Morocco tightens compliance rules for offshore holding companies

Tuesday 11 - 18:00

By: Sahili Aya

Morocco tightens compliance rules for offshore holding companies

Morocco is strengthening oversight of offshore holding companies as part of broader efforts to improve transparency and reinforce safeguards against money laundering and illicit financial flows.

The Office des Changes announced Monday the publication of Circular No. 2/2026, setting out new vigilance and internal monitoring requirements for offshore holding companies operating under Morocco’s offshore financial framework.

The measure is based on Morocco’s anti-money laundering legislation and the legal framework governing offshore financial centres.

A risk-based approach to compliance

The new circular introduces a risk-based framework designed to ensure that compliance procedures are proportionate to the size, activities and risk profile of each offshore holding company.

Among the key requirements is the identification and verification of customers and beneficial owners.

Companies will also be expected to establish the origin and destination of funds, giving regulators greater visibility into financial flows passing through offshore structures.

The approach is intended to move beyond uniform compliance requirements by requiring companies to adapt their monitoring systems to the specific risks associated with their activities.

Closer monitoring of suspicious transactions

The circular also strengthens requirements for the ongoing monitoring of financial operations.

Particular attention must be paid to transactions considered unusual, complex or high-risk, according to the Office des Changes.

Such enhanced scrutiny is designed to help companies identify potentially problematic transactions at an early stage and ensure that appropriate compliance procedures are activated when risks emerge.

The framework places greater responsibility on offshore holding companies themselves to maintain effective internal controls rather than relying solely on external supervision.

Compliance officers become a key requirement

A central provision of the new framework is the appointment of a compliance officer within each offshore holding company.

The designated official will be responsible for overseeing the implementation of the company’s vigilance system and monitoring its effectiveness.

This requirement gives compliance a clearly identified point of responsibility within each organisation and is intended to strengthen internal governance.

Reinforcing Morocco’s offshore financial framework

The Office des Changes said the circular forms part of its supervisory and control mandate over offshore holding companies.

The regulator said the new rules are designed to strengthen compliance, transparency and the security of offshore activities while maintaining a proportionate approach based on risk.

The move also places Morocco’s offshore financial structures under closer scrutiny at a time when international financial standards increasingly focus on beneficial ownership, transaction monitoring and the prevention of illicit financial flows.

Circular No. 2/2026 is available through the institutional website of the Office des Changes.

The new framework therefore marks a further step toward tighter governance of Morocco’s offshore holding sector, with companies expected to strengthen their internal vigilance systems and assume greater responsibility for identifying and managing financial risks.