DISCLAIMER: This post was last modified on 9 October 2024. Some information in this article may not be updated.

On 28 June 2024, the Financial Action Task Force (FATF) placed Monaco under increased monitoring or a “grey list” to combat money laundering and terrorist financing. The FATF is a global anti-money laundering watchdog that establishes regulations to prevent these activities and monitors jurisdictions with “strategic deficiencies” in their anti-money laundering and counter-terrorism regimes. 

According to the FATF, Monaco had not taken enough measures to stop money laundering from fraud committed overseas or to seize illegal assets. Well-known for being a playground for the wealthy due to its advantageous tax system, what would the FATF’s grey listing mean for the Monaco family offices?  

How the greylisting affect Monaco family offices and other players

The addition of Monaco under FATF’s grey list may result in increased scrutiny of corporate services, governance and regulatory compliance, even though the jurisdiction has already taken several actions after being singled out by the Council of Europe’s anti-money laundering authority. For family offices in Monaco, this development may necessitate a re-evaluation of certain internal functions to mitigate risks and ensure full compliance with evolving regulations.  

In addition to family offices in Monaco, the greylisting significantly impacts participants in industries subject to AML requirements and investors seeking to establish businesses, make investments and open bank accounts in the state.  

Monaco authorities must implement several measures to comply with the FATF’s recommendations. These measures include improving the standard of suspicious transaction reporting (STR), enforcing the oversight of AML/CFT and beneficial owner requirements violations, increasing the seizure of property suspected of being derived from criminal activities, enhancing judicial efficiency and applying effective, dissuasive and proportionate sanctions for money laundering.  

Monaco’s commitment towards enhanced AML/CFT

Monaco has achieved significant improvements on various action plans proposed by MONEYVAL in the Mutual Evaluation Report (MER) of December 2022. The country has developed a new combined financial intelligence unit (FIU) and AML/CFT supervisor, increased terrorism financing detection and strengthened risk-based supervision of non-profit organisations.  

Monaco strives actively to implement the FATF’s recommendations, hoping to remove itself from the grey list by January 2026 (with two stage evaluations scheduled for May and September 2025). It will comply with the new action plan by:  

• enhancing its understanding of money laundering and income tax fraud risks; 
• increasing outbound requests for the identification and seizure of criminal assets abroad; 
• completing its FIU resource programs and improving the quality and timeliness of STR reporting;  
• enhancing judicial efficiency with increased numbers of judges and prosecutors and the application of effective, dissuasive and proportionate sanctions for money laundering; and 
• increasing the seizure of assets suspected of being linked to criminal activities.  

Bolder solutions

At Bolder Group, we understand the unique challenges that family offices in Monaco now face. With our extensive expertise in governance and corporate services and active presence across 18 jurisdictions globally, we are well-positioned to assist you in navigating this new regulatory environment.  

Outsourcing governance and compliance services to a trusted third party like us enables you to maintain operational efficiency while reducing the burden of increased regulatory requirements.  

If you would like to discuss this development and learn more about our services, feel free to contact us so we can assess your needs and design solutions that align with your goals.  

Bolder Group does not provide financial, tax or legal advice and the information contained herein is meant for general information purposes only. We strongly recommend that before acting on any of the information contained herein, readers should consult with their professional advisers. The Bolder Group accepts no liability for any errors or omissions in the information, or the consequences resulting from any action taken by a reader based on the information provided herein.

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