Department of Economic Development: "Approximately 1,500 professionals are subject to the law"

As the primary point of contact for businesses, the Department of Economic Development (DDE) has implemented several measures: a large-scale clean-up of real estate investment companies (SCPs); the creation of registers of active beneficiaries and trusts in the name of transparency; administrative sanctions for breaches, etc.  Monaco Economie talks to Pierre-André Chiappori, Governement Conselor-Minister for Finance and the Economy.

What reforms have been undertaken since the last FATF assessments? Which are the priority projects being led by the DDE? What is the current status of the clean-up of SCPs and SCIs?

As part of the implementation of the FATF Action Plan, the DDE has worked to strengthen the transparency of legal entities and address the shortcomings identified in the Principality's fifth-cycle assessment report by the MONEYVAL Committee (2022).  The objective is to ensure that the various registers contain complete and up-to-date information (including basic information and data relating to beneficial owners).  The department now has a robust framework, enabling it to impose various sanctions in the event of identified breaches.  The DDE has thus made significant progress, both in terms of the regularisation carried out and the completeness rates of the various registers.  The clean-up of the Special Register of Non-Trading Companies has resulted in the automatic removal of several thousand firms identified as being inactive.  The measures implemented have been deemed satisfactory by the FATF and, therefore, no additional measures are required in this area. 

MONEYVAL had highlighted shortcomings in the transparency of legal entities.  All companies registered with the Monaco Trade and Industry Register (RCI), as well as foreign entities operating in the Principality, must now declare their beneficial owners to the Register of Beneficial Owners (RBE) and a new Register of Trusts (RDT) has also been created as part of the fight against money laundering.  Have these measures been well received by private sector stakeholders? Are these registers public?

The update of the Monégasque legal framework regarding the identification and verification of the identity of clients and beneficial owners, as well as the related due diligence obligations, stems from the transposition into domestic law of European Directives concerning the prevention of the use of the financial system for money laundering or terrorist financing.  This action, in line with the Principality of Monaco's international commitments, did not elicit any negative reaction from the private sector.  

The DDE, and more specifically RBE agents, contributed to supporting professionals and the general public in better understanding the concept of beneficial ownership through dedicated web pages, practical guides, regular training sessions and assistance with each application for registration with the RBE or the RDT.

The information contained in these registers is available to the public under certain conditions.  This approach is consistent with the case law of the European Court of Human Rights, which has ruled that "allowing unlimited public access to the register's information infringes on the privacy and personal data protection of beneficial owners". *

Businesses are now subject to new compliance obligations.  How many companies are subject to anti-money laundering laws? Has registration on these lists generated additional administrative costs or delays in compliance for professionals?

To date, approximately 1,500 professionals are subject to Law 1.362 of 3 August 2009, as amended.  It should be noted, however, that this number is constantly changing.  The private sector acknowledges the demanding nature of the procedures implemented but emphasises the quality of support provided by the authorities.  The strengthening of compliance obligations – in line with European standards – stems from legislative and regulatory updates that are mandatory in Monaco, regardless of Monaco's inclusion on the FATF Grey List and the European Union's list.

Do you have enforcement powers? How many companies have been sanctioned for breaches of their obligations and what are the fines?

Yes, we do.  Administrative sanctions can be imposed by the DDE, the Monégasque Financial Security Authority (AMSF) and the Bar Association and these may be published, if necessary.  Regarding the AMSF in particular, it is worth noting the recent publication of three decisions by its sanctions committee in the Journal de Monaco and on the Authority's website.  Criminal penalties can also be imposed, including the seizure and confiscation of the instruments and proceeds of crime.  The management of seized or confiscated assets is currently handled by a dedicated Seized or Confiscated Assets Management Service, under the authority of the Director of Judicial Services.

Have you observed any signs of resilience or slowdown in the Monégasque economy since the listing? Are some sectors more affected than others (finance, real estate, family offices, international trade)?

The Principality of Monaco has so far demonstrated considerable resilience.  Indeed, the fundamentals of the economy remain stable and sustainable in key sectors, including finance.  The total amount of assets under management by banks has increased over the past 12 months.  Nevertheless, caution remains essential and authorities are fully committed to removing Monaco from the FATF Grey List as quickly as possible.

Have companies postponed or cancelled projects to set up or invest in Monaco? What effects have you identified on the Principality's overall attractiveness for international investors?

Measuring postponed or abandoned projects is difficult since they are not, by their very nature, formally registered.  However, some key indicators seem to demonstrate that Monaco remains attractive: firstly, the number of asset management companies is constantly increasing, reaching a record 74 in December 2025; and secondly, the banking sector is showing an increase in loans granted, demonstrating continuity of investment.

Are banking or financial operations experiencing significant delays due to enhanced controls? Have some foreign institutions become more cautious in their dealings with Monaco (correspondent banking, international transfers, client files)? Are there any unusual blockages or delays in the processing of transactions, account openings or cross-border operations? Has access to financing or credit been affected for some businesses?

Monaco's inclusion on the EU Grey List de facto triggers enhanced due diligence measures by European financial institutions, which may lead to delays in certain banking transactions.  It is important to remember that the Principality of Monaco is part of the SEPA zone, which stipulates that euro transactions (transfers and direct debits) are processed uniformly with other European Union countries.  Nevertheless, some difficulties have been identified, which the government is working to resolve.

By Milena Radoman - Monaco Economie

*Regarding the register of BEs, Sovereign Ordinance No 2.318 of 3 August 2009, as amended, defines in particular the access procedures for various competent authorities within the framework of their missions in matters of AML/CFT-P-C but also for the bodies and persons referred to in Articles 1 and 2 of Law No 1.362 of 3 August 2009, as amended, within the framework of the implementation of their due diligence obligations.

Regarding the register of trusts, Sovereign Ordinance No 8.635 of  29 April 2021, as amended, sets out the access procedures for various competent authorities within the framework of their AML/CFT-P&I missions, for the bodies and persons referred to in Articles 1 and 2 of Law No 1.362 of 3 August 2009, as amended, within the framework of implementing their due diligence obligations, or for persons demonstrating a legitimate interest.