Tiphaine Duplantier
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
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
Sovereign Ordinance No. 11.639 of 27 November 2025, enforcing the Addendum to the Multilateral Competent Authority Agreement on the Automatic Exchange of Financial Account Information, was published in the Journal de Monaco on 5 December 2025. This Sovereign Ordinance confirms the entry into force of the new reporting obligations under the CRS as from 1 January 2026. Accordingly, the … Read more
Phoenix Compliance Essentials #13 Today’s focus: gatekeepers – key players or the weak link in AML/CFT-P-C? What if intermediary professionals found themselves at the heart of money laundering schemes? Depending on their practices, these professionals may knowingly or unknowingly contribute to the introduction of illicit funds into the financial system. Their role is therefore central. … Read more
