Experts from the Financial Action Task Force (FATF) have begun a field visit to Syria to review the implementation of its action plan on combating money laundering and terrorist financing. It is the first inspection of its kind since the country was placed on the “grey list” in 2010, at a time when the Syrian government is trying to prove it is making the necessary efforts to have its name removed from the list.
The FATF is an intergovernmental body founded in 1989 to set international standards for combating money laundering and terrorist financing and protecting the global financial system. It places on the “grey list” countries with strategic deficiencies in their financial and regulatory systems that have committed to an action plan to address these gaps under the group’s monitoring.
For years, the FATF has said that Syria completed the agreed action plan at the technical level, but the security situation prevented an on-site visit to verify that the required reforms had actually begun to be implemented and could be sustained.
But what does the arrival of FATF experts in Damascus mean? What will they look for inside Syrian institutions? And could exiting the grey list be another step on Syria’s road back to the global financial system?
A File Pending Since 2014
Syria’s relationship with the grey list dates to February 2010, when the Assad regime’s government made a high-level political commitment to work with the FATF and the Middle East and North Africa Financial Action Task Force (MENAFATF) to address strategic deficiencies in its anti-money laundering and counter-terrorist financing system.
In June 2014, the FATF concluded that Syria had substantially addressed its action plan at the technical level, including criminalizing terrorist financing and establishing procedures for freezing terrorist assets. But the closing of the file stalled at a key stage, as the group was unable to carry out an on-site visit to verify that the reforms had actually begun and were sustainable.
The FATF’s latest statement on jurisdictions under increased monitoring, in June 2026, repeats the same position, stating that Syria has completed the agreed action plan and that the group will conduct the on-site visit as soon as possible.
The FATF explains that a country seeking to exit monitoring must have addressed all or most of the items in its action plan, before an on-site visit is organized to confirm that the required legal, regulatory and operational reforms are being implemented and that there is political commitment and institutional capacity to sustain them.
Under its internal rules, if the visit’s outcome is positive, the group may decide to remove the country from public monitoring at one of its subsequent plenary meetings.
Two Tracks Before Syria
The FATF experts’ visit comes as the country prepares for a broader milestone: a new round of “mutual evaluation” of its financial system. On July 23, a high-level MENAFATF delegation visited Damascus, headed by the group’s president Hamed Saif al-Zaabi and including its executive secretary Suleiman al-Jebreen and the two co-chairs of the mutual evaluation working group.
The delegation met the governor of the Central Bank of Syria, Safwat Raslan, and the ministers of interior, justice, economy and industry, finance, endowments, social affairs and labor, local administration and communications, as well as representatives of the financial intelligence unit, the judiciary, law enforcement agencies and supervisory authorities.
MENAFATF said the visit aimed to support Syria’s readiness for the mutual evaluation process and to strengthen the effectiveness of its national system for combating money laundering, terrorist financing and proliferation financing.
Syria thus has two connected but distinct tracks before it. The first concerns its old FATF file and exiting the grey list. The second is the new mutual evaluation, which will subject the Syrian financial system to a broader review under the current international methodology.
A Test Beyond Laws
Under the FATF’s evaluation methodology, the tests are not only about whether a country has an anti-money laundering law or a financial intelligence unit. The assessment has two parts: “technical compliance”, which examines whether the legislation, institutions and procedures consistent with the group’s recommendations exist, and “effectiveness”, which looks at the results this system actually achieves.
During the on-site visit for a mutual evaluation, the country is asked to provide information and evidence of the effectiveness of its system in the areas set out by the FATF methodology, and the experts conduct interviews and visits to verify whether the existing systems actually work.
Turkey, whose new evaluation was published in 2026, offers Syria a close example of the difference between the two. Turkey reached a very high level of technical compliance, with only one of the 40 recommendations rated “partially compliant” and none rated “non-compliant”.
Even so, the evaluation attaches great importance to the practical results achieved by institutions, from investigations and prosecutions to the confiscation of the proceeds of crime and the supervision of the sectors most exposed to risk.
According to financial expert Khalil Maalouli, the most important thing Syria can take from the Turkish experience is that “the international standard will not settle for legislation, but will focus on the number of effective investigations and the volume of assets actually confiscated”.
Maalouli considers readiness for 2027 an integrated sovereign and economic project linking the judiciary, banks and regulators, and says that learning from neighboring countries’ experiences saves time and ensures preparing a file backed by numbers and results. But the question facing Syrian institutions seems different here: it is not only which laws have been issued, but what their application has produced.
From the Financial Report to the Courtroom
One of the main tests for monitoring the required action plan is the system’s ability to turn financial information into judicial outcomes. The chain usually begins with banks and financial institutions detecting suspicious transactions and reporting them to the financial intelligence unit, which analyzes them and refers them where necessary to law enforcement, and from there to the prosecution and the judiciary.
A rise in the number of reports or investigations alone is not enough to measure effectiveness, if cases stall before reaching judicial outcomes or asset recovery.
Maalouli describes one of the problems highlighted by the Turkish experience as “judicial bottlenecking”. He sees the lesson for Syria as “turning financial intelligence into final court rulings by training the judiciary and setting up fast tracks for financial crimes”.
Accordingly, Syrian figures will matter as much as legal texts: the number of suspicious transaction reports, the investigations resulting from them, the cases referred to the judiciary, the final convictions, and the volume of funds and assets frozen or confiscated.
$104 Million Under Seizure
The FATF experts’ arrival in the Syrian capital coincides with an announcement by the Central Authority for Control and Inspection of a major financial measure in a separate case concerning oil sector contracts.
On September 29, the head of the authority, Amer al-Ali, announced a precautionary seizure of the funds of contracting companies under investigation, worth about $104 million, in connection with a review of the implementation of certain terms of contracts in the oil sector.
Ali stressed that the amount does not represent funds proven to have been embezzled, and that the seizure is a precautionary measure aimed at protecting the state’s rights until the investigations conclude. He also said the investigation is not an accusation against the Syrian Petroleum Company or its employees, and that determining responsibility and any referral to the judiciary depend on the final results of the investigation.
As of the writing of this report, there is no documented information linking this measure to the FATF experts’ visit, and freezing assets in a case under investigation does not in itself mean that anti-money laundering standards have been met.
But the precautionary seizure offers a practical example of the kind of results that matter in measuring a state’s ability to trace funds, investigate financial crimes and take protective measures, and then, when violations are proven, to reach judicial proceedings and final confiscation under the law. The matter does not end with announcing a freeze. It extends to the institutions’ ability to establish the basis for the measure, complete the investigation, determine responsibilities and reach a measurable judicial outcome.
Who Is Behind the Companies?
The issue of the “ultimate beneficial owner” is another test for Syria’s financial and corporate sector. The term refers to the natural person who ultimately owns or controls a company, not just the name registered in the official documents.
In a case like Syria’s, this matters even more, with economic activity expanding, companies being established again, and new investors and capital arriving, because official registries alone do not prevent the use of front companies or multi-layered ownership structures to hide the ultimate owner of funds.
Financial expert Khalil Maalouli believes that Turkey’s experience shows that having digital company registries is not enough without verification mechanisms that ensure there are no shell companies. He calls for building a central, dynamic registry of beneficial owners that allows information to be verified.
The effect of this file is not limited to the FATF’s evaluation, as banks and financial institutions need to know who stands behind companies and clients in order to assess risks before entering financial relationships with them.
Where Are the Risks in Syria?
In this evaluation, Syria faces a complex financial and economic environment shaped over years of sanctions and banking isolation, the wide use of cash, informal transfers, smuggling and cross-border movement of funds. For this reason, the “national risk assessment” (NRA) is one of the key tools of the process.
The goal here is not to treat all financial activities as equally risky, but to identify the sectors, crimes and channels most exposed to money laundering and terrorist financing, and then direct supervision and investigation resources toward them.
The Syrian authorities had presented to the MENAFATF delegation, during its July visit, their efforts to develop the national framework and coordination among institutions, as well as the national strategy for combating money laundering and terrorist financing, which according to the group relies on risk management and on strengthening integration among the relevant bodies.
Financial expert Khalil Maalouli says that the lesson for Syria is “to direct field supervision and enforcement efforts straight toward the priorities set by the national risk assessment”, rather than focusing on less serious financial crimes and violations.
This places issues such as smuggling, informal transfers, cross-border cash movement, shell companies, terrorist financing and virtual assets among the questions on which Syria needs to determine the size of its risks and build a proportionate response.
Digital Currencies Are Also Under Test
Virtual assets and cryptocurrencies are emerging as one of the growing files in the global anti-money laundering and counter-terrorist financing system.
Recommendation 15, on new technologies, remains the only recommendation rated “partially compliant” in the latest published technical compliance rating for Turkey.
The FATF calls on countries to assess the risks of virtual assets and their service providers, and to set up licensing or registration, supervision and enforcement regimes rather than leaving the activity outside the regulatory system.
Maalouli considers that the lesson for Syria is “to avoid banning financial technologies without regulating them”, and to adopt a risk-based supervisory framework that closes gaps that could be used to move illicit funds.
This becomes more important as digital assets become one of the means that can be used to transfer money across borders outside the traditional banking system.
What Does Exiting the Grey List Mean?
A country’s presence on the grey list does not mean that the FATF calls for halting financial dealings with it. The group states explicitly that placing a country under “increased monitoring” means it is working with the country to address strategic deficiencies, and that the FATF standards do not call for cutting off entire categories of customers or applying a policy of comprehensive financial isolation, but for adopting a risk-based approach.
However, the listing is among the information that countries and institutions should consider when analyzing risk, which is why Syria’s attempt to close its file matters beyond the legal dimension.
At a time when the Syrian government is working to rebuild its economic relations, attract investors and reconnect Syrian banks with foreign financial institutions, the level of money laundering and terrorist financing risk is one of the elements that enter foreign financial institutions’ decisions.
Exiting the grey list does not mean an automatic return of correspondent banking relationships or a flow of capital, as banks make their decisions according to a broader set of risk, compliance and commercial viability factors. But it removes one of the most prominent international risk signals tied to the Syrian anti-money laundering and counter-terrorist financing system, and moves the country to the stage of regular monitoring, at a time when it is seeking to rebuild trust in its financial system.
From Laws to Numbers
In sum, more than a decade after the FATF considered that Syria had completed its action plan at the technical level, the current test may differ from those Damascus faced before. The question is no longer only whether Syria has laws criminalizing money laundering and terrorist financing, or institutions specialized in pursuing them, but whether it can prove that these institutions work and that their results are measurable and verifiable.
How many suspicious transactions have been detected? How many became investigations? How many cases reached the courts? How much money was frozen and confiscated? Can the authorities identify the beneficial owners of companies and trace money moving across borders, through informal channels and through digital assets?
Financial expert Khalil Maalouli describes preparing for this stage as “an integrated sovereign and economic project linking the judiciary, banks and regulators”. This means the importance of the FATF experts’ visit does not end with removing Syria from the grey list. The bigger test will be the ability of Syrian institutions to move from building laws and structures to actually producing investigations, rulings, confiscations and financial supervision that can be verified internationally, at a time when the country is trying to rebuild bridges with the global financial system.
This article was translated and edited by The Syrian Observer. The Syrian Observer has not verified the content of this story. Responsibility for the information and views set out in this article lies entirely with the author.
