AMSF posts first compliance-meeting decks: sanctions, supervision, goAML

Monaco's Autorité Monégasque de Sécurité Financière has published the presentation decks from the first edition of Les Rencontres de la Conformité, its compliance meeting with the private sector. The Sessions d'informations page now lists eight newly diffused decksAmsf alongside the June 2025 information-session materials: resources for the private sector, the company-objects question, the STRIX campaign, on-site control missions, sanctions-analysis feedback, goAML, DES quality and deadlines, and the strategic-analysis report with a cyber-fraud section.

The decks explain how the authority supervises, sanctions and supports obliged entities. Supervision runs on a risk-based footing: the supervision service builds entity and sector risk profiles from the annual STRIX questionnaireAmsf, which entities under article 1 and chiffres 1°) and 2°) of article 2 of loi n° 1.362 answer online within the set deadlineAmsf. Non-submission alone constitutes the breach punished under point 10°) of article 64-7Amsf — a pecuniary sanction of up to 5,000 eurosAmsf, doubled on repeat offendingAmsf — after formal notice reopens the questionnaire for 28 daysAmsf. The supervision service maps sector risks from STRIX data to sharpen its control plansAmsf, and the entity's national-risk-assessment-based risk evaluation feeds the same risk-based approach. A control ends with a report presenting the mission's conclusions and the entity's remarks in annexes; follow-up on the corrective actions runs through a separate suivi procedureAmsf — written report, follow-up risk-and-compliance meeting, desk-based or on-site follow-up control — closed once the recommendations are in place.

On sanctions, serious, repeated or systematic breaches of the law's duties can draw an administrative sanction from the Minister of State on the commission's proposalLegimonaco, from a warning up to suspension or withdrawal of authorisationLegimonaco, plus a pecuniary penalty capped at one million euros or twice the advantage gained where that can be determinedLegimonaco. For chiffres 1°) to 4°) of article 1, the pecuniary cap is the higher of five million euros and ten per cent of total annual turnoverLegimonaco. The Minister weighs gravity, frequency, duration, prior breaches, cooperation, harm to third parties and the financial situation, and may publish the decision, anonymously only where non-anonymous publication would compromise an ongoing criminal investigation or cause disproportionate harmLegimonaco.

On reporting, entities report to the financial intelligence unit the sums, operations and attempted operations they know, suspect or reasonably suspect to derive from a predicate offence or to finance terrorism or corruptionAmsf, in writing before executionLegimonaco. Since 1 January 2024 those declarations travel through goAMLAmsf, whose manuals, technical and functional FAQ and transmission notice the AMSF publishes on its suspicious-reporting pageAmsf. For the declaration itself, the law requires a written report before execution setting out the facts and indices behind it, with any later information passed onLegimonaco; since 1 January 2024 transmission runs through goAML under the AMSF transmission noticeAmsf, with the user manual, FAQ and webinar supports published on the reporting page.

On cash, the decks recall the article 35 frame: professional dealers in goods or services may neither make nor receive cash payments of 30,000 euros or more in totalLegimonaco, and from 10,000 euros they apply the vigilance measures of Chapter II Section I or article 14 according to the client's risk levelLegimonaco — each measured over one or several seemingly linked operations across six calendar monthsLegimonaco. The general guidelines restate the same thresholds: strictly prohibited at or above 30,000 euros over a rolling six monthsAmsf, permitted with risk assessment, reinforced vigilance or a special examination from 10,000 eurosAmsf, with a chronological cash-operations record policing the cumulative totalAmsf.

Legal basis: the page's decks restate duties from loi n° 1.362 du 3 août 2009Amsf — cash-payment limits, suspicious-transaction reporting, the STRIX questionnaire duty and the administrative-sanctions chapter.