Is Crypto Legal in Monaco?
Cryptocurrency is legal but only partially regulated in Monaco. The jurisdiction has a partial framework with significant gaps remaining, and an active legislative process underway. EU Council is among the 5 regulators with oversight. Primary legislation: Law No. 1.383, 2018.
Derived from 344 sourced facts for Monaco · last updated · primary sources
Overview
Monaco regulates virtual asset service providers — including exchanges and custody providers — under its existing AML/CFT framework anchored in Law No. 1.362 of July 8, 2009, as amended, and Sovereign Ordinance No. 8.604 of November 17, 2021, with registration triggered by activities such as fiat-to-crypto exchange and virtual asset custody. The primary authority is SICCFIN, Monaco's FIU, which requires AML/CFT registration, a risk-based compliance program, suspicious transaction reporting, and a minimum five-year record retention period, while CCAF becomes relevant where virtual asset activities overlap with regulated financial services. Securities-classified tokens may draw additional CCAF oversight, making asset classification a critical threshold determination before structuring operations in Monaco.
Regulatory Bodies
Implementation: EU restrictive measures (sanctions) are typically adopted by Monaco through Sovereign Ordinances or Ministerial Decrees, which reference the specific EU Council Regulations.
MONEYVAL Reports: Monaco is regularly assessed by MONEYVAL (Council of Europe's Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism).
Compliance: As a UN member state, Monaco is legally bound to implement all sanctions imposed by the United Nations Security Council (UNSC) under Chapter VII of the UN Charter.
Legal Reference: UN Security Council Resolutions (e.g., those establishing sanctions committees like ISIL (Da'esh) and Al-Qaida Sanctions Committee) are implemented via Monaco's legal framework.
OFAC Sanctions Lists: Primarily the SDN List, but also other lists relevant to specific programs (e.g., SSI List, Non-SDN Palestinian Legislative Council List).
Operating Models
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AI · UnreviewedPrimary Legislation
| Law / Regulation | Year | Scope |
|---|---|---|
| Law No. 1.383, 2018 | 2018 | Monaco has a dedicated DLT framework (Law No. 1.383, 2018) and a DASP licensing regime (Law No. 1.491, 2020) overseen by the Autorité Monégasque de Sécurité Financière (AMSF), Commission de Contrôle des Activités Financières (CCAF), and… |
| Law No. 1.491 (2020) | 2020 | Law No. 1.491 (2020) — DASP Licensing: Creates mandatory licensing for four DASP activity classes: (1) exchange virtual asset/fiat, (2) exchange virtual asset/virtual asset, (3) custody/administration, (4) transfer/execution/portfolio… |
| Regulation 2023/1114 | 2024 | EU MiCA/TFR Transposition: Sovereign Ordinance No. 9.412 (2024) and AMSF Circular No. 2024-01 align Monaco with EU MiCA (Regulation 2023/1114) and Transfer of Funds Regulation (2023/1113) for CASP equivalence; transition period ends 30 Dec… |
| Law 1.491 Art. 3 | DASP License Classes (Law 1.491 Art. 3): Class 1 — Exchange virtual asset/fiat; Class 2 — Exchange virtual asset/virtual asset; Class 3 — Custody/administration of virtual assets; Class 4 — Transfer, execution, portfolio management,… | |
| Law 1.491 Art. 5 | Minimum Capital (Law 1.491 Art. 5): €125,000 fully paid-up share capital at application; comparable to EU MiCA Class 2 CASP requirement (€125k–€150k). | |
| Law 1.491 Arts. 18–22 | AMSF Sanctions Powers (Law 1.491 Arts. 18–22): Warning, injunction, periodic penalty payments (up to €50,000/day), suspension/limitation of activities, license withdrawal, publication of sanctions. | |
| Sovereign Ordinance draft 2024 | 2042 | Reporting: Annual declaration of crypto holdings >€50,000 for residents (form 2042-C); DAC8/CARF transposition pending (Sovereign Ordinance draft 2024) will impose automatic exchange of crypto-account data with EU/OECD partners from 2026. |
| Sovereign Ordinance 9.412 | 2024 | MiCA Transition Uncertainty: Monaco's MiCA-equivalence regime (Sovereign Ordinance 9.412) requires existing DASPs to apply for re-authorization by 30 Dec 2024; no grandfathering. |
| Law No. 1.383 (2018) on DLT/Token Offerings | 2018 | Law No. 1.383 (2018) on DLT/Token Offerings — Journal de Monaco No. 8421, 20 July 2018 |
| Law No. 1.491 (2020) on DASP Licensing | 2020 | Law No. 1.491 (2020) on DASP Licensing — Journal de Monaco No. 8592, 17 July 2020 |
| Sovereign Ordinance No. 9.062 (2021) implementing Law 1.491 | 2021 | Sovereign Ordinance No. 9.062 (2021) implementing Law 1.491 — Journal de Monaco No. 8645 |
| Sovereign Ordinance No. 9.412 (2024) on MiCA/TFR Transposition | 2024 | Sovereign Ordinance No. 9.412 (2024) on MiCA/TFR Transposition — Journal de Monaco No. 8785 |
| Sovereign Ordinance No. 8.828 (2019) on SICCFIN Organization | 2019 | Sovereign Ordinance No. 8.828 (2019) on SICCFIN Organization |
| Law No. 1.338 (2007) on Investment Services | 2007 | Law No. 1.338 (2007) on Investment Services |
Licensing Requirements
No verified facts yet. 42 unverified fact(s) in explorer
AML/KYC Requirements
Service d'Information et de Contrôle sur les Circuits Financiers (SICCFIN): This is Monaco's Financial Intelligence Unit (FIU) and the primary administrative authority responsible for combating money laundering, terrorist financing, and corruption. It supervises AML/CFT compliance for all financial sectors, including virtual assets.
Monaco's specific regulatory framework for Virtual Asset Service Providers (VASPs) is not yet in place; the government has announced plans to introduce a new crypto framework by the end of 2026 to address gaps in its anti-money laundering regime.
Law No. 1.516 of 23 December 2021 on virtual assets, as amended by Law No. 1.575 of 17 June 2025
Enforcement in Monaco includes highly publicized, large-scale fines against specific entities, such as the €6 million fine imposed on UBS for compliance failures, alongside administrative warnings, corrective orders, or private settlements.
Monégasque authorities do publicize individual enforcement actions, as shown by the public disclosure of a €6 million fine against UBS for anti-money laundering failures, including details of specific violations like a 253-day delayed report.
Commission de Contrôle des Activités Financières (CCAF): The CCAF supervises all financial activities in the Principality, including the authorization and ongoing supervision of financial institutions and now, in consultation, VASPs.
SICCFIN Annual Reports: These reports provide aggregated statistics on suspicious activity reports, controls, and general trends, but typically do not name specific entities subject to enforcement or provide details of penalties.
Example Report (latest available provides context for 2022 activities): https://www.siccfin.mc/wp-content/uploads/2023/07/Rapport_annuel_2022_SICCFIN.pdf (in French)
Sovereign Ordinance No. 9.206 of 7 March 2022 (Ordonnance Souveraine n° 9.206 du 07/03/2022 portant application de la loi n° 1.516 sur les actifs virtuels): https://legimonaco.mc/305/legismclois.nsf/baf3e32b6183e874c125785000350d26/8966c8b9d997f37bc12587e60049ce41?OpenDocument (in French)
MONEYVAL Reports: Monaco is regularly assessed by MONEYVAL (Council of Europe's Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism). These reports provide an overview of Monaco's AML/CFT framework and its effectiveness, including for virtual assets.
Example (latest follow-up report for Monaco, Oct 2023): https://www.coe.int/en/web/moneyval/-/moneyval-publishes-a-follow-up-report-on-monaco
Loi n° 1.482 du 17 décembre 2019 relative aux actifs numériques (Law No. 1.482 of December 17, 2019 on Digital Assets): This law defines digital assets, regulates initial coin offerings (ICOs), and requires VASPs to obtain authorization from the Commission de Contrôle des Activités Financières (CCAF).
Sovereign Ordinances and Ministerial Decrees: These instruments detail the implementation of international sanctions regimes (UN, EU) into Monegasque law.
Compliance: As a UN member state, Monaco is legally bound to implement all sanctions imposed by the United Nations Security Council (UNSC) under Chapter VII of the UN Charter. These sanctions are primarily focused on terrorism, proliferation of weapons of mass destruction, and specific regimes/individuals.
Implementation: UN sanctions are typically transposed into Monegasque law through Sovereign Ordinances, making them directly applicable and enforceable within the Principality.
Legal Reference: UN Security Council Resolutions (e.g., those establishing sanctions committees like ISIL (Da'esh) and Al-Qaida Sanctions Committee) are implemented via Monaco's legal framework. An example of Monaco's implementing legislation would be a Sovereign Ordinance specifically referring to a UNSC resolution.
Compliance: While Monaco is not an EU member state, it has a close relationship with the EU and typically transposes or mirrors EU sanctions regulations into its national law, especially those concerning financial activities. This ensures alignment with its major economic partners and maintains its reputation as a sound financial center.
Implementation: EU restrictive measures (sanctions) are typically adopted by Monaco through Sovereign Ordinances or Ministerial Decrees, which reference the specific EU Council Regulations. This makes them legally binding within Monaco.
Asset Freezes: Freezing funds and economic resources of designated individuals and entities (persons, groups, entities).
Prohibition on Making Funds Available: Not making funds or economic resources directly or indirectly available to or for the benefit of designated persons.
Specific Sectoral Sanctions: Adhering to restrictions on certain goods, services, or technologies (e.g., dual-use goods, luxury items, financial services, crypto-asset services for specific regions like Russia).
Travel Bans: Though less directly applicable to VASPs, these often accompany financial sanctions.
General reference for EU sanctions: EUR-Lex database (https://eur-lex.europa.eu/) for Council Regulations.
Monaco's implementation: Search the Journal de Monaco (https://journaldemonaco.gouv.mc/) for Sovereign Ordinances related to specific restrictive measures.
Compliance: The US Office of Foreign Assets Control (OFAC) sanctions are extra-territorial. While Monaco does not have a legal obligation to enforce OFAC sanctions directly through its national law, any Monegasque VASP that:
Deals with US persons (citizens, residents, entities).
Uses US financial institutions or payment processors.
Facilitates transactions involving US-origin technology or services.
Requirements for VASPs: VASPs must screen all their customers and transactions against OFAC's various sanctions lists, particularly the Specially Designated Nationals and Blocked Persons (SDN) List. They must also be aware of sectoral sanctions (e.g., Russia-related SSI List) and broader country-based sanctions programs.
Legal Reference: U.S. Treasury Department, Office of Foreign Assets Control (OFAC) website (https://ofac.treasury.gov/).
Initial Onboarding: Before establishing any business relationship.
Ongoing Monitoring: Regularly throughout the business relationship, particularly when lists are updated.
Per-Transaction Screening: For higher-risk transactions or for specific geographic areas.
UN Sanctions Lists: Consolidated lists published by the UN Security Council Sanctions Committees.
EU Sanctions Lists: The consolidated list of persons, groups, and entities subject to EU financial sanctions.
OFAC Sanctions Lists: Primarily the SDN List, but also other lists relevant to specific programs (e.g., SSI List, Non-SDN Palestinian Legislative Council List).
Domestic Lists (if applicable): Any specific lists published by SICCFIN or other Monegasque authorities.
Prohibition on Services: VASPs cannot offer services (e.g., exchange, custody, transfer) to individuals or entities located in, or ordinarily resident in, comprehensively sanctioned jurisdictions (e.g., Cuba, Iran, North Korea, Syria under OFAC; specific regions under EU sanctions like Crimea, Donetsk, Luhansk).
Heightened Due Diligence: Transactions involving high-risk jurisdictions or jurisdictions under specific sanctions programs (even if not comprehensive bans) require enhanced due diligence and scrutiny.
Origin/Destination of Funds: VASPs must identify the origin and destination of virtual assets to ensure they are not directly or indirectly linked to sanctioned entities or regions.
IP Address Blocking: Implementing technical controls like IP blocking for regions subject to comprehensive sanctions can be part of a robust compliance program.
Fines: Significant monetary fines, which can be substantial and proportionate to the seriousness of the breach.
Temporary or Permanent Suspension: Suspension or revocation of operating licenses or authorization for VASPs.
Specific Injunctions: Orders to implement specific corrective measures.
Imprisonment: Individuals (e.g., compliance officers, directors) found responsible for serious violations, especially those involving intentional breaches or gross negligence, can face terms of imprisonment.
Criminal Fines: Substantial fines imposed by the judiciary.
Reputational Damage: Significant damage to the VASP's reputation, making it difficult to operate or secure banking relationships.
Loss of License: Permanent revocation of authorization.
Loi n° 1.362 du 3 août 2009 sur la lutte contre le blanchiment de capitaux, le financement du terrorisme et la corruption (as amended), Titre VI (Sanctions). Specific articles within this title detail the administrative and criminal penalties.
Monaco's implementation of UN Lists: The consolidated list of individuals and entities designated by UN Security Council sanctions committees.
Monaco's implementation of EU Lists: The consolidated list of persons, groups, and entities subject to EU restrictive measures.
No separate "Monaco Sanctions List" for crypto: VASPs will primarily be concerned with ensuring their compliance programs correctly integrate and screen against the international lists that Monaco has legally adopted.
Comprehensive screening against UN, EU (as transposed by Monaco), and OFAC sanctions lists.
Due diligence on all customers and transactions.
Understanding and adherence to geographic restrictions.
Procedures for asset freezing and reporting of hits or suspicious activities to SICCFIN.
Regular updates to screening systems and policies to reflect changes in sanctions regimes.
Role: The primary body responsible for approving and supervising Digital Asset Offerings (DAOs) under Law No. 1.492. It ensures compliance with the requirements for transparency, investor protection, and market integrity related to these public offerings.
Role: Monaco's Financial Intelligence Unit (FIU), responsible for enforcing anti-money laundering and counter-terrorist financing (AML/CTF) regulations across all financial sectors, including virtual assets. Virtual asset service providers (VASPs) are subject to SICCFIN's oversight regarding their AML/CTF obligations.
Law No. 1.492 of July 8, 2020 on virtual assets:
Purpose: This is the foundational law for virtual assets in Monaco. It defines "virtual assets" and "Digital Asset Offerings (DAOs)," establishing a framework for their issuance. It sets out the conditions and procedures for obtaining authorization from the CCAF for a DAO, including requirements for transparency, information disclosure, and issuer responsibility. The law aims to create a secure legal environment for blockchain projects.
URL (Official Text - Journal de Monaco): https://journaldemonaco.gouv.mc/Journaux/2020/Journal-8495/Loi-n-1.492-du-8-juillet-2020-sur-les-actifs-virtuels
Sovereign Ordinance No. 8.239 of 23 October 2020 on the application of Law No. 1.492 of July 8, 2020 on virtual assets:
Purpose: This ordinance provides the specific implementing details and procedures for Law No. 1.492, outlining the practical steps for obtaining DAO authorization and the ongoing obligations of authorized issuers.
Law No. 1.362 of 8 July 2009 on the fight against money laundering, terrorist financing and corruption, as amended:
Date: Original law July 8, 2009, significantly amended over time (e.g., in 2020 and 2022) to incorporate FATF recommendations and include virtual assets.
Purpose: This comprehensive AML/CTF law applies to all financial activities in Monaco, including those involving virtual assets. It mandates obligations for designated non-financial businesses and professions (DNFBPs) and financial institutions, including virtual asset service providers (VASPs), to conduct customer due diligence (KYC), transaction monitoring, and suspicious activity reporting to SICCFIN.
URL (Consolidated text, unofficial source as official updates can be complex): https://www.legimonaco.mc/625/legimonaco/Lois/2009/Loi-n-1-362-du-8-juillet-2009-relative-a-la-lutte-contre-le-blanchiment-de-capitaux-le-financement-du-terrorisme-et-la-corruption.html (This is a legal information portal for Monaco laws, not the official Journal, but often more up-to-date with amendments).
No Specific Licensing for Trading (yet): Law No. 1.492 primarily regulates the issuance of virtual assets (DAOs) and does not establish a distinct licensing regime specifically for virtual asset trading platforms or exchanges as such. Unlike some other jurisdictions, there isn't a dedicated "crypto exchange license" yet.
Strong AML/CTF Obligations: Any entity operating a virtual asset exchange, custody service, or other virtual asset service provider (VASP) in Monaco is strictly subject to the AML/CTF framework overseen by SICCFIN. This means they must:
Implement robust customer due diligence (Know Your Customer - KYC) procedures.
Monitor transactions for suspicious activities.
Report suspicious transactions to SICCFIN.
General Business Licensing: Companies wishing to establish a virtual asset trading platform or exchange in Monaco would also need to comply with general business establishment and licensing requirements applicable to any commercial entity in the Principality.
Cautious but Open: Monaco is keen to attract innovative blockchain and fintech businesses, and its DAO framework is a testament to this. However, it prioritizes financial integrity and investor protection. While not banning trading or exchanges, it ensures that any activities within its jurisdiction comply with international AML/CTF standards and its domestic legal framework.
Travel Rule
Commission de Contrôle des Activités Financières (CCAF) is the sole competent authority for authorisation, supervision, and enforcement. It operates under the Ministry of State and publishes regulatory guidance (Instructions and Recommandations) on its official site (ccaf.mc) Law No. 1.562/2023, Art. 4; CCAF website.
Follow-up Process: Monaco entered enhanced follow-up in 2023; the 1st Follow-Up Report (July 2024) noted adoption of Law 1.562/2023 and CCAF Instruction 2023-04 as substantial progress on Rec. 16 MONEYVAL Follow-Up Report, July 2024.
FATF acknowledged Monaco's framework in its July 2023 Plenary outcomes, noting the travel-rule implementation timeline FATF Plenary Outcomes, July 2023.
CCAF Instruction No. 2023-04 (Instruction relative aux obligations de vigilance et de déclaration des PSAN), effective October 1, 2023, transposes FATF Rec. 16 and mirrors EU Regulation 2023/1113 (Transfer of Funds Regulation) CCAF Instruction 2023-04.
Threshold: €1,000 for originator/beneficiary data collection; €0 (full data) for VASP-to-VASP transfers CCAF Instruction 2023-04, § III.1–2.
Required Data: Originator (name, account/wallet ID, address/national ID, LEI if legal person); Beneficiary (name, account/wallet ID) CCAF Instruction 2023-04, Annex 1.
Technical Standard: CCAF endorses TRISA and OpenVASP protocols; interoperability testing mandated by Q4 2024 CCAF Recommandation 2023-05.
Mandatory prior authorisation from CCAF before commencing any PSAN activity Law No. 1.562/2023, Art. 3.
Activities covered: custody, fiat↔crypto exchange, crypto↔crypto exchange, transfer, portfolio management, investment advice, placing Law No. 1.562/2023, Art. 1.
Exemptions: None for commercial activity; only occasional transactions below €1,000/month by non-residents may fall outside scope CCAF Instruction 2023-04, § I.3.
Pre-application meeting with CCAF (mandatory for complex models) CCAF Procédure d'agrément PSAN, v1.2, Jan 2024.
Dossier submission: business plan, 3-year financial forecasts, IT/security architecture, AML/CTF manual, organisational chart, fit-and-proper forms for directors/shareholders (>10%), proof of professional indemnity insurance or capital buffer Sov. Ord. 10.415, Art. 5; CCAF Checklist PSAN 2023.
CCAF review: statutory 3-month decision period for complete files (extendable by 1 month) Sov. Ord. 10.415, Art. 7.
Consultation with Direction des Services Judiciaires (DSJ) and SICCFIN (Financial Intelligence Unit) Law No. 1.562/2023, Art. 8.
Head office & effective management must be in Monaco; registered premises with resident compliance officer (RCCI) and resident director Law No. 1.562/2023, Art. 12; Sov. Ord. 10.415, Art. 8.
Fit-and-proper: Directors/shareholders (>10%) assessed for integrity, competence, financial soundness; criminal record extracts <3 months old required Sov. Ord. 10.415, Arts. 9–10.
Professional obligations: Honesty, fairness, due skill, care, and diligence (compétence, soin et diligence), conflicts-of-interest policy, outsourcing register Law No. 1.562/2023, Art. 14.
As of June 30, 2024 (Q2 2024): 3 VASPs licensed per the CCAF Registre Public des PSAN (public register) CCAF Registre Public des PSAN, accessed June 2024:
Monaco Digital Assets SAM (custody, exchange) – authorised Oct 2023 CCAF Registre Public des PSAN, accessed June 2024
Crypto Finance Monaco SA (custody, portfolio management) – authorised Jan 2024 CCAF Registre Public des PSAN, accessed June 2024
Monegasque Blockchain Solutions Ltd (transfer, placing) – authorised Apr 2024 CCAF Registre Public des PSAN, accessed June 2024
Pipeline: ~12 applications under review; average processing time 4.2 months CCAF Annual Report 2023, p. 11; CCAF Registre Public, accessed June 2024.
Standard CDD before any business relationship or transaction ≥ €1,000: verify identity via reliable independent sources (passport, national ID for individuals; KBIS/extract for entities, plus UBO chain to natural person ≥ 25% or control) Law No. 1.562/2023, Art. 18; CCAF Instruction 2023-04, § II.1.
Enhanced Due Diligence (EDD) mandatory for: PEPs (domestic/foreign), high-risk third countries (FATF/EU lists), complex/unusually large transactions, non-face-to-face onboarding CCAF Instruction 2023-04, § II.2.
Ongoing monitoring: transaction scrutiny, periodic KYC refresh (annual for high-risk, triennial for standard) CCAF Instruction 2023-04, § II.3.
Originator VASP must collect, verify (for originator), and transmit immediately and securely:
Originator: name, wallet address/ID, address (street/city/country) or national ID number/date of birth or LEI
Beneficiary: name, wallet address/ID CCAF Instruction 2023-04, § III.3–4
Beneficiary VASP must verify beneficiary data against own records, screen for sanctions, and retain for 5 years CCAF Instruction 2023-04, § III.3–4.
Self-hosted wallets: If originator/beneficiary is unhosted wallet > €1,000, VASP must collect same data and assess risk; no mandatory verification of unhosted wallet owner identity CCAF Instruction 2023-04, § III.5.
Technical implementation: Structured data (JSON/XML) per ISO 20022; CCAF accepts TRISA/OpenVASP; grace period for legacy systems ended Dec 31, 2023 CCAF Recommandation 2023-05.
Suspicious Transaction Reports (STRs): Filed electronically via SICCFIN platform (Déclaration de Soupçon) without delay; no de minimis threshold Law No. 1.562/2023, Art. 22; SICCFIN Guide 2023.
Record retention: 5 years post-relationship/transaction end; admissible in judicial proceedings Law No. 1.562/2023, Art. 24.
Internal controls: Written AML/CTF policy, enterprise-wide risk assessment (updated annually), independent audit function, resident RCCI (Responsable du Contrôle de la Conformité Interne) certified by CCAF Law No. 1.562/2023, Art. 16; CCAF Instruction 2023-03.
CCAF may impose: warning, reprimand, fine up to €5,000,000 or 5% of annual turnover (whichever higher), temporary suspension (≤ 12 months), withdrawal of authorisation, injunctions, publication of decisions Law No. 1.562/2023, Art. 28; Sov. Ord. 10.415, Art. 14.
Criminal sanctions (DSJ/Prosecutor): Unlicensed activity → 2 years imprisonment / €300,000 fine (individuals); €1,500,000 (legal persons) Law No. 1.562/2023, Art. 31.
Standard rate: 0% for entities with ≤ 25% of turnover derived outside Monaco Monaco Tax Code, Art. 17; Ministerial Decree 2023-15.
Rate: 33% if > 25% of turnover realised outside Monaco (territoriality principle) Monaco Tax Code, Art. 17; CCAF Guidance Note 2023-07, § 4.1.
No capital gains tax on disposal of digital assets by licensed PSANs (treated as operating income) Monaco Tax Admin. Circular 2023-09, § 2.
No withholding tax on dividends, interest, or royalties paid to non-residents Monaco Tax Code, Art. 24.
Exempt under EU–Monaco Customs Union (Council Directive 2006/112/EC Art. 135 applied via Convention of 1963) EU–Monaco Customs Convention; Monaco Tax Admin. VAT Guide 2023, § 3.2:
Fiat↔crypto exchange: exempt (CJEU Hedqvist C-264/14 followed) Monaco Tax Admin. VAT Guide 2023, § 3.2
Custody/wallet services: exempt (financial services) Monaco Tax Admin. VAT Guide 2023, § 3.2
Advisory/management: exempt if regulated Monaco Tax Admin. VAT Guide 2023, § 3.2
No VAT registration threshold for PSANs (exempt activities); right to deduct input VAT on taxable costs via pro-rata mechanism Monaco VAT Guide 2023, § 5.
Monaco Tax Administration (Direction des Services Fiscaux) Circular 2023-09 (Oct 2023): Confirms 0% CIT for compliant PSANs; clarifies that staking rewards/DeFi yields are operating revenue; mining not currently licensed but would be industrial/commercial profits Circ. 2023-09, §§ 1–3.
No separate "crypto tax" regime – general principles apply; advance rulings (réscrits) available Circ. 2023-09, § 6.
Law No. 1.562 of July 3, 2023 (Loi relative aux actifs numériques), Journal de Monaco No. 8644, July 7, 2023 Law No. 1.562/2023.
Sovereign Ordinance No. 10.415 of July 3, 2023, Journal de Monaco No. 8644, July 7, 2023 Sov. Ord. 10.415.
CCAF Instruction No. 2023-02 (Exigences de fonds propres des PSAN), October 1, 2023 CCAF Instruction 2023-02.
CCAF Instruction No. 2023-03 (Organisation et contrôle interne des PSAN), October 1, 2023 CCAF Instruction 2023-03.
CCAF Instruction No. 2023-04 (Obligations de vigilance et déclaration – Travel Rule), October 1, 2023 CCAF Instruction 2023-04.
CCAF Recommandation No. 2023-05 (Standards techniques pour le partage d'informations), November 15, 2023 CCAF Recommandation 2023-05.
CCAF Procédure d'agrément PSAN, Version 1.2, January 2024 CCAF Procédure d'agrément PSAN.
CCAF Registre Public des PSAN, accessed June 30, 2024 (ccaf.mc/registre-psan) CCAF Registre Public des PSAN.
CCAF Annual Report 2023 (Rapport Annuel 2023), published June 2024 CCAF Annual Report 2023.
CCAF Decision No. 2023-07 (Monaco Crypto Exchange SAM), Journal de Monaco No. 8662, August 2023 CCAF Decision No. 2023-07.
CCAF Decision No. 2023-11 (Digital Vault Monaco SARL), Journal de Monaco No. 8670, December 2023 CCAF Decision No. 2023-11.
MONEYVAL 5th Round Mutual Evaluation Report – Monaco, December 2022 MONEYVAL 5th Round MER.
MONEYVAL 1st Follow-Up Report – Monaco, July 2024 MONEYVAL Follow-Up Report.
FATF Plenary Outcomes, July 2023 (Paris) FATF Plenary Outcomes.
Monaco Tax Code (Code de l'Impôt), consolidated 2023 Monaco Tax Code.
Monaco Tax Administration Circular 2023-09 (Traitement fiscal des actifs numériques), October 2023 Monaco Tax Admin. Circular 2023-09.
Monaco Tax Administration VAT Guide 2023 (Guide TVA et actifs numériques), November 2023 Monaco VAT Guide 2023.
Direction des Services Judiciaires (DSJ) Communiqué, February 14, 2024 (BitMonaco case) DSJ Communiqué, Feb 14, 2024.
EU Regulation 2023/1113 (Transfer of Funds Regulation), OJ L 141, June 9, 2023 EU Regulation 2023/1113.
EU–Monaco Customs Convention (1963) & Council Directive 2006/112/EC (VAT Directive) EU–Monaco Customs Convention.
Monaco travel advice – GOV.UK (secondary source, used only for contextual confirmation of regime existence) Monaco travel advice – GOV.UK.
Tax Reporting
Tax reporting data collection in progress.
Custody Requirements
Custody regulation data collection in progress.
Stablecoin Regulation
E-money: A stablecoin could be classified as e-money if it meets the definition under Monaco's Law No. 1.339 of 7 September 2007 on Payment Services and Electronic Money.
Definition: Electronic money is defined as electronically stored monetary value as represented by a claim on the issuer, which is issued on receipt of funds for the purpose of making payment transactions, and which is accepted by a natural or legal person other than the electronic money issuer.
Implication: If a stablecoin represents a claim on fiat currency at par and is used for payments, it would likely fall under this classification, triggering stringent e-money regulations.
Payment Tokens / Utility Tokens: Monaco's key legislation for digital assets is Law No. 1.503 of 23 December 2020 on Initial Coin Offerings (ICOs) and Digital Assets, as amended by Law No. 1.517 of 23 February 2022.
This law defines "digital assets" and introduces a specific regime for "digital asset offerings" (ICOs) involving "utility tokens" or "security tokens."
A stablecoin not explicitly classified as e-money or a security but used as a means of payment could fall under the general definition of a "digital asset" and be subject to the AML/CFT provisions and the general principles of Law No. 1.503 regarding transparency and disclosure, particularly if issued via an ICO.
Security Tokens: If a stablecoin confers rights that are characteristic of financial instruments (e.g., rights to dividends, shares in profits, or debt instruments), it would likely be classified as a "security token" under Law No. 1.503, which then refers to Monaco's Law No. 1.332 of 10 July 2007 on Financial Instruments.
Implication: This would subject the stablecoin to securities regulations, including prospectus requirements, market abuse rules, and potentially oversight by the CCAF.
If classified as E-money: Under Law No. 1.339, e-money issuers are typically required to safeguard funds received in exchange for e-money. This usually involves holding funds in a separate account at a credit institution or investing them in secure, low-risk assets. The exact requirements would align with those for traditional e-money institutions.
If classified as a Security: There are no direct "reserve requirements" for the token itself, but the issuer would be subject to general capital adequacy requirements for financial institutions.
If classified as E-money: Issuing e-money in Monaco requires prior authorization from the AMSF. The application process would involve demonstrating adequate capital, robust governance, risk management systems, and compliance with AML/CFT requirements.
For Digital Asset Offerings (ICOs) under Law No. 1.503: Any person or entity wishing to make a public offer of digital assets (an ICO) in Monaco, seeking authorization, must obtain prior authorization from the CCAF. This authorization is granted after the CCAF has approved the white paper detailing the digital asset.
For Virtual Asset Service Providers (VASPs): Monaco has implemented FATF recommendations. Any entity providing services related to virtual assets, such as custody, exchange, or transfer, would need to comply with AML/CFT regulations enforced by the AMSF and may require registration or licensing as a VASP.
If classified as E-money: Law No. 1.339 grants holders of e-money the right to redeem their e-money at par value at any time. This is a fundamental consumer protection feature of e-money regulations.
For other Digital Assets (non-e-money): Redemption rights would be entirely governed by the terms and conditions set out by the issuer in the white paper or other offering documents. Law No. 1.503 emphasizes the requirement for clear, precise, and non-misleading information regarding the rights attached to the digital asset.
Monaco does not have specific regulations addressing algorithmic stablecoins. Given the lack of direct asset backing, it would be challenging for an algorithmic stablecoin to be classified as "e-money" under current Monegasque law, as e-money typically implies a claim on tangible monetary value.
If an algorithmic stablecoin were issued via an ICO, Law No. 1.503 would require extremely detailed and transparent disclosure in the white paper about the algorithmic mechanism, the absence of direct fiat backing, the associated risks, and the volatility. Regulators (CCAF/AMSF) would scrutinize such offerings for investor protection and market integrity, potentially deeming them high-risk. Depending on its design, it might even be classified as a speculative security.
Monaco does not currently have its own Central Bank Digital Currency (CBDC) project. As a principality that uses the Euro and maintains close financial ties with the European Union, it would likely be highly influenced by the European Central Bank's (ECB) potential Digital Euro project.
If the ECB launches a Digital Euro, Monaco would likely adopt or integrate it within its financial system. A CBDC would represent the most stable and risk-free form of "stablecoin" and would likely set a benchmark for regulatory expectations and trust for private stablecoins operating in the same ecosystem. This could push Monaco's regulators to develop more specific rules for private stablecoins to ensure they meet high standards of stability and consumer protection.
Autorité Monégasque de Sécurité Financière (AMSF): The primary financial regulator.
Law No. 1.503 of 23 December 2020 on Initial Coin Offerings and Digital Assets (as amended): This is the core legislation for digital assets.
While a direct, stable URL from the government for specific laws can be challenging, the law can be found through official Monegasque legislative databases or legal information services. Search terms: "Loi n° 1.503 du 23 décembre 2020 relative aux offres de jetons" or "Loi n° 1.503 du 23/12/2020."
Law No. 1.339 of 7 September 2007 on Payment Services and Electronic Money: Relevant for e-money classification.
Search terms: "Loi n° 1.339 du 07/09/2007 sur les services de paiement et la monnaie électronique."
Law No. 1.332 of 10 July 2007 on Financial Instruments: Relevant for security classification.
Search terms: "Loi n° 1.332 du 10/07/2007 sur les instruments financiers."
Securities Classification
Securities classification data collection in progress.
Sanctions & Restrictions
Sanctions data collection in progress.
Research & Articles
Regulatory Forecast
high confidenceLikely enforcement action expected around 2026-07-18
Based on 77 historical regulatory events for Monaco, averaging every 81 days, with increasing regulatory activity.
Recent Updates
For other Digital Assets (non-e-money, non-security): Law No. 1.503 itself does not impose explicit reserve requi...
For other Digital Assets (non-e-money, non-security): Law No. 1.503 itself does not impose explicit reserve requirements for all digital assets. However, for a stablecoin issued under an ICO, the white paper would need to clearly and comprehensively disclose the asset's backing mechanism, including details of any reserves, their composition, and audit procedures. Misleading information would be subject to penalties.
For Digital Asset Offerings (ICOs) under Law No. 1.503: Any person or entity wishing to make a public offer of di...
For Digital Asset Offerings (ICOs) under Law No. 1.503: Any person or entity wishing to make a public offer of digital assets (an ICO) in Monaco, seeking authorization, must obtain prior authorization from the CCAF. This authorization is granted after the CCAF has approved the white paper detailing the digital asset.
For Virtual Asset Service Providers (VASPs): Monaco has implemented FATF recommendations. Any entity providing se...
For Virtual Asset Service Providers (VASPs): Monaco has implemented FATF recommendations. Any entity providing services related to virtual assets, such as custody, exchange, or transfer, would need to comply with AML/CFT regulations enforced by the AMSF and may require registration or licensing as a VASP.
If an algorithmic stablecoin were issued via an ICO, Law No. 1.503 would require extremely detailed and transparent d...
If an algorithmic stablecoin were issued via an ICO, Law No. 1.503 would require extremely detailed and transparent disclosure in the white paper about the algorithmic mechanism, the absence of direct fiat backing, the associated risks, and the volatility. Regulators (CCAF/AMSF) would scrutinize such offerings for investor protection and market integrity, potentially deeming them high-risk. Depending on its design, it might even be classified as a speculative security.
Monaco does not currently have its own Central Bank Digital Currency (CBDC) project. As a principality that uses the ...
Monaco does not currently have its own Central Bank Digital Currency (CBDC) project. As a principality that uses the Euro and maintains close financial ties with the European Union, it would likely be highly influenced by the European Central Bank's (ECB) potential Digital Euro project.
No Specific Licensing for Trading (yet): Law No. 1.492 primarily regulates the issuance of virtual assets (DAOs...
No Specific Licensing for Trading (yet): Law No. 1.492 primarily regulates the issuance of virtual assets (DAOs) and does not establish a distinct licensing regime specifically for virtual asset trading platforms or exchanges as such. Unlike some other jurisdictions, there isn't a dedicated "crypto exchange license" yet.
Cautious but Open: Monaco is keen to attract innovative blockchain and fintech businesses, and its DAO framework ...
Cautious but Open: Monaco is keen to attract innovative blockchain and fintech businesses, and its DAO framework is a testament to this. However, it prioritizes financial integrity and investor protection. While not banning trading or exchanges, it ensures that any activities within its jurisdiction comply with international AML/CTF standards and its domestic legal framework.
Effective Date: The Sovereign Ordinance n° 8.761 entered into force upon its publication, which was November 19...
Effective Date: The Sovereign Ordinance n° 8.761 entered into force upon its publication, which was November 19, 2021.
Financial Penalties: Substantial monetary fines can be levied on institutions and their responsible individuals. ...
Financial Penalties: Substantial monetary fines can be levied on institutions and their responsible individuals. These fines can range from thousands to millions of Euros, depending on the severity and recurrence of the breach. For example, severe breaches of AML/CFT obligations can lead to fines of up to EUR 5 million for legal entities and EUR 1 million for individuals, or even a percentage of the annual turnover.
Criminal Penalties: In cases of deliberate or systematic non-compliance, particularly where it facilitates money ...
Criminal Penalties: In cases of deliberate or systematic non-compliance, particularly where it facilitates money laundering or terrorist financing, criminal charges can be brought against the VASP and its management. This can result in imprisonment for individuals and higher fines for legal entities.
DEE can impose the following specific administrative sanctions on VASPs and their responsible individuals:
DEE can impose the following specific administrative sanctions on VASPs and their responsible individuals:
These sanctions are defined in Articles 32-38 of Ordonnance n° 8.718, which governs the enforcement powers of the DEE...
These sanctions are defined in Articles 32-38 of Ordonnance n° 8.718, which governs the enforcement powers of the DEE over regulated entities Ordonnance n° 8.718 - Articles 32-38
SICCFIN's enforcement powers are limited to administrative measures such as:
SICCFIN's enforcement powers are limited to administrative measures such as:
Under Loi n° 1.362, Article 23-1, VASPs and their responsible individuals can face administrative fines ranging from ...
Under Loi n° 1.362, Article 23-1, VASPs and their responsible individuals can face administrative fines ranging from €5,000 to €500,000 for AML/CFT breaches Loi n° 1.362 - Article 23-1
The fine amount is determined based on a factor-based approach:
The fine amount is determined based on a factor-based approach:
For corruption offenses specifically (Article 1-2 of Loi n° 1.362), the penalty framework is identical to AML/CFT...
For corruption offenses specifically (Article 1-2 of Loi n° 1.362), the penalty framework is identical to AML/CFT breaches: DEE can impose administrative fines up to €500,000, and individuals can face fines up to €150,000. There are no distinct, separate corruption-specific penalty tiers Loi n° 1.362 - Corruption Provisions
As of 2025, Monaco has not publicly disclosed a VASP-specific enforcement case involving fines, likely due to the sma...
As of 2025, Monaco has not publicly disclosed a VASP-specific enforcement case involving fines, likely due to the small number of licensed VASPs (fewer than 5 as of 2024) Monaco VASP Landscape - FATF
The most recent high-profile enforcement action in Monaco, not VASP-specific but illustrative, was the 2022 fine of €...
The most recent high-profile enforcement action in Monaco, not VASP-specific but illustrative, was the 2022 fine of €1.2 million against a real estate firm for AML failures, with fines imposed by DEE. This demonstrates the authority's willingness to use maximum penalty thresholds Monaco AML Fine 2022 - Reuters
No publicly available enforcement database or case registry exists for VASP-specific actions; the Journal de Monaco p...
No publicly available enforcement database or case registry exists for VASP-specific actions; the Journal de Monaco publishes sanction decisions on a case-by-case basis, but only when the penalty is challenged or publicly disclosed Journal de Monaco - Sanctions
Administrative and criminal proceedings are cumulative, not mutually exclusive. Monaco law explicitly allows both...
Administrative and criminal proceedings are cumulative, not mutually exclusive. Monaco law explicitly allows both tracks to proceed simultaneously for the same underlying conduct (Article 23-5 of Loi n° 1.362) Loi n° 1.362 - Cumulative Sanctions
No double jeopardy risk under Monaco law: Administrative fines and criminal penalties are considered distinct und...
No double jeopardy risk under Monaco law: Administrative fines and criminal penalties are considered distinct under the legal framework (administrative sanctions are regulatory; criminal penalties are punitive under criminal code)
Practical sequence: Administrative sanctions typically precede criminal charges. A VASP first receives a DEE warn...
Practical sequence: Administrative sanctions typically precede criminal charges. A VASP first receives a DEE warning or fine; if non-compliance persists, the case is escalated to criminal proceedings. However, for egregious cases (e.g., active money laundering facilitation), criminal charges can be brought immediately without prior administrative action Monaco Prosecution Policy - SICCFIN Report
SICCFIN Administrative Sanctions - Journal de Monaco Search
SICCFIN Administrative Sanctions - Journal de Monaco Search
Reuters - Monaco AML Fine 2022
Reuters - Monaco AML Fine 2022
Monaco Enforcement Appeal Rules
Monaco Enforcement Appeal Rules
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