06/12/2023

Publications

Ministerial Order n°2023-680 of 22 November 2023, published in the Journal de Monaco on 1 December 2023, updates the list of states or territories whose anti-money laundering, terrorist financing or corruption system have strategic deficiencies.

This publication amends the Ministerial Order n°2023-413 of 7 July 2023.

As a reminder, the obligations related to HRST are as follows:

  • When a transaction involves a counterparty with links to an HRST, a special review report must be prepared and kept (article 14 of the amended law no. 1.362);
  • When a business relationship or transaction involves an HRST, it is necessary to implement enhanced due diligence measures (see article 14-2 of the amended law n°1.362)

The list now includes 28 states. 1 state has been added and 5 states have been removed:

AfghanistanMozambique
South AfricaMyanmar/Burma
AlbanieNigeria
BarbadosUganda
BulgariaPanama
Burkina FasoPhilippines
CambodiaDemocratic Republic of the Congo
CamerounSenegal
CroatiaSouth Sudan
United Arab EmiratesSyria
GibraltarTanzania
HaitiTrinidad and Tobago
Cayman IslandsTurkey
JamaicaVanuatu
JordanVietnam
MaliYemen
Marocco