AML/CFT obligations for chartered accountants and statutory auditors in Algeria (2026)

Every year, a chartered accountant sees the entries, invoices and bank statements of their clients. A statutory auditor examines a company's flows, contracts and structures from the inside. This privileged vantage point makes accounting professionals both sentinels and targets: sentinels because they can spot an inconsistent transaction, targets because certified financial statements or well-kept books can lend a veneer of respectability to funds of dubious origin. The AML/CFT obligations for chartered accountants and statutory auditors are designed precisely to ensure that this expertise is never put at the service of money laundering.

The context changed in 2026. Algeria left the FATF grey list on 19 June, and the next mutual evaluation, expected around 2029, will focus on the real effectiveness of AML/CFT frameworks, including among non-financial professions. A regulation specific to the accounting professions was also published in the Official Journal in May 2026. For firms, the question is no longer whether they are concerned, but whether they can demonstrate, with evidence, that they meet their obligations.

1. Applicable texts and supervisory authority

The foundation remains Law No. 05-01 of 6 February 2005, substantially overhauled by Law No. 23-01 of 7 February 2023 (OJ No. 08 of 2023). Its Article 4 distinguishes financial institutions from designated non-financial businesses and professions (DNFBPs), which expressly include chartered accountants and statutory auditors. All are "obliged entities", required to apply preventive measures, including suspicious transaction reporting. For a detailed reading of the reform, see our article on Law 23-01 on money laundering in Algeria.

Article 10 bis 3 of the law designates the supervisory authorities: the National Accounting Council (Conseil national de la comptabilité) for chartered accountants and the National Chamber of Statutory Auditors (Chambre nationale des commissaires aux comptes) for statutory auditors. Their duties are framed by Executive Decree No. 23-430 of 29 November 2023.

On that basis, an order of the Minister of Finance dated 14 April 2026, published in Official Journal No. 38 of 25 May 2026, puts in place a regulation on preventing and combating money laundering, terrorist financing and proliferation financing for chartered accountants, statutory auditors and certified accountants. This regulation designates the National Accounting Council as the regulatory, control and/or supervisory authority for its application. Firms must also take into account Law No. 25-10 of 24 July 2025, which provides for a national and sectoral risk assessment shared with obliged entities and tightens the ban on crypto-assets.

2. Key obligations

Risk classification

The 2026 regulation requires a risk identification and assessment mechanism proportionate to the size and nature of the firm. It covers clients, services, technologies and countries, as well as external sources, including the FATF and the CTRF. The assessment must be carried out at least once a year, and immediately after any significant event. It must be documented, kept up to date and justifiable to the National Accounting Council. Any new service, channel or technology must be assessed before launch, as must non-face-to-face relationships.

Customer due diligence and beneficial owners

The regulation requires every engagement to be formalised in a written agreement countersigned by both parties: the engagement letter thus becomes the first document in the KYC file. The firm identifies and verifies its client before accepting the engagement, understands the purpose of the relationship and identifies the natural persons who ultimately own or control the company. The public register of beneficial owners held by the CNRC, provided for in Article 8 of the law, is a useful source, but it does not replace a critical review of group charts. Politically exposed persons and clients linked to high-risk countries call for enhanced due diligence.

Suspicious transaction reports to the CTRF

When they suspect that a transaction is linked to money laundering, terrorist financing or proliferation financing, professionals report it to the CTRF, Algeria's financial intelligence unit within the Ministry of Finance, including mere attempts. The report is confidential: the client must never be informed. The form of reports is framed by the CTRF, notably by its Instruction No. 02 of 4 December 2023. A useful report is reasoned: it explains, with supporting documents, why the transaction is inconsistent with the client's profile.

Asset freezing and targeted financial sanctions

The firm screens its clients and their beneficial owners against sanctions lists, notably those of the United Nations Security Council and the national list, at onboarding and whenever the lists are updated. A positive match is handled without delay, with the competent authorities informed. For a small firm, what matters is knowing who checks, when, and how the check is recorded.

Record keeping

Identification documents, engagement agreements, risk analyses and transaction records must be kept so that a relationship or transaction can be reconstructed and promptly produced to the supervisor or the CTRF. Audit working papers, already subject to professional archiving rules, must be aligned with these requirements.

Training and internal organisation

The regulation requires written, up-to-date programmes, including policies, formal procedures and internal control, proportionate to the risks and size of the business. In practice: a partner or senior compliance lead, an engagement acceptance and continuance procedure, an internal alert channel and regular training for all staff, partners included. Our guide to the compliance function in Algeria explains how to position this role.

3. Sector-specific typologies and red flags

Accounting professionals have a unique vantage point. These signals should prompt a deeper review:

• transactions with no apparent economic or commercial rationale, or of unusual complexity given the business;
• large shareholder current-account contributions or capital increases with undocumented sources of funds;
• amounts, particularly in cash, unrelated to the client's turnover or usual flows;
• fictitious or circular invoicing between related companies, services that cannot be evidenced;
• loans or advances between group companies without a contract, interest or repayment schedule;
• frequent changes of shareholders, managers or registered office, or obvious front persons;
• pressure to certify accounts quickly, or refusal to produce certain supporting documents;
• flows with high-risk countries, or any trace of virtual-asset transactions, which are banned in Algeria.

4. Common mistakes

In accounting and audit firms, we see recurring gaps:

• Treating AML/CFT as a banking issue: many firms assume the client's bank already does the work, whereas the obligation rests on each obliged entity.
• Accepting an engagement without a KYC file: the engagement letter is signed, but beneficial owners are neither identified nor documented.
• A generic risk assessment: a template document, never tailored to the actual client base or updated annually.
• Confusing the audit opinion with AML/CFT vigilance: an anomaly can be immaterial to the accounts and still be a suspicion to report.
• No reporting channel: staff do not know whom to tell about a doubt, and the information is lost.
• One-off sanctions screening: checked at onboarding, never repeated when the lists are updated.

5. How Hodemia Consulting supports chartered accountants and statutory auditors

Fayçal Lounes spent nearly twenty years in major international audit firms, at EY and then as Director of Regulatory & Compliance Services at KPMG Middle East. He knows a firm's constraints from the inside: seasonality, staff turnover, the commercial relationship with the client. We offer:

• Compliance diagnostic (2 to 4 weeks): measuring the gap between your practices and the 2026 regulation, on a sample of client files. Discover our approach to the compliance diagnostic.
• AML/CFT programme implementation and KYC remediation: firm risk assessment, engagement acceptance procedure, file templates, suspicious transaction reporting channel, sanctions screening.
• Compliance & Ethics training (1 day): case studies drawn from accounting and audit engagements, for partners and teams.
• Leadership & Compliance seminar (2 days): for partners who want to make compliance a source of trust.

See our training programmes or contact us to discuss your needs.

Conclusion: compliance as part of professional quality

With the regulation put in place by the order of 14 April 2026, the AML/CFT obligations for chartered accountants and statutory auditors are now detailed in a sector-specific text, under the supervision of the National Accounting Council. An annual risk assessment, a written agreement for every engagement, identification of beneficial owners, reporting to the CTRF and sanctions screening: these requirements are a natural extension of the professional scepticism that gives the profession its value. Firms that build them into their quality procedures now will be ready for inspections and for the FATF evaluation expected around 2029. For an overview of the framework, read our guide to AML/CFT compliance in Algeria.

Fayçal Lounes

Founder of Hodemia Consulting

Nearly 20 years of international experience in regulatory compliance, risk and governance (EY in Luxembourg, San Francisco and London; Director, Regulatory & Compliance Services at KPMG Middle East). Certified coach, trainer and academic.