AMSF • AML/CFT-P-C: General guidelines for Monegasque professionals, Version 2 of 21 April 2026

The Monegasque Financial Security Authority (AMSF) has published the second version of its General Guidelines for Monegasque Professionals V2 dated 21 April 2026 (263 pages), which replaces the first version dated 21 July 2021.

These guidelines clarify the legislation in force as at 21 April 2026 concerning the prevention of money laundering, terrorist financing, the proliferation of weapons of mass destruction and corruption (AML/CFT-P-C), and provide guidance to regulated entities on the fulfilment of their obligations. They are not legally binding.

Only the legislative provisions (Law No. 1.362, as amended) and regulatory provisions (in particular Sovereign Order No. 2.318, as amended, and other implementing regulations) currently in force are authoritative. These provisions are subject to change. It should be noted in this regard that Monaco will implement the ‘European anti-money laundering package’, comprising in particular Regulation (EU) 2024/1624 (AMLR6), Directive (EU) 2024/1640 (AMLD6) of 31 May 2024 (implementation deadline for Monaco: 31 December 2028).

The new version of the General Guidelines formalises the developments that have taken place since the first version of 2001:

• Institutional reform (replacement of SICCFIN by AMSF, independent administrative authority with enhanced powers),
• Substantial changes to the AML/CFT-P-C regime (amendments introduced in particular by Law No. 1.537 of 9 December 2022, Law No. 1.549 of 6 July 2023 Part I, Law No. 1.550 of 10 August 2023 Part II, Law No. 1.553 of 7 December 2023 Part III, Law No. 1.559 of 29 February 2024 Part IV, Sovereign Order No. 10.124 of 21 September 2023, Sovereign Order No. 10.513 of 17 April 2024),
• Modernised reporting tools (goAML, STRIX).

Furthermore, the 2026 edition has been enhanced in terms of comprehensiveness and practicality (concrete examples and resources).

In addition to these general guidelines, the AMSF has also published:

• Guidelines "Suspicion Report"
• Guides: Private Banking and Wealth Management, Terrorist Financing, Politically Exposed Persons (PEPs)
• Sector-specific practical guides: Estate Agents, Sports Agents, Yachting
• Thematic practical guides: Beneficial Owners and Complex Structures, Internal Procedures, Overall Risk Assessment, Suspicion Reports, Targeted Financial Sanctions

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Contents of the General AML/CFT Guidelines (V2, 21 April 2026)

The 2026 Generic Guidelines V2 are structured as follows:

Glossary and abbreviations
Foreword and objectives
Contents
Flowcharts
• Overview of the topics covered
• List of obligations covered
• Summary of customer due diligence obligations
• Summary of the different categories of due diligence measures
Introduction
1. Background and legal framework of AML/CFT-P-C
1.1. The European and international framework
1.2. The Monegasque framework
2. The Monegasque authorities
2.1. Working and coordination groups
2.2. Authorities involved in AML/CFT-P-C
2.2.1. Monegasque Directorates and Departments
2.2.2. Administrative and independent authorities
2.2.3. The regulatory authority for lawyers
3. Definitions of offences in Monaco
3.1. Money laundering
3.2. Terrorist financing
3.3. Proliferation of weapons of mass destruction
3.4. Corruption
4. The Monegasque Financial Security Authority (AMSF)
4.1. The Monegasque Financial Security Authority
4.2. The Financial Intelligence Unit (FIU)
4.3. The Department responsible for supervision
4.4. The Department responsible for sanctions
5. Scope of application of the law and role of regulated entities
5.1. Scope
5.2. The key role of regulated entities
6. Key definitions
6.1. A prospective client
6.2. A client
6.3. A business relationship
6.4. An occasional transaction or an occasional client
Part 1: Implementing the risk-based approach
1. A thorough understanding of the comprehensive risk assessment
2. Proper application of the obligation to carry out a comprehensive risk assessment
2.1. Essential requirements for a risk assessment that complies with the regulations
2.2. The risk assessment process
Part 2: Internal organisational obligations
1. Governance of the entity
2. Good repute requirements
3. The AML/CFT-P-C officer
3.1. The identity of persons responsible for AML/CFT-P-C
3.2. The duties of AML/CFT-P-C officers
4. The officer responsible for basic information and information on beneficial owners
5. Internal procedures
5.1. The content of internal procedures
5.2. Approval, updating and communication
6. The internal control framework
7. Staff training and awareness-raising
7.1. Training for members of the regulated entity
7.2. Recruitment of staff
8. Arrangements for groups
8.1. Where the regulated entity belongs to a group
8.2. Where the regulated entity has subsidiaries or branches
9. Arrangements in the event of cessation of business
Part 3: Risk assessment at client level
1. Methodology
2. Formalisation
3. Follow-up actions
Part 4: Due diligence measures to be implemented according to the risk level assigned to the client
1. Client profile analysis
1.1. Identification and verification of customers’ identities
1.2. Identification and verification of beneficial owners’ identities
1.3. Identification and verification of the identity of representatives acting on behalf of the customer
1.4. Relationships with partners
1.5. Gathering information on the nature and purpose of the business relationship and the socio-economic background
1.6. Delegation of due diligence obligations to a third party
2. Refusal to enter into or maintain a business relationship
3. Standard due diligence measures
4. Simplified due diligence measures
4.1. Low risk and absence of suspicion
4.2. The customer is a person or entity referred to in Article 21(2) of the amended OS 2.318
5. Enhanced due diligence measures
5.1. The principle of enhanced due diligence measures
5.1.1. Re-identification in cases of doubt
5.1.2. Specific checks
5.2. Specific cases of enhanced due diligence provided for by law
5.2.1. Politically exposed persons
5.2.2. High-Risk Countries or Territories (HRCs) and Non-Cooperative Countries or Territories (NCCs)
5.2.3. Establishing a business relationship or carrying out a transaction remotely
5.3. Cases presenting a high risk
Part 5: Ongoing due diligence measures
1. Updating client files
1.1. Periodic updates
1.2. Ad hoc updates
2. Monitoring transactions
2.1. Monitoring procedures
2.2. The specific case of cash payments
2.3. The specific case of prepaid cards and cash withdrawals
2.4. The specific case of virtual assets
2.5. Atypical transactions
Part 6: How to proceed in cases of doubt or suspicion
1. Specific reviews
2. Suspicion reports
2.1. Cases requiring a suspicion report
2.2. Procedures for filing a suspicion report
2.3. Follow-up to a suspicion report
3. The internal reporting mechanism
Part 7: Penalties
1. Administrative penalties
1.1. Breaches of Article 64-7 of Law No. 1.362, as amended
1.2. Breaches of Article 65 of Law No. 1.362, as amended
1.3. Breaches of the provisions of Ministerial Order No. 2.318, as amended
1.4. Penalties incurred pursuant to Article 65-8 of Law No. 1.362, as amended, and Ministerial Order No. 2.318, as amended
2. Criminal penalties
Part 8: Data retention
Part 9: Registers
1. The "Register of Beneficial Owners - Companies and Economic Interest Groups -"
1.1. Persons required to register
1.2. Registration and updating of information
1.3. Access to the register
1.4. Inspections and penalties incurred
2. The register of trusts
2.1. Persons required to register
2.2. Registration and updating of information
3. The register of associations
4. The register of payment accounts, bank accounts and safe deposit boxes (FICOBAM)
4.1. Persons and information covered
4.2. Access to the register
Part 10: Miscellaneous Provisions
1. Administrative procedures to be followed to ensure full compliance
1.1. Registration as an AML/CFT Officer
1.2. Registration with GoAML
1.3. Submission of internal procedures and the annual activity report
1.4. STRIX
1.5. Subscription to relevant newsletters
1.6. Application for exemption from the requirement to implement an automated system
2. Bearer instruments
Appendices
Appendix A: List of supporting documents to verify a client’s socio-economic background
Appendix B: Documents to be collected
1. Best practices
2. National identity documents
3. Extract from the Register of Commerce and Industry
4. Certificate of registration in the Special Register of Civil Companies
5. Power of Attorney
6. Trust deed or deed of settlement
7. Articles of Incorporation / Association
8. Certificate of Registration / Incorporation
9. Certificate of Incumbency
10. Share certificate / Stock certificate
11. Nominee shareholder: Declaration of Trust / Nominee agreement
12. Share transfer agreement / Sale of shares
13. Partnership deed
14. Certificate of Good Standing
Appendix C: Rules for identifying beneficial owners
1. Direct ownership of capital
2. Indirect ownership of capital
3. Direct and indirect ownership of capital
4. Direct and indirect ownership of capital involving a trust client and natural persons
5. Direct and indirect ownership of capital involving a trust and natural persons
6. Direct and indirect ownership of capital involving a client trust with natural persons and legal entities
7. Direct and indirect ownership of capital involving a trust with natural persons and legal entities
8. Taking out or joining a life insurance policy
9. Ownership of capital involving a division of ownership
10. Holding of capital involving a subsidiary of a company listed on a regulated market
11. Holding of capital involving a minor
12. Holding of capital involving a chain of majority ownership
13. Holding by other means – family group
14. Ownership of capital involving an arrangement designed to secure control through cross-shareholdings between companies (or control via a closed loop)
Appendix D: Registers
1. European registers (business directories, commercial registers)
2. Non-European registers (non-exhaustive list)

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