Phoenix Compliance Essentials #3
Focus of the Day: Sanctions in Monaco
After exploring the inspections carried out by the AMSF in a previous post, today we turn to another key aspect of its supervisory role: sanctions.
The main developments regarding sanctions, introduced by the regulatory changes of 30 September 2023, are as follows:
- A supervisory authority with direct decision-making powers
Unlike its predecessor, SICCFIN, which was required to refer cases to the Commission for the Review of Inspection Reports (CERC), the AMSF now has the authority to rule directly on alleged breaches and impose administrative sanctions.
- A dedicated sanctions department
Sanctions are now issued by a dedicated unit within the AMSF, which includes, among others, a magistrate with at least five years of judicial experience within the Monegasque court system.
- More severe sanctions since September 2023
The amendments to Monaco’s AML/CFT/CPF framework have significantly strengthened the sanctions regime itself, with higher penalties, a broader scope of application, and therefore a greater deterrent effect.
Source: The information presented above is derived from the AMSF 2023 Annual Report (https://lnkd.in/dJFvDsK5) and from the Prince’s Government of Monaco: Details of sanctions imposed by the Minister of State based on the opinions issued by the Commission for the Review of Inspection Reports (CERC).
