AML/CFT obligations for bailiffs and auctioneers in Algeria (2026)

A debtor who pays, without argument, a large debt nobody had heard of; a bidder who wins a lot by bidding far above its value; a payment made by an unknown third party: bailiffs and auctioneers handle funds and goods within a framework that inspires trust. That framework is exactly what fraudsters try to exploit. The AML/CFT obligations for bailiffs and auctioneers aim to prevent legal procedures and public sales from being used to launder money.

Algeria's removal from the FATF grey list on 19 June 2026 shifts attention to effectiveness. At the next mutual evaluation, expected around 2029, non-financial professions will be assessed on their actual practices, not simply on the existence of laws. This guide sets out the applicable obligations, the red flags specific to these two professions and a method for building a proportionate framework.

1. Applicable laws and supervisory authority

Law No. 05-01 of 6 February 2005 on the prevention of and fight against money laundering and terrorist financing, amended by Law No. 23-01 of 7 February 2023 and then by Law No. 25-10 of 24 July 2025, distinguishes financial institutions from designated non-financial businesses and professions (DNFBPs). Bailiffs (huissiers de justice) and auctioneers (commissaires-priseurs) are expressly listed among these DNFBPs, alongside notaries, lawyers and accounting professionals.

Article 10 bis 3 of the law designates two separate authorities: the National Chamber of Bailiffs (Chambre nationale des huissiers de justice) for bailiffs and the National Chamber of Auctioneers (Chambre nationale des commissaires-priseurs) for auctioneers, notably in their auction activity. Executive Decree No. 23-430 of 29 November 2023 (Official Journal No. 76 of 30 November 2023) specifies how these authorities carry out their mission: regulations for the professions they supervise, a risk-based approach, off-site and on-site inspections, reporting of weaknesses, corrective measures and disciplinary sanctions, and coordination with the CTRF. Check with your chamber which texts and guidance it has issued.

Finally, Law No. 25-10 provides for a national and sectoral risk assessment, regularly updated and shared with obliged entities, on which your own analysis should build. For an overview, see our guide to AML/CFT compliance in Algeria and our analysis of Laws 05-01, 23-01 and 25-10.

2. Key obligations

Risk classification

Exposure depends on your activities. For a bailiff, risk is concentrated in operations where funds pass through the office, particularly debt recovery. For an auctioneer, it relates to auctions of valuable goods (vehicles, jewellery, works of art, equipment) and to the identity of successful bidders. Combine these activities with the profile of clients and payers, the nature of the goods, amounts and payment methods, then classify files as low, medium or high risk.

Customer due diligence and beneficial owners

Identify and verify your instructing clients, payers and, for sales, successful bidders. For a legal person, look for the natural person or persons who ultimately own or control it, by consulting the public register of beneficial owners kept by the CNRC (Article 8 of amended Law No. 05-01) and cross-checking it against the articles of association. Ask yourself whether the debt being recovered is real and where the funds paid come from. For politically exposed persons and high-risk situations, apply enhanced due diligence.

Suspicious transaction reporting to the CTRF

When you suspect that a transaction, even one merely attempted, involves funds of illicit origin or is linked to terrorist financing, you must report it to the Financial Intelligence Processing Unit (CTRF), attached to the Ministry of Finance. Confidentiality is absolute: the person concerned must never be told. Set up a short internal process (detection, analysis, decision, filing) and keep a written record of each analysis.

Asset freezing and targeted financial sanctions

Before handing funds to a creditor or knocking down a lot, check that the persons involved do not appear on sanctions lists, notably those of the United Nations Security Council and the national list. In the event of a confirmed match, no funds or goods may be made available and the competent authorities must be informed without delay.

Record keeping

Keep identification documents, debt instruments, proof of payment, auction records, screening evidence and your analysis notes. Organise them so they can be produced quickly during an inspection by your chamber or at the CTRF's request.

Training and internal organisation

Clerks are often the ones who collect payments or register bidders. They must know the red flags and whom to alert when in doubt. Appoint an AML/CFT lead, write a simple procedure and keep a training log.

A small office does not need to replicate a bank's organisation. A procedure of a few pages, a standard identification form, a tracking sheet for high-risk files and an annual review of the framework by the office holder are often enough to show the chamber that due diligence is real and managed.

3. Sector-specific typologies and red flags

For bailiffs

• a large, poorly documented debt, acknowledged and paid immediately by the debtor;
• payment made by a third party with no apparent link to the debtor;
• a request to pay the funds into an account other than the creditor's, or abroad;
• repeated recoveries between the same parties, suggesting fabricated debts;
• split or cash payments without a coherent explanation.

For auctioneers

• a bidder who refuses to identify himself or acts for someone he will not name;
• bidding clearly disconnected from the value of the item;
• an item bought back by a person linked to its former owner;
• payment by several third parties or with funds of unexplained origin;
• quick resale of goods bought at auction, notably works of art, jewellery or vehicles;
• cancellation of a sale followed by a request for a refund to another account.

4. Common mistakes

• Assuming the judicial framework is enough: a court decision or enforceable title does not rule out a debt having been fabricated upstream.
• Identifying the instructing client but not the payer: the risk often lies with whoever pays the funds.
• Settling for the bidder's name: without verified identification and a search for the real buyer, the public sale becomes an entry point.
• Not documenting: an unwritten analysis has no value during an inspection.
• Never reporting: a complete absence of reports in an activity that handles third-party funds raises questions for the supervisor.

5. How Hodemia Consulting supports bailiffs and auctioneers

Hodemia Consulting helps offices build a framework suited to their size and defensible before their chamber:

• Compliance diagnostic (2 to 4 weeks): review of collection, recovery and auction procedures, testing on a sample of files, prioritised action plan. See our article on the compliance diagnostic;
• AML/CFT programme set-up and KYC remediation: risk assessment, identification forms for payers and bidders, sanctions screening, CTRF reporting process;
• Compliance & Ethics training (1 day) for office holders and their clerks, based on debt recovery and auction cases. Explore our training courses.

To discuss your office's situation, contact us.

Conclusion: preserving the trust attached to the procedure

The AML/CFT obligations for bailiffs and auctioneers protect what gives these professions their value: the trust attached to an enforcement act or a public sale. Under the supervision of the National Chamber of Bailiffs and the National Chamber of Auctioneers, every office must know its risks, identify instructing clients, payers and bidders, screen against sanctions lists and report suspicions to the CTRF. A short procedure, trained clerks and written analyses are enough to approach inspections and the upcoming evaluation with confidence.

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.