Morocco is tightening its anti-money laundering measures. At the end of December 2025, Head of Government Aziz Akhannouch received Jouher Nefissi, President of the National Financial Intelligence Authority (ANRF), on the occasion of the presentation of the authority’s annual report. Beyond the protocol, the message is clear: Morocco is preparing for a decisive deadline. Effective November 2026, the Kingdom will be subject to a new evaluation cycle by the Financial Action Task Force (FATF), which leads global efforts to combat money laundering and terrorist financing.

A test of credibility

This time, the review will focus less on the Kingdom’s legal architecture and more on its implementation. Its ability to detect, analyze, report, and sanction. And its ability to cover the entire economy, from banks to the liberal professions, incorporating emerging risks related to cryptoassets.

The stakes go far beyond regulatory compliance. A return to the FATF gray list—which Morocco left in February 2023 after being added in 2021—would weigh heavily on international banking relations, increase the cost of country risk, and damage Morocco’s financial attractiveness. Conversely, a credible, enforced, and transparent system becomes a competitive advantage in an environment where borrowing costs are rising and compliance standards are tightening.

It is with this in mind that Morocco has been running its money laundering detection machine at full speed in recent years. According to the latest ANRF report, 8,103 suspicious activity reports were recorded at the end of 2024, representing an annual increase of 40.26%. At the same time, 84 cases were referred to the public prosecutor’s office, an increase of 18.31% over one year.

In substance, the majority of reports remain related to money laundering in the strict sense (8,076 cases), compared with only 27 for terrorist financing. However, a second reading of the judicial referrals reveals developments that are far more worrying. The most common underlying offenses are receiving stolen goods (27.38%), fraud (22.62%), and forgery and use of forged documents (20.24%). In addition to these « classic » cases, new practices are emerging: illegal sports betting, pyramid schemes, and above all, cryptocurrencies.

Cryptoassets, a new blind spot 

This is where the problem lies. For the first time, cryptoassets are explicitly identified as a vector for the money laundering mechanisms analyzed by the Moroccan authorities. The latest report from the Office of the Public Prosecutor also documents this shift: 17 cases involving the illegal use of digital currencies were recorded in 2024, including three cases related to terrorist financing.

In one of these cases, funds were collected through the purchase of USDT stablecoins on an international platform, before being transferred to an electronic wallet linked to a terrorist organization. While the number of cases is still limited, the nature of the circuits is striking: fast transactions, cross-border dimension, difficult traceability. Traditional financial surveillance tools are showing their limitations.

This is especially true given that the legal framework remains incomplete. In particular, the rules governing the freezing, seizure, and confiscation of cryptoassets are lacking, which weakens the criminal justice chain.

« There is a big gap between the technical reality and the legal text: judges do not have a unified view of these cases, and the issue is currently subject to personal interpretation, «  observes blockchain expert Badr Bellaj.

The problem is also operational. « The ease of conversion offered by the black market in Morocco makes it possible to convert cryptocurrencies into cash dirhams, which encourages these operations,«   he continues.  He warns: « Black market users may find themselves facing legal proceedings if they buy cryptocurrencies from individuals linked to terrorism, as blockchain ledgers record and archive all transactions forever. »

The late awakening of the liberal professions

Another notable development is the expansion of the circle of reporting entities. Unsurprisingly, with 60.89% of suspicious activity reports received by the ANRF in 2024, the banking sector remains the main source. Payment institutions come in second place (13.14%). But the highlight of the year lies elsewhere: reports from the non-financial sector jumped by 99.31% compared to 2023.

Lawyers, notaries, real estate agents, jewelers, accountants… long held back, these players are beginning to integrate, sometimes under duress, into the field of vigilance. However, this catch-up process remains gradual. Whereas banks have long since industrialized KYC (Know Your Customer, a process for verifying the identity of a company’s customers), screening sanction lists, and tracking flows, many liberal professions are still discovering the extent of their obligations.

« Banks are equipped; it’s part of their daily routine. But the majority of other operators continue to act as if it doesn’t concern them, » observes Hazim Sebbata, founder of the ScreenEdge compliance platform. The risk, however, is not abstract. Law 43-05 provides for financial penalties and even criminal prosecution in the event of a breach of due diligence obligations. « Professional associations and federations have raised awareness among their members, and the National Financial Intelligence Authority (ANRF) has issued numerous circulars… but as long as there are no visible convictions, these obligations remain abstract for many, » he adds.

Money laundering: penalties provided for by law

Law No. 43-05 provides for severe criminal penalties for money laundering. Perpetrators face two to five years in prison and a fine of 20,000 to 100,000 dirhams. Penalties may be doubled in the presence of aggravating circumstances, particularly when the acts are committed habitually, in a professional context, or by an organized gang.

Legal entities are also criminally liable when they are directly involved. They are liable to fines of between 500,000 and 3,000,000 dirhams, to which additional penalties may be added: prohibition from carrying out certain activities, closure of establishments, or dissolution in the most serious cases. The law requires the mandatory confiscation of property, funds, and instruments related to money laundering, even when they have been transformed or integrated into lawful assets.

Failures to comply with vigilance and reporting obligations—lack of internal controls, failure to maintain records, or non-cooperation—are subject to administrative penalties imposed by the supervisory authorities, which may include withdrawal of authorization. However, when these breaches are deliberate, repeated, or intended to facilitate money laundering, they may be considered as participation in the acts, engaging the criminal liability of the legal entity with all the penalties provided for by law.

Written in French by Safae Hadri; edited in English by AngloMedia Group.