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 the implementation of enhanced due diligence measures.
👉 Cash payments of EUR 30,000 or more, carried out in one or several transactions over a six-calendar-month period, are prohibited.
These thresholds provide important reference points for regulated entities. However, they are not sufficient on their own to determine the level of risk associated with a transaction.
Even below these thresholds, a cash payment may present a risk where it forms part of an unusual pattern, such as structuring, inconsistencies or incompatibility with the customer’s profile.
Contextual analysis therefore remains essential.
2️⃣ AML/CFT-P-C challenges
Limited traceability, ease of structuring (smurfing) and concealment of the origin of funds: cash transactions are frequently associated with money laundering, tax fraud and terrorist financing.
In practice, structuring remains one of the most recurrent vulnerabilities identified in AML/CFT-P-C control frameworks.
3️⃣ Due diligence and obligations of regulated entities
From EUR 10,000 (including multiple transactions): enhanced due diligence and an assessment of the consistency, frequency and structuring of the transactions.
In the event of serious doubts: refusal to carry out the transaction and submission of a suspicious transaction report.
Proportionate, effective and properly documented measures are essential to ensure compliance and manage both regulatory and reputational risks.
4️⃣ Case study: the Louis Vuitton case
In July 2025, a criminal investigation was opened in the Netherlands into the Dutch subsidiary of Louis Vuitton over suspicions of money laundering linked to cash payments.
The alleged facts concern:
– Repeated purchases of luxury goods paid for in cash below the EUR 10,000 threshold;
– Shipments to China/Hong Kong;
– Failure to report despite apparent risk indicators.
⚠️ This case is currently under investigation and has not resulted in any judicial decision. The presumption of innocence fully applies.
👉 Nevertheless, from an AML/CFT-P-C compliance perspective, it illustrates:
– Structuring as a red flag;
– Potential deficiencies in due diligence procedures;
– The risk of internal complicity;
– Significant reputational risk.
