Morocco Regulates Offshore Holding Companies

Morocco is strengthening its financial transparency and economic defenses with new regulations targeting offshore holding companies. The Exchange Office has published Circular No. 2026/2, outlining vigilance and internal control duties for these entities, a move designed to bolster the nation's financial integrity.

This initiative is a direct application of anti-money laundering laws, specifically Law No. 43-05 as amended, and free zone regulations under Law No. 58-90. The circular aims to establish a comprehensive vigilance system tailored to the size and nature of each company's activities. Key requirements include robust customer due diligence, verification of the actual beneficiaries of transactions, and scrutiny of fund sources.

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a legal novelty that closes loopholes for this category of companies in the fight against money laundering.

A source from the Exchange Office explained that this legal update addresses gaps in combating money laundering within this specific corporate sector. The directive, signed by Minister of Economy and Finance Nadia Fettah, became effective on July 23, 2026. It falls under the Exchange Office's supervisory role over offshore holding companies.

The circular employs a risk-based approach, compelling companies to implement strict procedures for identifying clients and ultimate beneficial owners. This involves verifying the origin and destination of funds, regularly updating client data, and applying enhanced due diligence for politically exposed persons or those linked to high-risk countries. Companies must also establish detailed information cards for each client before establishing business relationships or executing urgent transactions. The definition of a beneficial owner includes any individual directly or indirectly holding 25% or more of capital or voting rights, or exercising effective control over management.

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establishing an integrated vigilance system that aligns with the size and nature of companies' activities, particularly concerning customer identification and beneficial owners, and verifying the sources of funds.