Page 16 - MONACO LAW REVIEW 2025-2

The AMSF
and Financial Intelligence
Bruno DALLES
Bruno DALLES
Director of the AMSF
Director of the AMSF
The Monaco Financial Security Authority (AMSF) is
an independent administrative authority entrusted
with multiple responsibilities to ensure the effective
implementation of international and domestic standards on
combating money laundering, terrorist fi nancing, corruption
and the proliferation of weapons of mass destruction.
The AMSF includes a dedicated fi nancial intelligence service
which corresponds to the international defi nition of a Financial
Intelligence Unit (FIU), in line with Recommendation 29 of
the Financial Action Task Force (FATF).
Its mission is to receive suspicious transaction reports from
obliged professionals governed by AML legislation (Know
Your Customer requirements, risk analysis, detection of
unusual transactions, risk-based due diligence, etc.). The FIU
conducts quality control of suspicious transaction reports,
corroborates suspicions of money laundering, and enriches
them by drawing on multiple databases in order to perform
operational analysis. Its purpose is to produce fi nancial
intelligence capable of being transmitted to the Public
Prosecutor so that criminal investigations may be initiated, or
to strengthen the evidential basis of ongoing investigations.
Cooperation between FIUs belonging to the Egmont Group
(181 FIUs) enables rapid and precise access to fi nancial
intelligence.
Under Article 47-1 of Law No. 1.362 of 3 August 2009, as
amended, the FIU must conduct both operational analysis
and strategic analysis. Its structure therefore includes two
principal divisions, each comprising specialised sections
whose tasks are distributed as follows.
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The Director of the Monaco Financial Security Authority
(AMSF), acting as head of the FIU, has the power to oppose
suspicious fi nancial transactions, a power exercised in
coordination with the Public Prosecutor. In 2024, the Financial
Intelligence Unit used this right of opposition on eight
occasions in respect of transactions involving individuals or
entities that had been the subject of suspicious transaction
reports. In each case, the level of suspicion justifi ed exercising
this right and referring the matter to the judicial authorities.
The combined value of the transactions suspended exceeded
EUR 57 million. As at 31 October 2025, ten oppositions have
been recorded for the year.
“In 2025, the FIU exercised its
right of opposition on ten occasions
in respect of suspicious transactions”
The AMSF also publishes an annual activity report, sectoral
analyses, and professional guidance (by theme: suspicious
transaction reporting, internal procedures, fi nancial sanctions,
national risk assessment; and by sector: private banking and
wealth management, terrorist fi nancing, politically exposed
persons, real estate agents, sports agents, yachting). It also
issues guidelines, strategic analyses, collections of typologies
and, where necessary, alerts concerning high-risk or unlawful
activities.
The human, budgetary and technological resources of
the AMSF continue to grow in order to strengthen the
effectiveness of all its missions.
“The combined value of the
transactions suspended exceeded
EUR 57 million.”