Technical compliance and operational effectiveness in Morocco's anti-money laundering and counter-terrorist financing framework

Morocco achieved rapid AML-CFT legislative progress between 2019 and 2024, exiting the Financial Action Task Force (FATF) grey list and reaching 39 Compliant or Largely Compliant technical ratings, which raises the question of whether these reforms translated into operational effectiveness. Drawing on Reuter and Edwin (2004) Two-Pillar model and data from the Moroccan National Financial Intelligence Authority (ANRF) annual reports, prosecutorial statistics and Middle East and North Africa Financial Action Task Force (MENAFATF) evaluations, the study uses lagged and cumulative ratios to distinguish processing delays from persistent gaps and identifies three different situations within the same system. The detection stage expanded rapidly, with almost five times more suspicious transaction reports, but transmissions to prosecutors did not keep pace and their relative share kept falling even when time lags were taken into account. Judicial outputs, by contrast, caught up once the specialized tribunals became operational, while asset management still lacks a dedicated institution. The paper introduces the concept of transitional effectiveness to describe this combination of closing delays and persistent gaps, and argues that evaluation methodologies would benefit from indicators able to capture the period between legislative reform and operational maturity.