Following its evaluation process started in 2021, Monaco has been placed under reinforced scrutiny by the FATF which however acknowledged the significant progress and improvements made by the Principality of Monaco on several recommended actions by the mutual evaluation report (available here). Monaco is continuing its work towards the fulfillment of FATF’s recommendations with the goal to be out of the grey list before January 2026 (and two stage reviews in May and September 2025).
The placement of Monaco under FATF’s grey list highly impacts players of the Monaco market subject to AML regulations as well as investors willing to start business, invest and open bank accounts in Monaco. To comply with FATF’s recommendations, Monaco authorities will – for example – strengthen the quality of STR reporting, enhance the application of sanctions for AML/CFT and beneficial owners requirements breaches, increase the seizure of property suspected to derive from criminal activities and enhance judicial efficiency and application of effective, dissuasive and proportionate sanctions for money laundering.
DL Corporate & Regulatory has strong experience in Monaco AML/CFT requirements. For over 10 years, our lawyers have advised major banks and other entities (e.g. CSP, asset management, law firms, yachting sectors, etc) on their compliance with Monaco AML/CFT laws. Our recommendation is to step-up AML training sessions and review internal procedures (both legal obligations under Monaco law for professions subject to AML regulations) to neutralise the effects of Monaco’s downgrading and ensure full compliance with new extensive and complex AML/CFT obligations.
Feel free to contact us here for any further information or details on our AML/CFT legal services.
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