15
May
2026
Legal news
Yatching and maritime law
Risks & Compliance AML/CFT-P-C
2026
Legal news
Yatching and maritime law — Risks & Compliance AML/CFT-P-C
AMSF (AML/CFT-P-C) • Practical Guide #7 Yachting 2026 (Monaco)
On 13 May 2026, the Monegasque Financial Security Authority (AMSF) published its Practical Guide #7 Yachting 2026, which sets out the legislation and regulations in force on that date relating to the fight against money laundering,financing of terrorism financingand of the proliferation of weapons of mass destruction, and corruption (AML/CFT-P-C).
The Guide, which is for information purposes (only the legislative and regulatory texts governing the AML/CFT-P-C framework in the Principality are authoritative), is intended for yachting professionals subject to AML/CFT-P-C obligations pursuant to paragraph 15° bis) of Article 1 of Law No. 1.362 of 3 August 2009, as amended.
See also the General Guidelines V2 (April 2026)
Key points of the PracticalGuide #7 Yachting 2026
CONTEXT
Reminder regarding yachting professionals subject to Monaco’s AML/CFT-P-C regime (any entity which, as a natural or legal person, regardless of the vessel’s length or the amount involved, acts as an intermediary or carries out transactions involving: the purchase or sale of new or second-hand vessels; the chartering or hiring of vessels, as well as the administrative management of large pleasure or commercial vessels.)
KEY SECTOR-SPECIFIC RISKS
Monaco’s maritime economy in figures (835 businesses, 3,268 employees, revenue of €1.8 billion, equivalent to 10% of the Principality’s total revenue; of which the yachting sector accounts for 411 businesses, 1,429 jobs and revenue of €600 million; for the sale of large pleasure craft: 203 entities, 431 jobs, revenue of €309 million; chartering activities: revenue of €44 million).
According to the 2021 National Risk Assessment 2 (ENR 2), the yachting sector is considered to present a “High” risk in Monaco, and the data analysed since then supports maintaining this risk level:
- risk that Monaco may be used to channel funds of illicit origin stemming from underlying offences committed abroad, or that it may serve as the final destination for the placement of such funds;
- risk arising from the slight increase in the proportion of legal entities, trusts and similar legal structures amongst the client base, the complexity of which may make it more difficult or impossible to identify the beneficial owners;
- risks posed by distribution channels: the multitude of intermediaries (entities’ use of partnerships, brokerage agreements and business introducers to acquire clients and provide them with services) and the use of remote identification increase the difficulties in adequately identifying clients and/or beneficial owners;
- emergence of a new risk with the settlement of certain purchases or services in crypto-assets.
RISKS
Overview of known AML/CFT-P-C risks in the yachting sector, and key areas for vigilance:
- Risks related to customer characteristics (nature of the customer: their status, behaviour, professional activity, reputation).
- Risks related to products and services (vulnerabilities specific to each type of product or service offered: allowing for anonymity, significant transaction volumes, unusual purchase or sale patterns).
- Risks related to transaction conditions (means of payment used; transaction amounts; transaction volumes; spreading of payments over time; complexity of transactions).
- Risks related to distribution channels (the manner in which products and services are offered to customers: conditions for remote identification; use of third parties).
- Risks related to geographical areas (jurisdiction to which the customer, beneficial owner or agent is linked: country or territory of residence, nationality, destination of funds, companies registered in high-risk or non-compliant states or territories
OBLIGATIONS
Overview of the three main categories of AML/CFT-P-C obligations:
- Basic obligations (verification of the fit and proper requirements relating to persons effectively managing the reporting entity, as well as its partners, shareholders and beneficial owners; appointment and training of one or more AML/CFT-P-C compliance officers; implementation of a business-wide risk assessment; definition and formalisation of internal AML/CFT-P-C procedures; implementation of an internal whistleblowing mechanism; establishment of an internal control framework; appointment of a representative in the event of cessation of business activities; implementation of a group-wide framework where applicable; appointment of a person responsible for maintaining basic information and beneficial ownership information where the professional is a commercial company, an economic interest grouping or a civil company).
- Annual obligations (submission of the annual STRIX questionnaire; staff training).
- Operational obligations applying to all clients (customer identification and understanding of the business relationship, where applicable; determination of the level of risk in order to apply the appropriate level of due diligence — simplified, standard or enhanced); applying to business relationships (ongoing monitoring, including continuous transaction monitoring and periodic updating of customer files); and suspicious transaction reports (qualitative reporting).
Three practical operational case studies are attached.
FAQ
The Guide answers the following questions:
- How should internal AML/CFT-PF-C procedures be drafted?
- What is the purpose of the entity’s risk assessment?
- Should transactions involving politically exposed persons (PEPs) be prohibited?
- What action should be taken where a client or third party involved in the business relationship is subject to Monegasque asset freezing measures?
The Guide concludes with a reminder of the applicable legislative and regulatory provisions, as well as the administrative sanctions imposed by the AMSF.
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