Tiphaine Duplantier
As part of our regulatory monitoring efforts and our support for professionals in compliance matters, we hosted a webinar on May 5 dedicated to presenting our analysis of the new version of the AMSF’s General Guidelines. This session provided an opportunity to review the key changes, key points of attention, and the practical implications for … Read more
We would like to inform you that the AMSF has published a new version of its General Guidelines. This V.2 version provides important clarifications and further guidance on the Authority’s expectations, particularly regarding compliance frameworks and due diligence requirements. Taking these updates into account is essential to ensure that your practices remain aligned with regulatory expectations. We encourage you to review them: … Read more
Phoenix Compliance Essentials #18 Today’s focus: KYC and Artificial Intelligence AI is reshaping operational practices across many sectors.AML/CFT-P-C frameworks are no exception.This transformation is two-sided: AI enhances KYC processes but also makes them easier to circumvent.Deepfakes and forged documents are becoming tools for gaining access to business relationships. ➡️ How do deepfakes threaten KYC frameworks? … Read more
Ministerial Decree no. 2026-126 of March 13, 2026, published in the Journal de Monaco on March 20, 2026, updates the list of HRSTs. Main changes to the list of High-Risk States or Territories (HRST): The list now includes 28 States. 2 States have been added to the list: Afghanistan Algeria Angola Bolivia British Virgin Islands Bulgaria Cameroon Democratic Republic … Read more
Phoenix Compliance Essentials #17 Today’s focus: the STRIX questionnaire ➡️ A key annual regulatory requirement The STRIX questionnaire is a mandatory requirement for entities subject to Articles 1 and 2 of amended Law No. 1.362. It takes the form of a detailed online questionnaire to be completed as part of the sectoral campaigns organised by … Read more
Ministerial Decree no. 2026‑72 of February 18, 2026, published in the Journal de Monaco on February 20, 2026, updates the list of HRSTs. Main changes to the list of High-Risk States or Territories (HRST): The list now includes 26 States. 1 State has been added and 6 States have been removed from the list: Afghanistan Algeria Angola Bolivia British Virgin Islands Bulgaria … Read more
Phoenix Compliance Essentials #16 Today’s focus: cash payments, when complying with thresholds is no longer enough in AML/CFT-P-C. In Monaco, cash payments are permitted but represent a high-risk factor from an AML/CFT-P-C perspective. 1️⃣ Applicable regulatory framework 👉 Any cash transaction of EUR 10,000 or more, including where it is structured into multiple transactions, requires … Read more
Phoenix Compliance Essentials #15 Today’s focus: “smurfing”, a money laundering method still widely used today. ➡️ What is it? Smurfing is one of the money laundering methods described in international ML/FT-P-C typologies. It consists of breaking down illicit funds into multiple transactions carried out by several coordinated accomplices, known as “smurfs”, in order to remain … Read more
Ministerial Decree No. 2025-665 of December 5, 2025, published in the Journal de Monaco on December 19, 2025, updates the lists of reporting jurisdictions and partners applicable to the Automatic Exchange of Information (AEOI). In summary, three new jurisdictions are now subject to reporting and partnership requirements: Uganda, Rwanda, Senegal. These jurisdictions will be subject … Read more
Phoenix Compliance Essentials #14 Today’s focus: ML/FT-P-C risks in the yachting sector An attractive industry, high-value transactions and international stakeholders: the yachting sector is particularly exposed to ML/FT-P-C risks. ➡️ A structurally exposed sector: In Monaco, the yachting sector is subject to AML/CFT-P-C obligations. Several factors explain its increased exposure to ML/FT-P-C risks: – The … Read more
