23
Jun
2026
Legal news
Companies and taxation
International and European law
2026
Legal news
Companies and taxation — International and European law
OECD / Monaco • Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request (June 2026)
The Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request of the Global Forum on Transparency and Exchange of Information for Tax Purposes of the Organisation for Economic Co-operation and Development (OECD) was published on 19 June 2026.
The Individual Monitoring Report on Monaco (pp. 50–54) analyses the measures taken by Monaco to address the recommendations set out in its 2018 Peer Review Report on Element A.1: Availability of information on owners, beneficial owners and identity, and the peer contributions received for the 2023-2024 monitoring period.
The Report concludes that the recommendations are “considered to have been implemented within the framework of the follow-up process (subject to peer review)”. Furthermore, it provides statistics on the exchange of information between Monaco and third countries for the 2023–2024 follow-up period, as well as guidance on the next steps to be taken by Monaco:
Element A.1: Availability of information on legal owners, beneficial owners and identity
1. Availability of information on the beneficial owners of general partnerships, limited partnerships, civil property companies and civil investment companies
The 2018 Report (paragraphs 52 to 54 and 85) recommended that Monaco ensure that information on the beneficial owners of partnerships is available in all cases. Information on the beneficial owners of partnerships was not updated following their incorporation before a notary, where such partnerships did not hold a bank account in Monaco or have a relationship with a chartered accountant established in Monaco.
The 2026 Individual Montoring Report notes that Monaco has taken comprehensive measures to implement this recommendation and that the shortcomings identified in 2018 have now been rectified:
- Information on the beneficial owners of partnerships is available from persons subject to Law No. 1.362 of 3 August 2009 on combating money laundering, the financing of terrorism and of the proliferation of weapons of mass destruction, and corruption (AML/CFT-P-C) as part of their client due diligence obligations.
- Partnerships are now required to identify and retain information relating to their beneficial owners and to report this information to the centralised register of beneficial owners that has been established. The new legal framework covers the availability of information on the beneficial owners of all relevant entities and legal arrangements, and contains provisions ensuring the availability of adequate, accurate and up-to-date information in accordance with the OECD standard. The definition and methodology for identifying beneficial owners are in line with the OECD standard. The legal framework provides for an obligation to collect sufficient information to ensure the identification of beneficial owners and to retain this information for 10 years.
- Companies are required to keep information on their beneficial owners up to date and to notify the central register of any changes within 30 days of becoming aware of the change. Although there is no obligation to confirm the accuracy of the information with the central register at fixed intervals (for example, on an annual basis), the legal framework nevertheless includes provisions enabling companies to remain informed of any changes relating to their beneficial owners. Firstly, within 30 days of a change, beneficial owners are required to notify the entity of the change and to provide the necessary supporting documents for their identification. Secondly, every company is required to appoint a beneficial owner information officer, who must be a natural person resident in Monaco (either a person chosen from among its partners, shareholders, staff or directors (or their members or representatives), or a person subject to anti-money laundering legislation from the list set out in the law, as applicable). The person responsible for information on beneficial owners is personally responsible for ensuring that the information contained in the register is always up to date.
- The discrepancy reporting system requires entities subject to anti-money laundering obligations to obtain an extract from the register of beneficial owners before entering into a business relationship with their customers, and to report any discrepancies with the information they have gathered in accordance with their due diligence obligations. The legal framework also allows them to request an extract from the centralised register at a later date as part of their ongoing duty of vigilance, and requires them to inform the authorities of any discrepancies.
- These obligations, combined with the requirement to keep information on their clients’ beneficial owners up to date, strengthen the system for ensuring that accurate, adequate and up-to-date information is available, given that all companies are required to hold a bank account in Monaco and banks are subject to an obligation to monitor their clients on an ongoing basis. This obligation includes updating information on beneficial owners in the event of a change or suspicion, as well as at appropriate intervals, depending on the client’s risk level. Although the legal framework does not specify these intervals, the supervisory authority has provided indicative intervals for what it considers appropriate, and each bank is required to notify the authority of the intervals set out in its internal procedures. The supervisory authority ensures that banks comply with their obligation to update information on their customers’ beneficial owners and has already imposed sanctions in cases where the frequency was too low or updates were not carried out in accordance with the frequency specified in internal procedures.
- The legal framework provides for penalties in the event of non-compliance with obligations relating to beneficial owners.
- The tax authorities have access to information held in the centralised register of beneficial owners.
2. Strengthening the supervision of chartered accountants, statutory auditors and notaries who hold information on beneficial owners
The 2018 Report (paragraphs 62 to 66) recommended that Monaco strengthen the supervision of chartered accountants, statutory auditors and notaries, who hold information on the beneficial owners of entities and legal arrangements in Monaco. Although SICCFIN [Service d’Information et de Contrôle sur les Circuits Financiers, replaced in 2023 by the Autorité Monégasque de Sécurité Financière (AMSF)] stepped up its checks on the legal professions during the assessment period, on-site inspections of chartered accountants did not begin until the end of the assessment period. With regard to the supervision of the three notaries practising in Monaco during and after the assessment period, no on-site visits had been carried out by the offices of the Public Prosecutor, which was responsible for supervising judicial officers.
The 2026 Individual Monitoring Report notes that Monaco has taken comprehensive measures to implement this recommendation and that the shortcomings identified in 2018 have now been rectified:
- Since 2023, notaries have been under the supervision of the AMSF, rather than the Public Prosecutor.
- Monaco has strengthened its inspection teams and introduced a tool to improve the identification of risks by type of professional. The STRIX questionnaire enables a comprehensive annual AML/CFT compliance questionnaire to be sent to each professional and their risk profile to be established. It has been in use for chartered accountants since 2023 and for notaries since 2024.
- Monaco closely monitors and supervises professionals and implements control programmes. Where breaches have been detected, sanctions have been imposed. The audits have provided adequate coverage, targeting professionals subject to the AML/CFT-P-C legislation covered by this recommendation, in particular chartered accountants (who are the only professionals in Monaco authorised to act as statutory auditors) and notaries. With regard to chartered accountants, inspections have been carried out since 2016 at the firms employing the largest number of these professionals, covering 78 per cent of those subject to the legislation. Sanctions have been imposed in cases of non-compliance. Monaco’s three notaries were audited in January 2020 and March 2022. Since then, the AMSF has held targeted meetings with these professionals to discuss their obligations and the follow-up to the actions recommended following the audits. In 2025, the AMSF also carried out a sectoral risk analysis, for which the three notaries were consulted and met with.
Statistics on the exchange of information between Monaco and third countries (2023-2024)
- Monaco received 543 requests for tax information, mainly from France, Italy and the United Kingdom. Monaco reported that it had provided complete and final responses to 99 per cent of all requests received. The remaining 1 per cent comprises one request currently being processed and three requests withdrawn by the requesting jurisdiction.
- Monaco sent 13 requests, mainly to France.
Seven members provided comments on their exchange relationship with Monaco. Peers indicated that they were generally satisfied with their experience of exchanging information with Monaco.
Next steps expected of Monaco
In particular, Monaco must continue to submit a self-assessment report as part of the enhanced monitoring process in order to:
- report any new national developments (legal, administrative or judicial) that may affect the implementation of the standard on transparency and exchange of information on request.
- provide statistical information on its experience with the exchange of information on request during the monitoring period.
- provide a response to any other questions relating to the OECD standard on transparency and the exchange of information on request, where specifically requested.
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Sources:
- OCDE (2026), Rapport de suivi renforcé sur la mise en œuvre de la norme de transparence et d'échange de renseignements sur demande – Mise à jour 2026 (juin) (version abrégée), Éditions OCDE, Paris, https://doi.org/10.1787/721c5ee7-fr
- OECD (2018), Global Forum on Transparency and Exchange of Information for Tax Purposes: Monaco 2018 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/9789264291157-en
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