Tiphaine Duplantier
Phoenix Compliance Essentials #19 Today’s focus: lines of defence within the AML/CFT-P-C framework Compliance is not only about having procedures in place, but also about how they are implemented. The lines of defence provide the structure for that implementation. ➡️ What are the lines of defence? A line of defence represents a level of responsibility … Read more
Phoenix Data Protection Essentials #2 Today’s focus: the risks and penalties for non-compliance with Law No. 1.565 Non-compliance with personal data protection requirements goes far beyond the issue of regulatory penalties. It represents a cross-cutting risk that may affect the organisation as a whole. 1️⃣ The risks 👉 Reputational risk … 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 Data Protection Essentials #1 Today’s focus: GDPR and Law No. 1.565 – common inspiration, distinct approaches Monaco’s law on personal data protection is often presented as a “local GDPR”. In practice, however, certain differences must be taken into account by Monaco-based businesses. 1️⃣ Purpose of the frameworks 👉 GDPR: to harmonise the rules and enable … 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
