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05RABAT2549 2005-12-21 16:35:00 UNCLASSIFIED Embassy Rabat
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1. Morocco is not a regional financial center and the
extent of the money laundering problem in Morocco is not
known. Morocco remains an important producer and exporter of
cannabis, with estimated revenues of $13 billion annually,
according to a joint study released in May 2005 by the
United Nations Office on Drugs and Crime (UNODC) and
Morocco's Agency for the Promotion and the Economic and
Social Development of the Northern Prefectures and Provinces
of the Kingdom. Some of these proceeds may be laundered in
Morocco and abroad. There is no indication that
international or domestic terrorist networks have engaged in
widespread use of the narcotics trade to finance terrorist
organizations and operations in Morocco. Press reports
indicate, however, that the Spanish investigation into the
March 11, 2004 terrorist bombings in Madrid found that the
alleged Moroccan national perpetrators of the attacks
financed the purchase of the explosives used in the blasts
through modest sales of cannabis resin in Spain.

2. Morocco has a significant informal economic sector,
including remittances from abroad and cash-based
transactions. There are unverified reports of trade-based
money laundering, including bulk cash smuggling, under-and
over-invoicing, and the purchase of smuggled goods. Banking
officials have indicated that the country's system of
unregulated money exchanges provides opportunities for
potential launderers. Morocco has a free trade zone in
Tangier, with customs exemptions for goods manufactured in
the zone for export abroad. There have been no reports of
trade-based money laundering schemes or terrorist financing
activities using the Tangier free zone or the zone's
offshore banks, which are regulated by an interagency
commission chaired by the Ministry of Finance.

3. There were no reported arrests or prosecutions for money
laundering or terrorist financing in Morocco in 2005.
Morocco has a relatively effective system for disseminating
U.S. Government (USG) and United Nations Security Council
Resolution (UNSCR) freeze lists to the financial sector and
law enforcement. Morocco has provided detailed and timely
reports requested by the UNSC 1267 Committee. A handful of
small value accounts have been administratively frozen based
on U.S. Executive Order 13224 freeze lists.

4. The Moroccan financial sector is modeled after the
French system and consists of 16 banks, five government-
owned specialized financial institutions, approximately 30
credit agencies, and 12 leasing companies. The monetary
authorities in Morocco are the Ministry of Finance and the
Central Bank, Bank Al Maghrib (CBM), which monitors and
regulates the banking system. A separate Foreign Exchange
Office regulates international transactions. Morocco has
used administrative instruments and procedures to freeze
suspect accounts.

5. However, CBM issued Memorandum No. 36 in December 2003,
in advance of passage of still pending anti-money laundering
legislation, instructing banks and other financial
institutions to conduct their own internal
analysis/investigations. It also mandates "know your
customer" procedures, reporting of suspicious transQtions
and the retention of suspicious activity reports. Morocco
also has in effect: legislation prohibiting anonymous bank
accounts; foreign currency controls that require
declarations to be filed when transporting currency across
the border, although not strictly enforced; and internal
bank controls designed to counter money laundering and other
illegal/suspicious activities.

6. In June 2003, Morocco implemented a comprehensive
counterterrorism bill that provided the legal basis for the
lifting of bank secrecy to obtain information on suspected
terrorists, freeze suspect accounts and prosecute terrorist
finance-related crimes. The law also provides for the
seizing and confiscation of terrorist assets and for
international cooperation with regard to foreign requests
for freezing assets of a suspected terrorist entity. This
law brought Morocco into compliance with UNSCR 1373
requirements for the criminalization of the financing of

7. As of December 2005, Morocco has enacted two
banking/financial sector reform bills that will further
strengthen Morocco's anti-money laundering system. A
specific anti-money laundering (AML) bill is in the process
of being presented to Parliament for passage. The AML
reportedly includes, among other provisions, a suspicious
transaction reporting scheme and the creation of a Financial
Intelligence Unit (FIU). All three bills are based on the
Financial Action Task Force (FATF) Forty Recommendations and
Egmont Group guidelines and will help bring Morocco's
financial sector in line with international standards.

8. Together, the three bills will enhance the supervisory
and enforcement authority of the Central Bank and outline
investigative and prosecutorial procedures. The Central
Bank has already mandated "know your customer" requirements
and the reporting of suspicious transactions by financial
institutions. All money transfer activities that take place
outside the realm of the official Moroccan banking system-as
set by the CBM guidelines-are deemed illegal. The bills also
expand the CBM's regulatory authority over non-banking
financial transactions. Other significant provisions
include: the lifting of bank secrecy during investigations,
as well as legal liability protection of bankers and
investigators for cooperation during investigations.

9. Morocco is a party to the UN International Convention
for the Suppression of Financing of Terrorism, and the UN
Convention against Transnational Organized Crime. Morocco is
also a party to the UN International Convention against
Illicit Traffic in Narcotic Drugs and Psychotropic
Substances (the Vienna Convention); in fact, Morocco has
ratified or acceded to all UN and international conventions
and treaties related to counterterrorism.

10. The Government of Morocco would strengthen its AML
capacity by moving expeditiously to pass the anti-money
laundering bill. Upon passage of the AML legislation, and as
part of itQnti-money laundering program, Morocco's AML
efforts would benefit from the establishment of a
centralized Financial Intelligence Unit (FIU) that will
receive and analyze suspicious transaction reports and
disseminate them to appropriate law enforcement agencies for