Monaco's AML authority, the AMSF, has published the eight presentation decks from the first edition of Les Rencontres de la Conformité
Amsf, its new compliance meeting with the private sector. The decks set out how the authority supervises, sanctions and supports obliged entities, and what it expects from suspicious-transaction reporting and the goAML portal.
On sanctions, the enforcement arm reports 803 mises en demeure in 2025Amsf — 545 against entities that had never sent internal control proceduresAmsf and 258 against STRIX non-respondents — followed by 166 sanctionsAmsf, with 80% regularizationAmsf. In 2026, 148 concerned two failings: failure to designate the LCB/FT-P-C officer (58) and STRIX non-response (90, down from 258)Amsf. Of 35 control reports, 24 ended in non-saisine with recommendations (69%)Amsf and 11 in sanction proceedings (31%)Amsf, covering 14 financial and 21 non-financial institutionsAmsf. Recurrent grievances are a risk assessment disconnected from the actual clientele, defective identification — two identity documents for remote onboarding of natural persons, incomplete beneficial-owner identification in complex structures — background and origin of funds resting on bare client declarations, missing PPE frameworks, monitoring systems with no discriminating alert criteria, and late reports. The sanctions deck recalls the quantum it presents as articles 65-8 and 66 of loi n° 1.362: a pecuniary penalty of up to one million euros or 10% of annual turnover excluding tax, whichever is higher, for financial institutionsAmsf, rising to 10 million euros for financial institutionsAmsf, with nominative publication as the principle subject to two narrow exceptions — an ongoing criminal investigation or a verified disproportionate harmAmsf — and weighing of gravity, frequency, duration, prior breaches and the financial situation.
On supervision, the Service de Supervision counts 25 agents, up from 16 at end-2024Amsf, of whom 17 staff the two on-site control divisionsAmsf covering financial institutions and non-financial establishments and professionsAmsf; missions rose from 22 in 2023Amsf to 54 in 2025Amsf. Planning follows a risk-based approach built on the national risk assessment and information held on entities, including STRIX returns, activity reports, internal procedures and prior controls. Controls are presented as non-punitive: every mission ends in personalised follow-up on corrective actions annexed to the mission report, and entities owe transparency and diligence.
On reporting, the financial intelligence unit received 1,479 déclarations de soupçon in 2025Amsf — 901 financial, 578 non-financialAmsf — against 653 in 2020Amsf. Of 3,965 forms transmitted, 3,060 were validatedAmsf and 905 rejectedAmsf; 530 feedback reports went outAmsf and 19 entities were received by the CRFAmsf. goAML went live on 1 January 2024Amsf, and a four-person data-quality section now applies a two-level check — admissibility, then data enrichment — with monthly feedback to each reporting entity. A valid report's statement of grounds must cover entry into relationship, operation of the relationship and accounts, the account of the suspicion and its analysisAmsf; attachments are capped at 50 files and 33 megabytesAmsf, and where the CRF exercises its right of opposition, notified in writing via goAML messaging, the opposition blocks any transaction for at most five business days from notification
Legimonaco.
On proliferation financing and cyber-fraud, the strategic-analysis report presents dual-use goods listed exhaustively in Annexe I of règlement (UE) 2021/821Amsf, typologies such as maritime transport of dual-use goods and concealment of a sanctioned beneficiary, and indicators including document fraud, shell companies and transactions inconsistent with the client's activity; proliferation cases get priority treatment via the PFTR/PFAR forms. On cyber-enabled fraud, Monaco's CRF applies the Egmont Group's CEF rapid-response protocol since 2024Amsf, with a Direction de la Sûreté Publique partnership from March 2025 for fast cross-FIU information gathering, opposition and repatriation; business-email compromise accounts for 58% of identified fraudsAmsf and phishing for 30%Amsf.
On tools, goAML access is restricted to Monaco-geolocated IP addressesAmsf, with prior authorisation via contact@amsf.mc from abroadAmsf. Version 5.5.9 restores two-factor authenticationAmsf and fixes IBAN validation; 5.6 adds duplicate-attachment detectionAmsf and direct correction of rejected XML reports in web formsAmsf. A B2B interface linking internal systems to goAML Web is piloted before general opening, and the 2027 STRIX campaign moves toward mandatory completeness, with formal notices sent at campaign endAmsf. The decks also clarify that the 10,000-euro cash threshold in the Lignes Directrices Génériques of 21 April 2026 is a risk indicator, not an automatic trigger of enhanced vigilance under articles 3 and 35 of loi n° 1.362Amsf, and that listing an activity covered by articles 1 and 2 in the objet social suffices for subjection, whatever the predominant activity.
Legal basis: the sanctions deck cites loi n° 1.362 du 3 août 2009, articles 65-8 and 66, and the strategic-analysis deck cites règlement (UE) 2021/821, Annexe I, for the exhaustive dual-use goods list.
Download the eight Rencontres de la Conformité decks from the AMSF Sessions d'informations page and align internal control, reporting and goAML setups with the checklists they detail.
