Risk Mapping, Internal Governance and Criminal Liability: What Changes in 2026 as Tunisia’s AML/CFT Regime Accelerates for the Leadership Bodies.
Just over a year after the tightening of internal banking controls, Tunisia closes a dense regulatory cycle on the fight against money laundering and the financing of terrorism (AML/CFT). The Financial Market Council, the Central Bank of Tunisia, the National Register of Companies: three regulators converge toward the same level of mutation, that of the personal responsibility of the directors. Compliance, long the preserve of dedicated services, becomes a governance issue directly enforceable against the governing bodies, under penalty of civil, administrative and now criminal sanctions.
An Accelerating Regulatory Arsenal
Published in the Official Journal on January 23, 2026, the new regulation of the Financial Market Council concerning the implementation measures in AML/CFT and the fight against the proliferation of weapons marks a break with the formal compliance approach that had prevailed until then.
The text, which builds on substantial amendments introduced by Organic Law No. 2019-9 of January 23, 2019 to Organic Law No. 2015-26 of August 7, 2015, broadens its scope to securities-based crowdfunding and requires more than 120 regulated participants in the financial market to adopt a risk-based approach as the central reference for preventive measures.
Concretely, each obliged entity must now develop and submit to the CMF a periodic risk mapping, designate a permanent contact point with the National Commission for the Fight Against Terrorism, implement an institutional risk management strategy and establish harmonized criteria of professional competence for the compliance officers.
The Central Bank of Tunisia has followed a similar trajectory. In fact, its Circular No. 2025-17 of December 22, 2025, entered into force without a transitional phase, requires banks to carry out a formal and documented risk assessment, updated at a minimum every three years, and explicitly integrates for the first time the risk of financing the proliferation of weapons of mass destruction.
One month later, Circular No. 2026-02 extended this tightening to exchange offices, under penalty of permanent withdrawal of the license in case of non-compliance.
Towards Individual Accountability
