Ministerial Order no. 2023-680 of April 15, 2024, published in Monaco’s Journal de Monaco on April 19, 2024, updates the list of countries or territories whose anti-money laundering, anti-terrorist financing or anti-corruption measures are strategically deficient.
This publication amends Ministerial Order no. 2021-703 of November 8, 2021, amended on November 22, 2023.
As a reminder, the obligations relating to ETHR are as follows:
When a transaction involves a counterparty with links to an ETHR, a special examination report must be drawn up and kept (article 14 of the amended law n°1.362) ;
When a business relationship or transaction involves an ETHR, enhanced due diligence measures must be put in place (cf. article 14-2 of law no. 1.362 as amended).
The list currently comprises 30 countries. 2 States have been added.
| Afghanistan | Namibia |
| South Africa | Myanmar/Burma |
| Barbados | Nigeria |
| Bulgaria | Uganda |
| Burkina Faso | Panama |
| Cameroon | Philippines |
| Croatia | Senegal |
| United Arab Emirates | South Sudan |
| Gibraltar | Syria |
| Haiti | Tanzania |
| Democratic Republic of Congo | Trinidad and Tobago |
| Jamaica | Turkey |
| Kenya | Vanuatu |
| Mali | Vietnam |
| Mozambique | Yemen |
The United Arab Emirates, Barbados, Gibraltar and Uganda have been removed from the Financial Action Task Force (FATF) grey list. However, Monaco has decided to maintain their ETHR status, as they remain on the European Union list.