Combating Money Laundering and Terrorism Financing Commission, Decision No. 19 of 2019, the system for monitoring banking and financial operations in banking and financial institutions operating in the Syrian Arab Republic and the Syrian free zones for the purpose of combating money laundering and terrorism financing; with a later decision amending specified requirements in some of its articles
Source ID
SRC-209
Citation
Combating Money Laundering and Terrorism Financing Commission, Decision No. 19 of 2019, the system for monitoring banking and financial operations in banking and financial institutions operating in the Syrian Arab Republic and the Syrian free zones for the purpose of combating money laundering and terrorism financing; with a later decision amending specified requirements in some of its articles
URL or path
research/SRC-209_decision_possibly_19_of_2019.pdf; amendment at research/SRC-209_decision_amending_19_of_2019.pdf; page images at research/SRC-209_decision_possibly_19_of_2019_pages/
Type
Subordinate instrument, Syrian regulator, Arabic
Hierarchy tier
1
Published
2019-03-13
Accessed
2026-08-17
Snapshot
Retrieved 17 August 2026 from cmlc.gov.sy, HTTP 200, 66 pages, 1,342,426 bytes. A text layer exists but its Arabic is corrupted by a custom font encoding, so it was READ FROM RENDERED PAGE IMAGES at 165 dpi; the amendment is a two-page image-only scan and is NOT read
Claims
CH6 the identification floor that the 2025 circulars altered; who may be identified and therefore paid
Status
READ_IN_PART
Version history
The register keeps changing after the book is fixed in print. Each entry below was added to this row in the order shown.
READ 17 August 2026 AT PAGES 26 AND 27 ONLY, being Article 30 and the opening of Article 31; THE OTHER 64 PAGES ARE UNREAD AND ARE READING OWED. THIS IS THE INSTRUMENT ALL THREE CIRCULARS AT SRC-208 REST ON, and it was retrieved because they rest on it. IDENTITY AND AUTHORITY: headed 'قرار رقم 19', made by the Management Committee of the Commission on the basis of Legislative Decree 33 of 2005 and its amendments, the executive instructions issued by decision 1311 of 28 April 2014 as amended, and the Committee's meeting of 13 March 2019. Its scope expressly includes THE SYRIAN FREE ZONES as well as the Republic. ARTICLE 31 IS HEADED 'بيانات ووثائق التعرف والتحقق من هوية العميل', data and documents for identifying and verifying the client's identity, and RUNS FROM PAGE 26 TO PAGE 37, eleven pages. ITS OPENING IS THE POINT: the institution shall obtain the listed data and documents on every client according to the nature of each client, 'باعتبارها المتطلبات الدنيا', AS MINIMUM REQUIREMENTS, and 'وللمؤسسة المصرفية والمالية أن تطلب أي بيانات ووثائق إضافية أو أخرى ترى ضرورة الحصول عليها', the institution may require any additional or other data and documents it considers necessary. THE CONSEQUENCE THE CHAPTER MUST NOT MISS: a supervisory circular adding a document to this list RAISES WHAT IS ACCEPTABLE AT THE FLOOR; IT DOES NOT COMPEL ANY BANK TO TREAT THAT DOCUMENT AS SUFFICIENT, because Article 31 expressly preserves the institution's power to demand more. Permission at the supervisor is not obligation at the counter, which is this chapter's subject in one provision. ARTICLE 31(أ)(3) أولاً IS THE LIST THE 2025 CIRCULARS ADDED TO. For Syrians and those treated as such, defined to include Palestinians registered with the General Authority for Palestinian Arab Refugees, ONE of: (a) the personal identity card, or the temporary residence card issued by the Ministry of Interior for registered Palestinians; (b) a valid passport or the travel document for registered Palestinians, or a duly certified copy for those not present on Syrian territory; (c) the developed military identity bearing the national number, or the ordinary military identity with a unit registration statement bearing it. SO THE PRE-2025 FLOOR FOR IDENTIFYING A SYRIAN WAS A DOCUMENT ISSUED BY THE SYRIAN STATE, and the February and March 2025 circulars added Salvation Government documents to it. ARTICLE 31(أ)(1) AND (2) list the minimum DATA, and they include 'رقم ومكان سجله المدني', the number and place of the client's CIVIL REGISTRY entry, which is why the March 2025 circular's civil registry extract matters. Thresholds appear at 31(أ)(1) for occasional operations, stated in Syrian pounds and differing between financial and banking institutions; THE FIGURES ARE READ BUT ARE NOT RECORDED HERE, because a threshold in nominal Syrian pounds set in 2019 needs a currency and date treatment the chapter has not yet given it, and SRC-044's redenomination bears on it. ARTICLE 30 ALSO READ: it requires the institution to satisfy itself that the documents relate to the client as a person with material existence and to the nature of their activity, to capture document data automatically by barcode where present, to retain all identification data electronically, to record how and when each due-diligence step was completed, and to update client identity data at least once every three years and more often for high-risk clients. THE AMENDMENT AT research/SRC-209_decision_amending_19_of_2019.pdf, listed as amending specified requirements within some articles of Decision 19, IS HELD AND NOT READ, and it may change any of the above. NOTHING FROM THIS ROW MAY BE PRINTED AS THE CURRENT RULE UNTIL THAT AMENDMENT IS READ.
THE AMENDMENT IS NOW READ IN FULL, both pages, from rendered images, 17 August 2026, AND THE BAR STATED ABOVE IS LIFTED. It is DECISION No. (8/ل إ هـ) of the Commission's Management Committee, on its deliberation of 28 MARCH 2023, made under Legislative Decree 33 of 2005 as amended, decision 1311 of 28 April 2014 as amended, and Decision 19 of 2019. Signed at Damascus on 28 March 2023 by Dr Mohammad Issam Hazima as chairman and Majd Hamad as secretary. Article 1 repeals decision (1/ل إ هـ) of 14 February 2023. Article 3 requires immediate communication to those bound to implement it. ARTICLE 2 REPLACES MONEY AMOUNTS THROUGHOUT DECISION 19, AND THESE SUPERSEDE THE FIGURES ON PAGE 27 THAT THIS ROW DELIBERATELY DID NOT RECORD. In Article 23(1-ي): one million Syrian pounds or foreign-currency equivalent. In Article 31 at items (1-أ), fourthly of item 3 of paragraph أ, (8-ب), (4-د), (4-هـ), (4-و), (4-ز) and (ح), and in Article 33: THREE MILLION SYRIAN POUNDS OR EQUIVALENT FOR FINANCIAL INSTITUTIONS AND ONE HUNDRED MILLION FOR BANKING INSTITUTIONS. In Article 31(6-ج): three million for external transfers requiring the approval of the licensing government body or the self-regulating body to which a non-profit is subject; fifty million as the ceiling above which the Commission must be informed; one hundred million as the ceiling of the occasional operation or linked operations permitted. In Article 31(7-ج): three million and one hundred million respectively. In Article 41(ب) and Article 48(أ): one hundred million. In Article 48(هـ): two hundred and fifty million. In Article 48(و): three million for the annual insurance premium, five hundred thousand for the retirement pension, twenty-five million for death compensation. In Article 49(ب)(و-1): three million. AND HERE IS THE EXHIBIT, WHICH IS THIS BOOK'S OWN SUBJECT ARRIVING IN A SUPERVISORY INSTRUMENT. EVERY ONE OF THOSE THRESHOLDS IS A NOMINAL SYRIAN POUND FIGURE FIXED ON 28 MARCH 2023. SRC-044 records the Central Bank's announcement of a two-zero redenomination in December 2025. A threshold denominated in a unit that has since been redenominated does not mean in 2026 what it meant when it was written, and a customer due diligence trigger that has drifted is a trigger that no longer triggers. SCOPE OF THE ABSENCE, STATED AS THE RULE REQUIRES: the Commission's decisions section at cmlc.gov.sy, as listed on 17 August 2026, carries FOUR DISTINCT FILES, being this amendment, Decision 19 itself, a decision amending decision 11 of 27 January 2011 on cash amounts permitted across borders, and one concerning insurance and electronic archiving. NONE OF THE FOUR IS A LATER RESTATEMENT OF THESE THRESHOLDS. THAT IS A STATEMENT ABOUT ONE SECTION OF ONE SITE ON ONE DAY AND NOT ABOUT SYRIAN LAW: a later instrument may exist elsewhere, and the chapter must say so before printing that the figures still stand.