Monaco Compliance Report

Generated 2026-09-22

Partially Regulated

Regulatory Overview

Regulatory Status: Some rules exist but significant gaps; draft legislation or limited guidance
Key Regulator(s): EU Council, Council of Europe's Committee of Experts, United Nations Security Council, Al-Qaida Sanctions Committee, Non-SDN Palestinian Legislative Council
Primary Legislation: Law No. 1.383, 2018, Law No. 1.491 (2020), Regulation 2023/1114, Law 1.491 Art. 3, Law 1.491 Art. 5, Law 1.383 Title III (Arts. 8, Law 1.491 Arts. 18–22, Impôt sur les Bénéfices Arts. 1, 14 Crypto mining/staking treated as commercial activity. Code de l, Sovereign Ordinance draft 2024, Sovereign Ordinance 9.412, Law No. 1.383 (2018) on DLT/Token Offerings, Law No. 1.491 (2020) on DASP Licensing, Sovereign Ordinance No. 9.062 (2021) implementing Law 1.491, Sovereign Ordinance No. 9.412 (2024) on MiCA/TFR Transposition, Sovereign Ordinance No. 8.828 (2019) on SICCFIN Organization, Law No. 1.338 (2007) on Investment Services
Travel Rule: Not adopted — Threshold: €1,000

Key Facts

aml This is the foundational AML/CFT law in Monaco. It has been significantly amended over the years to incorporate international standards, including those related to virtual assets. It defines "obliged entities" and outlines their general AML/CFT responsibilities. Ordonnance Souveraine n° 8.182 du 10 mars 2021 portant modification de l'ordonnance souveraine n° 2.318 du 3 août 2009 d'application de la loi n° 1.362 du 3 août 2009 modifiée, relative à la lutte contre le blanchiment de capitaux, le financement du terrorisme et la corruption, modifiée (Sovereign Ordinance No. 8.182 of March 10, 2021 amending Sovereign Ordinance No. 2.318 of August 3, 2009 implementing Law No. 1.362 of August 3, 2009, as amended, on the fight against money laundering, terrorist financing, and corruption) This is the critical piece of legislation specifically bringing virtual asset activities and VASPs under the scope of Monaco's AML/CFT regime. It defines virtual assets and virtual asset service providers and subjects them to the same AML/CFT obligations as traditional financial institutions. It also stipulates that individuals or legal entities wishing to carry out VASP activities in Monaco must be registered with the Service d'Information et de Contrôle sur les Circuits Financiers (SICCFIN) and, in some cases, may require specific authorizations depending on the nature of services offered. Natural Persons: Obtain and verify the client's name, address, date and place of birth, nationality, and a unique identification number (e.g., passport or national ID card number). Verification must be based on reliable, independent source documents or data. Legal Entities: Obtain and verify the name, legal form, address of the registered office, company registration number (if applicable), articles of association, and proof of legal existence and powers. Non-Face-to-Face Relationships: Enhanced measures are required to mitigate the higher risk associated with non-face-to-face onboarding. Identify the natural person(s) who ultimately own or control the client, directly or indirectly. For legal entities, this typically means anyone holding 25% or more of the shares or voting rights, or otherwise exercising control.
licensing SICCFIN (Service d'Information et de Contrôle sur les Circuits Financiers): This is Monaco's Financial Intelligence Unit (FIU) and the primary authority for AML/CFT supervision. SICCFIN is responsible for defining and overseeing the AML/CFT obligations of VASPs. CCAF (Commission de Contrôle des Activités Financières): The financial markets supervisory authority in Monaco. While not directly responsible for "crypto licenses" in the broader sense, the CCAF would be involved if a virtual asset activity falls under the scope of existing regulated financial services (e.g., if a crypto asset is deemed a security, or if investment advice related to crypto is provided). Requirement: Registration with SICCFIN for AML/CFT purposes. Scope: This applies to platforms facilitating the exchange between virtual assets and fiat currencies, and between one or more forms of virtual assets. Scope: This includes entities that provide safekeeping or administration of virtual assets or instruments enabling control over virtual assets (e.g., private keys) on behalf of clients. If handling virtual assets (e.g., converting crypto to fiat for merchants): The virtual asset component of the service would likely qualify the entity as a VASP, requiring registration with SICCFIN. If handling traditional fiat payments (e.g., processing card payments, traditional money remittance): These activities fall under existing payment services regulations. Depending on the exact nature, a license or authorization from the CCAF might be required if the activity constitutes a regulated financial service. Customer Due Diligence (CDD): Implementing robust procedures for identifying and verifying the identity of clients (Know Your Customer - KYC), including beneficial owners, and understanding the purpose and intended nature of the business relationship.
stablecoin 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.
status 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 Service d'Information et de Contrôle sur les Circuits Financiers (SICCFIN). Journal de Monaco No. 8421 (Law 1.383), Journal de Monaco No. 8592 (Law 1.491) Licensing requires €125,000 minimum capital, fit-and-proper directors, and full AML/CFT compliance aligned with FATF standards and EU MiCA/TFRs. Journal de Monaco No. 8421 (Law 1.383), Journal de Monaco No. 8592 (Law 1.491) As of Q2 2025, the AMAF public register shows zero licensed DASPs; the licensing door is open but stringent, with no entities having completed the full authorization process to date. AMAF Registre public des DASP autorisés Monaco is a Moneyval member (since 2003) and underwent its 5th round mutual evaluation in 2022; it transposes EU AML Directives and applies FATF standards via Laws 1.383/1.491 and implementing Sovereign Ordinances. Moneyval 5th Round Report on Monaco (2022) Tax regime: zero capital gains tax for resident individuals on crypto disposals; corporate income tax 25% for companies deriving >25% revenue outside Monaco (reduced rates possible); VAT exemption for crypto-to-fiat exchange per EU CJEU Hedqvist (C-264/14); token offering VAT analysis required case-by-case. Code de l'Impôt sur les Bénéfices, Direction des Services Fiscaux guidance Autorité Monégasque de Sécurité Financière (AMSF): Principal supervisor for DASPs under Law 1.491; responsible for licensing, ongoing supervision, prudential oversight, and enforcement. Law 1.491 Arts. 3–4; Sovereign Ordinance No. 9.062 (2021) implementing Law 1.491 Replaced the former CCAF's licensing role for DASPs. Law 1.491 Arts. 3–4 Commission de Contrôle des Activités Financières (CCAF): Retains mandate for investment services, collective investment schemes, and traditional financial intermediaries; coordinates with AMSF on perimeter issues. Law 1.338 (2007) Art. 1; Law 1.491 Art. 2 Service d'Information et de Contrôle sur les Circuits Financiers (SICCFIN): Monaco's Financial Intelligence Unit (FIU); receives STRs from DASPs and all obliged entities under Law 1.383 Title III; member of Egmont Group. Law 1.383 Arts. 15–18; Sovereign Ordinance No. 8.828 (2019) on SICCFIN organization Law No. 1.383 (2018) — DLT/Token Offerings: Defines "token," "DLT," "token offering," "DASP"; establishes registration regime for token offerors (white paper filing with AMSF) and AML obligations for all DASPs. Journal de Monaco No. 8421, 20 July 2018
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.

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-06. View full profile