Faced with an unprecedented surge in suspicious transaction reports between 2020 and 2025, Tunisia’s Financial Analysis Committee (CTAF) underwent a profound structural transformation.
Over the course of three successive leadership terms, the institution evolved from traditional cash-flow monitoring into a sophisticated cybercrime-tracking body.
Analysis
Behind the closed doors of the CTAF, Tunisia’s financial intelligence unit established within the Central Bank of Tunisia and chaired by its governor, a flood of data has upended regulators’ assumptions. In just six years, the number of suspicious transaction reports submitted by financial institutions tripled, reaching a historic peak of 1,334 reports in 2025, compared with only 446 in 2020.
This is highlighted in the latest Strategic Analysis Bulletin entitled “Terrorism Financing: Lessons Drawn from Cases Submitted During the 2020–2025 Period.”
The signal is strong. Yet the explosion in figures does not tell the full story. Reading between the lines reveals that beyond criticism, misunderstandings and political exploitation attempts, the CTAF has been handling highly sensitive cases, developing valuable expertise and serving as a protective bulwark that deserves both public and political support.
Beyond the charts, the data illustrates a 180-degree shift, technological, structural and managerial, in Tunisia’s financial governance.
Across three leadership mandates and under three successive secretaries-general, the CTAF changed scale entirely. What was once a conventional agency focused on cash transactions and traditional bank transfers has become a highly technical intelligence unit now confronting international electronic wallets and increasingly agile transnational criminal networks.
In essence, it has become a team of elite financial investigators. Yet it remains an institution often squeezed between political tensions, troubling institutional populism and difficult transparency demands.
To understand this evolution, one must examine three distinct periods, each deeply shaped by the style, expertise and administrative culture of successive secretaries-general.
The Lotfi Hachicha era (2020 – September 2023): The bastion of traditional compliance
Although Lotfi Hachicha had begun his tenure well before 2020, that year serves as the reference point used in the strategic bulletin. Officially, he left office on September 1, 2023, though he had actually reached retirement age in 2021 and received two successive one-year extensions to complete his mission.
This period unfolded amid a difficult international environment. Tunisia was still recovering financially and striving to consolidate gains achieved after being removed from the Financial Action Task Force (FATF) grey list. For Hachicha, the absolute priority was clear: permanently embedding a culture of compliance within Tunisian banks.
Under his leadership, the CTAF targeted vulnerabilities in an economy still heavily dependent on cash and the informal sector. Between 2020 and 2022, suspicious financial activity was mainly linked to two traditional pillars: international bank transfers (29%) and cash transactions (29%).
After a slight dip to 418 reports in 2021, bank vigilance intensified in 2022 with 516 reports before surging dramatically to 850 cases in 2023. It was also during this period that terrorism financing reached its highest level, accounting for 4% of reports in 2022.
Hachicha became the most outspoken secretary-general in the CTAF’s history, reflecting both his personality and the demands of the period.
The Neïla Fathallah interlude (March 2024 – September 2024): The major crackdown
Although her tenure was brief and ended abruptly, history will remember Neila Fathallah as the second woman to hold this highly sensitive post, following the notable tenure of Habiba Ben Salem.
Her time in office coincided with a significant hardening of the state’s approach, marked by accelerated administrative controls and heightened monitoring of financing channels, particularly cross-border flows.
This coercive turn immediately triggered a massive influx of alerts. In 2024, the annual number of suspicious transaction reports crossed a psychological threshold, reaching 1,236 reports.
A striking paradox emerged: while overall reports exploded, cases linked to terrorism financing collapsed to just 1%, only four terrorism financing reports transmitted for six suspicious reports received.
The CTAF consequently found itself overwhelmed by white-collar financial crime, as money laundering consumed 99% of analysts’ time. Businesses increasingly became the focus of investigations.
International trade and associations together accounted for 52% of alerts involving legal entities, followed by the construction and public works sector, which emerged as a major vulnerability area with 15% of reports.
Though her tenure ended unsuccessfully, it nevertheless initiated a new operational cycle.
The Abdessalem Ben Hamouda era (since April 2025): Technological maturity meets FATF stress test
In April 2025, Abdessalem Ben Hamouda took over as CTAF secretary-general. A rigorous legal expert and seasoned technocrat trained within the Central Bank of Tunisia, he inherited an institution under heavy quantitative pressure and facing a crucial institutional deadline.
Shortly after taking office, he found himself on the front line of a new country evaluation exercise conducted by the Financial Action Task Force, aimed at assessing the real effectiveness of Tunisia’s anti-money laundering and counter-terrorism financing framework.
Under this intense international scrutiny, his governance style combined strict legal orthodoxy with direct engagement with new fintech realities.
During his tenure, CTAF activity reached a historic peak with 1,334 reports processed in 2025, demonstrating the institution’s ability to absorb ever-growing data volumes while meeting FATF responsiveness standards.
But the real break under Ben Hamouda was qualitative and technological. For the first time, CTAF reports documented in precise detail the use of modern digital tools previously flying under Tunisia’s radar.
Facing international evaluators, the CTAF had to prove its competence against dematerialized threats: electronic wallets now feature in 2% of fraud cases, while international bank cards account for 1%.
This more scientific and internationally aligned approach also refined the mapping of underlying criminal offences generating illicit funds.
Ben Hamouda’s teams demonstrated that while direct terrorism financing remains contained at a residual rate of 1%, suspicious financial flows are now primarily linked to complex transnational crimes. Migrant trafficking — classified as illicit trade — alone accounts for 27% of cases.
This represents a crucial demonstration of Tunisia’s financial intelligence maturity on the international stage, an effort that must be consolidated, strengthened and sustained.
Beyond terrorism: The real societal cost
In the public imagination, the CTAF remains primarily an anti-terrorism weapon. Yet the cases handled between 2020 and 2025 reveal a different reality. Economic security is now deeply intertwined with major human crises. Illicit migrant trafficking alone represents 27% of offences associated with terrorism financing.
Money laundering itself has evolved. Beyond the crude schemes of the past, it is increasingly rooted in the legal economy, hidden behind respectable commercial structures and seemingly legitimate real estate transactions.
This transformation makes Tunisia’s experience a lesson for regulators worldwide. It demonstrates that a state can deploy legislative and security tools effectively enough to reduce terrorist networks to a marginal 1%.
However, the infrastructure of dirty money never truly disappears. It adapts with remarkable flexibility, infiltrating legitimate sectors, exploiting migration crises and rapidly appropriating emerging technologies.
The surge in suspicious transaction reports shows that the financial sector has become far more reactive and disciplined regarding compliance rules, while also reflecting the CTAF’s growing expertise in detecting anomalies.
The major challenge now lies in the grey zone where traditional trade-based money laundering converges with digital anonymization techniques. Ben Hamouda still has significant work ahead. It is now up to political leaders to provide the means necessary to match Tunisia’s ambitions.
