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MONACO LAW REVIEW | DECEMBER 2025 | SPECIAL REPORT
professions relating to customer due diligence, reporting and
cooperation with the competent authorities. It also establishes
the AMSF, which has extensive responsibilities, and sets out,
in Articles 47 et seq., the manner in which the authority
may obtain fi nancial intelligence, as well as the mechanisms
governing cooperation with the judicial authorities.
Cooperation and information-sharing between the Public
Prosecutor and the Department of Tax Services are also
provided for in Article 2 of Sovereign Ordinance No. 3.085
on the rights and duties of tax offi cials. The provision states
that “in any proceedings before the civil or criminal courts, the
Public Prosecutor may disclose case fi les to the Department of
Tax Services.” Law No. 1.559 of 29 February 2024 further
strengthened this dynamic, particularly through Article 24,
which expands the possibilities for cooperation between
administrative and judicial authorities, in line with
Recommendation 2 of the Financial Action Task Force (FATF),
relating to national coordination and cooperation. This
provision establishes a system of shared secrecy between the
Public Prosecutor’s Offi ce and the tax administration, thereby
enabling structured and secure information-sharing. The
Department of Tax Services is a key source of information,
particularly regarding real estate and asset transactions. Its
ability to cross-reference data can reveal patterns indicative
of the integration of illicit funds.
Other institutional actors also contribute to the AML/CFT
framework, by virtue of the information available to them,
even where their specifi c legal basis derives solely from
the obligation set out in Article 61 of the Code of Criminal
Procedure6. These include the Business Development Agency,
the Financial Activities Supervisory Commission and the
Advisory Committee on Freezing Measures, established to
implement targeted fi nancial sanctions (TFS).
Effective Cooperation and Rapid
Transmission of Information
Beyond the preliminary investigation alone, the effectiveness
of the fi ght against money laundering depends closely on
the fl ow of information between public bodies. To this end,
Monegasque legislation - in particular Law No. 1.362 and
its implementing Sovereign Ordinance No. 2.318 - provides
for several structured coordination mechanisms. These
include the Contact Group on Money Laundering, Terrorist
Financing and Corruption, established under Article 51 of the
Sovereign Ordinance. Placed under the authority of the State
Secretary of Justice, the Contact Group ensures reciprocal
information-sharing between the prosecuting authorities, the
Monaco Police Department, the AMSF and the State services.
It promotes consistency of action and the swift resolution of
potential obstacles.
More recently, the Operational Intelligence Exchange Unit
on Money Laundering was created by a circular issued by
the State Secretary of Justice on 8 January 2025. This unit
functions as a genuine platform for information-sharing,
bringing together on a regular basis the Public Prosecutor,
the Monaco Police Department, the Department of Tax
Services and the AMSF. Its purpose is to centralise, enhance
and redistribute intelligence relevant to the detection and
disruption of money laundering, the concealment of criminal
assets and the fi nancing of terrorism. Exchanges within
this unit take place under the rule of shared secrecy, which
preserves confi dentiality while allowing the circulation
of intelligence that may, where appropriate, be capable of
entering judicial proceedings.
These mechanisms give concrete expression, at national
level, to Recommendations 2 and 40 of the Financial Action
Task Force (FATF), which require States to ensure effective
cooperation and the timely exchange of information,
including with foreign counterparts.
A Complete Paradigm Shift
Recent developments in Monegasque law refl ect a
fundamental change: the former silo-based approach has
given way to an integrated model in which the controlled
fl ow of intelligence forms the backbone of effective money-
laundering investigations. The closer cooperation between
the Public Prosecutor’s Offi ce, the Department of Tax Services,
the AMSF and the Monaco Police Department illustrates this
commitment to shared operational insight, consistent with
Recommendations 2 and 40 of the Financial Action Task
Force (FATF) and recognised in international evaluations.
This opening, however, is not without its challenges. It
requires maintaining, within the stream of information
exchanged, the traceability of data, the protection of sources
and respect for fundamental rights. In this respect, the
system of shared secrecy established by Law No. 1.559 of 29
February 2024 represents a signifi cant step forward, though
it will need to be continuously tested in practice and clarifi ed
through case law.
Ultimately, information exchange is not merely a technical
tool: it has become a strategic pillar of criminal policy and
a benchmark for assessing the international credibility of
Monaco’s anti-money laundering framework.
5| Article 81-6-1 of the Code of Criminal Procedure.
6| “Any authority, public offi cial or offi cer who, in the exercise of his or her duties, becomes aware of a serious or
an intermediate offence shall immediately notify the Public Prosecutor and transmit to that judge all information,
documents and records that may assist in prosecuting the offence.”
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