Context and Regulatory Framework
Following its grey-listing by the FATF in 2024, Monaco undertook comprehensive reforms to its AML/CFT regime. A key part of this overhaul was the creation of the Autorité Monégasque de Sécurité Financière (AMSF) in July 2023, replacing SICCFIN. The AMSF was granted independent supervisory and sanctioning powers. Notably, its Sanctions Commission may now impose penalties without ministerial validation, even for single-instance compliance failures.
This marked a shift from prior practice, where enforcement was limited to "grave, repeated, or systematic" violations. As of mid-2025, over 700 entities had received formal compliance notices from the AMSF, with approximately 600 hundred taking remedial action within the prescribed period. The remainder were referred to the Sanctions Commission. Six published Sanctions Commission decisions from 2025 onward are summarised below, followed by a review of developments within the legal profession. Note some decisions may be subject to appeal:
I. AMSF Sanctions Commission Decisions
1. Procedure 2025/2144 – Anonymised (Monaco Numismatic and Precious Metals Dealer) – Oct 2025
Entity: Anonymised
Decision Date: 29 October 2025
Findings: In a decision dated 15 October 2025, the AMSF Sanctions Commission imposed a €60,000 fine on an anonymised Monaco-based firm primarily engaged in the purchase and sale of coins, antique jewellery, collectible items, and precious metals, as well as coin auctions. The entity, which is undergoing liquidation, was found to have committed multiple breaches of AML Law No. 1.362. These included the absence of a documented risk assessment, a deficient client risk classification methodology, and failure to perform or document ongoing monitoring and periodic KYC reviews for high-risk clients. The AMSF acknowledged partial remediation but underscored that corrective action after inspection does not absolve prior violations. This early published decision set a clear precedent on the enforcement of AML obligations for high-value goods dealers.
Sanction: €60,000 fine
Implication: This case set the precedent for what would become a pattern of increasingly rigorous published enforcement actions. Demonstrated the AMSF’s readiness to sanction.
2. Procedure 2025/2145 (Monaco Yacht Brokerage) – Nov 2025
Entity: Anonymised
ecision Date: 18 November 2025
Findings: The firm engaged in high-value asset transactions (e.g., yachts) and lacked adequate AML measures. Violations included outdated policies, superficial KYC, insufficient source of funds checks (including a Bitcoin-funded purchase), and improper delegation of compliance functions to unqualified third parties. The failure to perform appropriate due diligence in high-risk contexts, particularly when crypto assets and complex jurisdictions were involved, was particularly serious.
Sanction: €50,000 fine
Implication: Reinforced the duty of sector-specific risk-based controls, especially for luxury intermediaries handling complex and crypto-linked transactions.
3. Procedure 2025/2147 (Monaco Real Estate Agency) – Nov 2025
Entity: Anonymised
Decision Date: 18 November 2025
Findings: A small Monaco real estate firm was fined for having virtually no AML framework. Its procedures had not been updated since 2010. Failings included no training, no documented risk assessment, and incomplete client files lacking key due diligence materials. The agency also failed to conduct periodic client reviews or identify politically exposed persons.
Sanction: €18,000 fine
Implication: Showed that even small firms face enforcement if AML obligations are disregarded, and that post-inspection remediation does not offset prior non-compliance.
4. Procedure 2025/3171 – (Monaco TCSP [1]) (Dec 2025)
Entity: Name of TSCP published
ecision Date: 22 December 2025
Findings: The firm faced one of the most severe penalties for structural failings in AML governance. It lacked an effective Compliance Officer for several months, had outdated or inconsistent risk assessment tools, failed to verify source of wealth across clients, and had not addressed repeated prior warnings. Governance dysfunction and staff turnover were major aggravating factors.
Sanction: €800,000 fine; decision published in full
Implication: Largest fine to date; a signal that governance lapses and delayed remediation attract significant penalties. Demonstrated that costly post-facto remediation (e.g., consulting expenses) does not excuse historical failings.
5. Procedure 2025/3199 – (Monaco TCSP [2]) (Dec 2025)
Entity: Name of TSCP published
Decision Date: 22 December 2025
Findings: The CSP failed to meet basic AML expectations. Deficiencies included missing wealth documentation, poor handling of politically exposed persons (PEPs), and failure to file timely suspicious transaction reports (STRs). ICS had previously been inspected and warned in 2019 but did not fully address the issues.
Sanction: €500,000 fine
Implication: Confirmed that CSPs must maintain AML continuity and escalate risk issues, especially involving PEPs. Reinforced expectations for senior-level oversight of high-risk clients and effective follow-up to prior inspection findings.
6. Procedure 2025/3196 (Monaco Real Estate Agency) – Dec 2025
Entity: Anonymised Monaco Real Estate Agency
Decision Date: 22 December 2025.
Findings: The firm, a three-person real estate agency focused on local rentals, had no functioning AML/CFT system. Its procedures dated back to 2010, it lacked a risk assessment, staff training, and proper client due diligence. Files were missing IDs and ownership data, and there were no controls for PEPs or high-risk countries. Although remediation began after inspection, eight violations were confirmed.
Sanction: €18,000 fine.
Implication: The AMSF emphasised that ignorance of AML obligations and post-inspection remediation do not excuse past non-compliance. Small firms are fully accountable under AML law.II.
II. Legal Profession AML Sanctions (2025–2026)
Supervisory Powers and Methodology
The Monaco Bar Council became AML supervisor for legal professionals under a 2023 reform. In September 2024, it adopted formal disciplinary procedures and launched a robust program of inspections. By December 2025, all Monaco law firms had undergone some form of AML verification, including:
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Two full-scope on-site reviews (June 2024, April 2025)
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Two targeted on-site reviews (October 2024, September 2025)
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One document-based review (November 2025)
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Fifteen AML compliance interviews at the Maison de l’Avocat
The Bar also designated a dedicated AML focal point and supervision delegate to lead its efforts and ensure ongoing communication with the AMSF.
First Disciplinary Sanction – July 2025
Entity: Anonymised chamber (law firm)
Findings: Breach of Law No. 1.362. Although the Council did not publicly detail the specific failings, they likely included failure to implement adequate internal procedures, incomplete client due diligence, or insufficient documentation of AML compliance.
Sanction: €10,000 fine
Outcome: Decision became final without appeal.
Implication: Marked the first known AML-related disciplinary fine by the Bar Council. Sent a strong message to legal professionals that they are not exempt from robust enforcement and that failure to adopt a documented, risk-based AML framework can result in financial penalties.
Indicators of Growing Engagement
In addition to the inspection regime and sanction activity, the legal profession demonstrated greater involvement in AML enforcement by:
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Filing 12 STRs to the AMSF via the goAML platform by end-2025
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Participating in regular sectoral risk assessment updates
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Receiving guidance on client screening, PEP detection, and escalation procedures
These developments reflect increasing alignment between the Bar Council and the AMSF, with growing cooperation and shared standards.
Since 2025, Monaco has entered a new phase of AML enforcement. The AMSF has demonstrated its capacity to impose meaningful sanctions, including landmark fines of €800,000 and €500,000 against major fiduciaries. These cases confirm that failures in governance, due diligence, STR filing, and source of wealth verification can no longer be overlooked. At the same time, the legal profession’s regulator has issued its first disciplinary fine and completed chamber-wide inspections.
Together, these developments illustrate a robust institutional response to the FATF grey listing and reflect a transformed compliance culture across Monaco’s regulated sectors. Firms of all sizes and profiles must now treat AML compliance as a continuous, auditable obligation. The message is clear: enforcement is active, and no entity is immune. The AMSF and the Bar Council have both shown that credible deterrence, transparency, and accountability are the new standard in Monaco’s financial and professional ecosystem.
At Rosemont Consulting in Monaco we follow closely the evolving AML compliance environment in Monaco.
How Rosemont Consulting can help
Rosemont Consulting in Monaco and Rosemont International can assist obliged entities, including yacht brokers, real estate agents, asset managers, single and multi-family offices and corporate service providers, to:
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Review and update AML policies and risk assessments aligned with Law 1.362 and OS 2.318.
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Design practical KYC and source of wealth procedures for high value yachting and property transactions.
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Implement PEP and ETHR screening, training plans and file review cycles.
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Map and remediate gaps ahead of AMSF inspections.
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Organised compliance monitoring and screening with the LEXCO platform
Contact us consulting@rosemont.mc
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