Monaco: Update to the list of high-risk jurisdictions (ETHR) – 07.2026

04/08/2026
Following the publication of Ministerial Order No. 2026-433 of 28 July 2026, amending Ministerial Order No. 2021-703 of 8 November 2021, as amended, Monaco has updated the list of States or territories whose anti-money laundering, counter-terrorist financing and counter-proliferation financing, and anti-corruption (AML/CFT-PF/CFT) frameworks present strategic deficiencies (the "ETHR list").

This list, initially established by Ministerial Order No. 2021-703 of 8 November 2021, is a key component of Monaco's AML/CFT-PF/CFT framework, adopted pursuant to Article 14-1 of Law No. 1.362 of 3 August 2009, as amended.


Key update
Ministerial Order No. 2026-433 adds the following jurisdictions to the ETHR list:
  • Bosnia and Herzegovina
  • Iraq
These jurisdictions are now classified as presenting strategic deficiencies in AML/CFT matters, following the placement decision adopted by the Financial Action Task Force (FATF) at its Plenary meeting of 16–19 June 2026.


Extended reporting obligations
Article 2 of Ministerial Order No. 2026-433 further confirms that the reporting obligations under Chapter V of Law No. 1.362, as amended, pursuant to Article 41 thereof, remain extended to any transactions and facts concerning natural or legal persons domiciled, registered, or established in the Democratic People’s Republic of Korea and the Islamic Republic of Iran.


Updated list of high-risk jurisdictions (ETHR)
As updated by Ministerial Order No. 2026-433, the Monégasque ETHR list now comprises the following 30 States and territories:
  • Afghanistan;
  • Algeria;
  • Angola;
  • Bolivia;
  • Bosnia and Herzegovina;
  • Bulgaria;
  • Cameroon;
  • Democratic Republic of the Congo;
  • Democratic People's Republic of Korea;
  • Ivory Coast;
  • Haiti;
  • British Virgin Islands;
  • Iraq;
  • Islamic Republic of Iran;
  • Kenya;
  • Kuwait;
  • Lao People's Democratic Republic;
  • Lebanon;
  • Myanmar/Burma;
  • Namibia;
  • Nepal;
  • Papua New Guinea;
  • Russian Federation;
  • South Sudan;
  • Syria;
  • Trinidad and Tobago;
  • Vanuatu;
  • Venezuela;
  • Vietnam;
  • Yemen.

Alignment with international standards
The Monégasque ETHR list is aligned with international standards, in particular:
  • the Financial Action Task Force (FATF) lists; and
  • the European Union's list of high-risk third countries, annexed to Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016, as amended, supplementing Directive (EU) 2015/849.
This update reflects the Principality's ongoing commitment to keeping its AML/CFT-PF/CFT framework consistent with evolving international standards.


Regulatory implications
Jurisdictions included on the ETHR list are deemed to present strategic deficiencies in their AML/CFT regimes. As a result, any business relationship or transaction connected with one of these jurisdictions is subject to an enhanced due diligence regime under Monégasque law.


Obligations for reporting entities
A link with a State or territory on the ETHR list triggers, for entities subject to Law No. 1.362, as amended, a set of enhanced obligations, including:
  • implementing enhanced due diligence measures for any business relationship or transaction presenting such a link, pursuant to Article 14-2 of Law No. 1.362, as amended;
  • documenting the assessed level of risk;
  • adjusting, where necessary, the frequency of file reviews and transaction monitoring;
  • retaining documentation evidencing the due diligence carried out.
In addition, where a transaction meets the criteria set out in Article 14 of Law No. 1.362, as amended, notably where it appears complex, unusually large, or lacking an apparent economic or lawful justification, a special examination report must be prepared and retained. A connection with an ETHR jurisdiction is frequently a factor triggering heightened scrutiny in this respect.


Operational impacts to anticipate
Beyond its regulatory scope, this update typically calls for prompt operational adjustments. Reporting entities are advised to review:
  • their internal high-risk country reference lists;
  • the configuration of their screening and transaction monitoring tools;
  • the consistency of their internal procedures and risk mapping in light of this change;
  • client files with a connection to the newly listed jurisdictions, with a view to reassessment;
  • training provided to compliance and operational teams.
These checks help ensure consistent application of the applicable regulatory requirements and demonstrate, where required, the effectiveness of the compliance framework in the event of a supervisory review.


How Rosemont can assist
Rosemont International supports clients in:
  • monitoring regulatory developments in AML/CFT-PF/CFT matters;
  • analysing jurisdictional risk exposure;
  • adapting compliance frameworks;
  • supporting private wealth and international structures.
In this respect, LEXCO AML Software, powered by KYC Portal®, allows reporting entities to integrate ETHR list updates directly into their screening and monitoring tools, ensuring these regulatory changes are captured immediately and traceably within the compliance framework.

For more information, please contact consulting@rosemont.mc.


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