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 of the Congo
- Haiti
- Islamic Republic of Iran
- Ivory Coast
- Kenya
- Kuwait
- Democratic People’s Republic of Korea
- Lao People’s Democratic Republic
- Lebanon
- Myanmar/Burma
- Namibia
- Nepal
- Papua New Guinea
- Russian Federation
- South Sudan
- Syria
- Republic of Trinidad and Tobago
- Vanuatu
- Venezuela
- Vietnam
- Yemen
As a reminder, the obligations relating to HRSTs are as follows:
When a transaction involves a counterparty with links to an HRST, a “examen particulier” report must be drawn up and kept (cf. article 14 of law no. 1.362 as amended);
When a business relationship or transaction involves an HRST, enhanced due diligence measures must be put in place (cf. article 14-2 of law no. 1.362 as amended).
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