Palestine

Art. 21(1) of Decree-Law 39/2022 requires transaction records to be kept for at least ten years after the transaction is completed; account files and CDD records follow a similar ten-year rule from the end of the business relationship. Art. 30 of Instructions No. 4 of 2022 states the same ten-year minimum.

Art. 22 of Decree-Law 39/2022 requires financial institutions and DNFBPs to run AML/CFT programmes that include appointing a compliance officer at management level, who follows up implementation and reports suspicious transactions to the Unit; the programme also covers screening, training and independent audit. Arts. 31-32 of Instructions No. 4 of 2022 repeat the compliance officer duty for financial institutions.

Art. 10(1) of Decree-Law 39/2022 bars anonymous or fictitious-name accounts and requires ongoing CDD; Art. 11 sets the CDD triggers. Instructions No. 4 of 2022 (Art. 4) apply CDD at onboarding, for occasional transactions of USD 15,000 or more, on suspicion of ML/TF, and for wire and electronic transfers whatever their value; Art. 9 requires identifying anyone holding 25% or more of a legal person.

Art. 25 of Decree-Law 39/2022 requires financial institutions and DNFBPs to report any suspicious transaction or activity to the Unit immediately, including attempted transactions and regardless of value. Art. 32 of Instructions No. 4 of 2022 has the compliance officer report promptly to the Unit, whether or not the transaction was carried out.