A brief reminder, first, of the history of Tunisia's relations with the Gafi . Taking up his new duties
Governor of the BCT, Mustapha Kamel Nabli had then requested the FSAP, an evaluation of the system
Tunisian financial institution by the World Bank. The latter systematically involves a visit from the Gafi ,
whose last visit to Tunisia dated back to 2007 and was only to be repeated in 2017. By mutual agreement, the
visit had been brought forward to 2012, when Tunisia was not prepared for it and was in the midst of
revision of the constitution. This is why the FATF visit only took place in 2014, and with a new
approach.
* The beginning of an affair that should not have taken place
The latter then had two parts. The first concerned the implementation of reforms, and the second
concerns the effectiveness of these reforms. In 2016, the Gafi report on Tunisia was released. 2017, the FATF notified
to Tunisia its classification on the black list . A scandal then broke out and the entire opposition, offended but
delighted to find a pretext to question the head of government. The government which had, for a
time, to find a scapegoat, especially since the government, which knew very well the
shortcomings of its financial system, could and should have taken its time and made the necessary reforms,
without risk of being classified. A ranking that had done a lot of harm to Tunisia and forced it to have
recourse to the European Union to help him get out of it, to the point of giving the impression to the EU ambassador,
become intermediate, that he could make rain or shine, especially in the file of the Aleca which him
was very close to his heart, and even allow himself to give advice to the government in place. He was recalled to
order and Tunisia, partially removed from the black list to the grey.
An action plan was then negotiated and validated by the Gafi , divided into five chapters and comprising more than 80
steps to take, to be completely whitened. On January 22, 2018, this plan was presented to the Board of
ministers. The idea was to complete it in one year. Skeptical, the Tunisian Minister of Foreign Affairs
is surprised before the CM. The team in charge of this dossier, however, went into overdrive "with a
unconditional support of the Head of Government and the Governor of the BCT as well", testifies for us a
team member. Implementation of the national business register, modification of the law of 2015.
Implementation also of professional guidelines for the professions concerned, such as jewelers,
lawyers and accountants, notaries, casinos and real estate agents, the stock market, and consulting
of the financial market, to name but a few, to always verify the origin and nature of the
financial transactions to prevent them from being the result of money laundering or
terrorist financing. Six CIMs (Interministerial Councils) were then devoted to this Gafi file .
On January 29, 2019, Tunisia presented its reform plan implementation report. On June 20, 2019, this
report is sent to FATF . In June 2019, the Gafi recognizes that Tunisia has finalized its action plan, which
fits with all his remarks and requests and decides to schedule an "On Site" visit, to ensure
itself, in Tunisia and in all the structures and institutions concerned, the proper execution of the plan
of reforms.
* A decisive and “dangerous” meeting, in the middle of the elections
This Gafi On-Site visit will take place in Tunisia on September 16 and 17, the day after the announcement of the
results of the 1st round of early presidential elections, with an interim head of government, a head of state
interim and number of ministers, concerned or immersed in the various electoral deadlines in
Tunisia. It is at the end of this On-Site visit, and in view of what the Gafi experts will notice during
their visits to almost all the institutions and different professions and even to the structures in charge
of the fight against terrorism and corruption, that the Gafi will decide whether or not Tunisia can, Cautious, the government decides, on the proposal of Fayçal Derbel according to our sources, to organize
a white site visit. As in a white bin, recourse has thus taken place, to evaluators
independent and experienced in the matter or who have made, on behalf of the FATF , this evaluation in
other countries.
Instructions were given to assess everything and comb through everything before the Gafi team arrived .
This was done on August 22 and 23, 2019. According to those who organized it, the white On-Site visit,
would have been generally satisfactory. It is assumed that by September 15, the necessary touch-ups
will have been made, to ensure the success of the actual Gafi examination. The visit taking place in full
elections, let's hope that these Gafi sleuths will not ask the ISIE, for example, if the candidates,
for the early presidential elections and for the legislative elections, have all declared their assets and if the ISIE and the Court
des Comptes, verified the origin of the funds which financed the campaigns of each candidate!
We also understand that, on the same occasion, the board of directors of Gafi in the MENA region should
meet in Tunisia. Alongside the Gafi evaluators , no less than 54 other members of MENA-Fatf
will come to Tunisia at the same time.
It will then be a question, not only of giving all the evidence of the implementation of the reforms which
condition the exit from the blacklist, but also to make a very good impression with the members of the FATF and
of Europe, which had initially somewhat contributed to the blacklisting of Tunisia.