20/03/2025

Compliance Essentials #2 – The inspections conducted by the AMSF (formerly SICCFIN) in Monaco

Phoenix Essentials #2

 

Today’s Focus: Strengthening AML/CFT-P-C Supervision in Monaco

 

The AMSF’s 2023 Annual Report (formerly SICCFIN) highlights the Authority’s increased supervisory efforts and enhanced controls under Law No. 1.362, reflecting Monaco’s ongoing commitment to addressing growing AML/CFT-P-C challenges.

 

Two types of inspections:

 

  • Document-based inspections : these inspections focus on three mandatory documents that reporting entities must submit to the AMSF:
    1. Internal AML/CFT-P-C procedures and policies;
    2. Annual activity reports;
    3. Annual STRIX questionnaires.
  • On-site inspections: these inspections assess the effective implementation of AML/CFT-P-C frameworks and include the review of customer files and compliance practices.

What has changed since 2023?

 

  • More diversified and targeted supervision: in addition to inspections focused on internal control frameworks, the AMSF has strengthened its supervisory approach through thematic inspections, focusing on specific regulatory obligations and ad hoc inspections, initiated when a potential risk is identified, for example following publicly available information or the submission of a suspicious transaction report.
  • A new forum for dialogue: the AMSF has introduced Risk and Compliance Meetings, during which reporting entities present their compliance framework, the resources deployed, and discuss challenges encountered in implementing their AML/CFT-P-C arrangements.
  • Enhanced risk-based supervision: through the STRIX platform, the AMSF is able to refine its risk analysis and focus supervisory efforts on sectors that are considered most exposed to money laundering, terrorist financing, and proliferation financing risks.

Source: The information presented above is drawn from the AMSF 2023 Annual Report, available here: https://lnkd.in/dJFvDsK5