In twenty years, Algeria's anti-money laundering law has changed more than in the whole period before. For the head of a bank, an insurer or a notary's office, Algeria anti-money laundering law is no longer a single text you read once: it is a stack of reforms, regulations and instructions that continuously redefine what is expected of you. Procedures written five years ago are, in many cases, already out of date.
This article traces how the framework has evolved, from Law 05-01 to the 2023 and 2025 reforms, then translates these changes into concrete obligations and an action plan. It complements our reference guide on AML/CFT compliance in Algeria, which presents the framework as a whole.
Law No. 05-01 of 6 February 2005 on the prevention of and fight against money laundering and terrorist financing is still the backbone of the framework today. It has never been repealed: each reform has amended and supplemented it. It laid down the principles every obliged entity knows: customer identification, record keeping, and suspicious transaction reporting to the CTRF, the financial intelligence unit attached to the Ministry of Finance.
Ordinance No. 12-02 of 2012 broadened the predicate offences for money laundering, clarified that terrorist financing is an offence whether or not an attack takes place, and strengthened the duty to establish the identity of the beneficial owner when a customer appears to be acting on behalf of someone else. It also confirmed the distinction between financial institutions and designated non-financial businesses and professions (DNFBPs), which still shapes the scope of obliged entities.
This foundation relied largely on a rules-based logic: apply a list of due diligence measures, whatever the customer's profile. The FATF international standards, revised in 2012, now required a risk-based approach, greater transparency on beneficial ownership and coverage of proliferation financing. The following reforms set out to close that gap.
Law 23-01 of 7 February 2023 was adopted as Algeria prepared for its mutual evaluation carried out under MENAFATF, the FATF-style regional body for the MENA region. The stakes were twofold: align the text with international standards and show the political will to apply them. Algeria's grey-listing by the FATF on 25 October 2024 showed that the effectiveness agenda remained open despite this reform.
For many institutions, Law 23-01 marked the shift from documentary compliance to demonstrable compliance. Having a procedure is no longer enough: you must prove that it fits your risks and is actually applied. In our engagements in Europe and the Gulf, we have seen the same shift after every evaluation cycle: supervisors move their attention from whether frameworks exist to what they deliver.
Law 25-10 of 24 July 2025, published in Official Journal No. 48 of 2025, requires a national and sectoral assessment of money laundering, terrorist financing and proliferation financing risks, regularly updated and shared with obliged entities. This is a structural change: your own risk mapping must now be consistent with that assessment. An institution that ignored a risk identified at national or sectoral level would find it very hard to justify that choice to its supervisor.
Law 25-10 tightens the ban on crypto-assets: issuing, buying, selling, holding, using them for payment or investment, promoting them and operating exchange platforms are prohibited and punishable by criminal penalties. For banks, this concretely means monitoring scenarios able to detect flows linked to foreign platforms or informal intermediaries.
According to the Algerian press, the reform also tightens oversight of associations, which must justify the origin of their funds, and supervision of professions considered high-risk, such as real estate agents or jewellery dealers. The same Official Journal publishes Law No. 25-11 on personal data protection, with which your KYC processing must remain compatible.
Laws set the principles; implementing texts specify how they apply. This is where most of the obligations of obliged entities play out day to day.
| Text | Issuer | Main subject |
|---|---|---|
| Regulation No. 24-03 of 24 July 2024 | Bank of Algeria | Prevention of money laundering, terrorist financing and proliferation financing |
| Instruction No. 02 of 4 December 2023 | CTRF | Instruction from the unit to obliged entities |
| Instruction No. 04-2026 of 30 April 2026 | Bank of Algeria | Unified KYC procedure for banks, financial institutions and Algérie Poste |
Instruction No. 04-2026 is probably the most operational text. It provides for customer risk scoring on four parameters, consultation of the CNRC beneficial ownership register, senior management approval before onboarding a politically exposed person, and cases where a relationship must be refused. Above all, it sets a file review frequency: at least annually for high risk, every three years for medium risk and every five years for low risk.
For banks and financial institutions, these requirements sit within Regulation No. 11-08 of 28 November 2011 on internal control. The AML/CFT framework must therefore be built into governance, ongoing controls and internal audit, rather than treated as an isolated function.
Before launching these workstreams, it is best to know exactly where you stand. A compliance assessment lets you compare your practices with the requirements of Law 23-01, Law 25-10 and Instruction 04-2026, then prioritise actions. Our experience shows that a targeted plan, sponsored by management and tracked quarterly, delivers more than a full overhaul run without clear trade-offs.
From the 2005 Algeria anti-money laundering law to the 2023 and 2025 reforms, the logic has changed profoundly: from a list of due diligence measures to a risk-based approach, informed by a shared national assessment and equipped with precise implementing texts. Leaving the FATF grey list on 19 June 2026 is not the end of the road: the next mutual evaluation, expected around 2029, will judge how effective frameworks really are. Obliged entities that have aligned their procedures, remediated their files and trained their teams will approach that deadline with confidence, and reassure their foreign partners along the way.