Morocco – CM AM

2025, Cross-border, Update

Country Manual Asset Management

Morocco

out of company’s Country of Establishment (Def, BT & RT)

Source of changesAnswers
Law / RegulationNo
New Position of the AuthoritiesNo
Evolution of Expert’s InterpretationYes

Definition & Concepts, Regulatory Overview and Behaviour Template

Material changes

The changes/modifications are as follows:

It is highlighted that the handling of contracts, agreements, subscription forms or transaction documents (including signature of documents) should only be performed on a cross-border basis into Morocco (remote). Therefore, the Country Manual Asset Management Behaviour Template (CM AM BT) now provides the answer “YES” in the remote scenario only;

In addition, “reverse solicitation” is no longer permitted onshore in Morocco (at target). Therefore, transactions and investment services requested on the client’s own initiative are only permitted if (directly) performed on a cross-border basis into Morocco (remote) or if (indirectly) conducted via/with locally licensed intermediaries/distributors. The CM AM BT therefore now provides the answer “NO” in the relevant onshore scenario;

The marketing of funds and structured products as well as the marketing of services and mandates is only permitted if conducted indirectly via/with locally licensed intermediaries/distributors. Accordingly, the CM AM BT now provides the answer “NO” in the onshore scenarios.

Non-material changes

Some comments and content have been slightly reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, June 18th, 2025