Control is not determined by share capital alone. Special rights provided for in the articles of association or in shareholders’ agreements must be examined against the control criterion.
- Consistency between filings is essential. The information provided to the register, to the bank as part of its due diligence and, where applicable, to the Foreign Exchange Office (Office des changes) must match. A single discrepancy is enough to delay an account opening or a repatriation of funds.
- Foreign legal arrangements are caught from their first transaction in Morocco.
3. Anticipating due diligence rather than reacting to it
As the evaluation approaches, credit institutions have every reason to document their know-your-customer (KYC) due diligence more thoroughly. For investors, preparing and maintaining up-to-date governance files in advance (ownership chart, identity of the beneficial owners, source of funds, evidence of filing with the register) shortens the time needed to open accounts, secure financing or reach closing.
Conclusion
Since 2021, Morocco has had a comprehensive AML/CFT framework, recognised by its removal from the grey list in 2023. The MENAFATF evaluation expected at the end of 2026 shifts the focus to effectiveness, which inevitably raises the expectations that banks and regulated professions place on their clients. This momentum makes beneficial ownership transparency an integral part of preparing any transaction in Morocco.
This analysis is based on the texts in force at the date of publication and is provided for information purposes only. It does not constitute personalised legal advice: as each situation must be assessed on its own facts, we recommend that you consult your usual adviser or the UGGC Africa team in relation to any specific transaction.
The findings of the mutual evaluation, expected after the assessors’ visit, could lead to further regulatory adjustments. Regular monitoring remains essential.
Key takeaways
What is AML/CFT compliance in Morocco?
It is the body of obligations arising from Law No. 43-05, as amended by Law No. 12-18 in 2021: customer due diligence, suspicious transaction reporting to the ANRF and beneficial ownership transparency, monitored by the supervisory authorities.
What is the key development in 2026?
- The MENAFATF mutual evaluation of Morocco, announced for the end of 2026 and focused on effectiveness.
Who must file beneficial ownership information?
All Moroccan companies, branches of foreign companies and foreign legal arrangements with activity in Morocco or a resident administrator, within one month of registration, of a change or of the first transaction.
What is the practical takeaway for a legal department?
Build register updates into M&A transactions, analyse control beyond the 25% threshold and ensure that the information provided to the register, to banks and to the Foreign Exchange Office is consistent.
A transaction to structure in Morocco? Contact the UGGC Africa team