Monaco placed on the FATF “gray list”: The Princely Government commits to exiting the list

In January 2023, the Council of Europe’s anti-money laundering body, Moneyval, indicated to Monaco that “fundamental improvements” were warranted to enhance the effectiveness of supervision, investigations, prosecutions of money laundering, and the confiscation of crime proceeds, as well as in the fight against terrorist financing.

In response, Monaco’s parliament has since enacted nine new laws to bolster the Monegasque Financial Security Authority (AMSF) and the anti-money laundering legal framework. These measures have increased the capabilities for detecting and investigating terrorist financing and introduced targeted financial sanctions and risk-based supervision of non-profit organizations.

As indicated by the FATF (see official statement of the Financial Action Task Force below), Monaco has now, in 2024, been placed under increased monitoring. The FATF’s statement acknowledged the significant progress made by the Principality on several actions recommended by MONEYVAL in January of last year.

In particular, the statement highlights the strengthening of measures to combat terrorist financing, the creation of a new financial intelligence and oversight authority, the implementation of targeted financial sanctions, and risk-based supervision of associations.

A schedule has been set, extending over one and a half years (until January 2026), with two intermediate checkpoints (May 2025, September 2025). The Principality confirms its determination to implement the remaining FATF recommendations outlined in the statement, in accordance with the agreed deadlines.

FATF Statement

In June 2024, Monaco made a high-level political commitment to work with the FATF and MONEYVAL to enhance the effectiveness of its AML/CFT regime (anti-money laundering and combating the financing of terrorism). Since the adoption of its mutual evaluation report (MER) in December 2022, Monaco has made significant progress on several actions recommended by the MER, including creating a new financial intelligence unit (FIU) and AML/CFT controller, strengthening its approach to detecting and investigating terrorist financing, implementing targeted financial sanctions, and conducting risk-based supervision of non-profit organizations.

Monaco will continue to collaborate with the FATF to implement its action plan by:
1. Enhancing the understanding of risks related to money laundering and tax fraud committed abroad;
2. Demonstrating a sustained increase in outgoing requests aimed at identifying and seizing criminal assets abroad;
3. Improving the enforcement of sanctions for AML/CFT violations and breaches of basic and beneficial ownership requirements;
4. Completing its resource program for its FIU and enhancing the quality and speed of suspicious transaction reporting;
5. Improving judicial effectiveness, particularly by increasing the resources of investigative judges and prosecutors, and imposing effective, dissuasive, and proportionate sanctions for money laundering;
6. Increasing the seizure of assets suspected of being derived from criminal activities.