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MONACO LAW REVIEW | DECEMBER 2025 | SPECIAL REPORT
Thus, since 2019, the number of cases has progressively
risen and then accelerated in 2023, with nine convictions that
year, followed by fi fteen in 2024 and already twenty cases
adjudicated in 2025, with a further eight cases scheduled for
hearing before the end of the calendar year.
Shortly after the presumption of money laundering was
introduced, the Court was seized of a larger number of cases
that ultimately resulted in acquittals, which are not included
in the above fi gures, as the Court’s case law had to clarify
the contours of this new provision, in particular the factual,
legal or fi nancial circumstances which cannot reasonably be
explained other than by an intention to conceal the origin or
the actual benefi ciary of assets.
Indeed, the mere inability to justify the origin of funds in
one’s possession does not necessarily fall within the scope of
the presumption. Several decisions were therefore required
to refi ne the application of these provisions and to defi ne
their scope.
However, the introduction of the presumption made it
possible to uncover certain deviant behaviours, notably
individuals coming to Monaco to launder illicitly obtained
funds by purchasing luxury goods in cash, while offi cially
engaged in occupations that could not plausibly justify
possession of such sums.
Numerous cases of money laundering have also been detected
during controls relating to failures to declare the transport of
accompanying cash.
It should be noted that the sentences imposed by the Court
have consistently been as dissuasive as possible. Although the
penalties vary widely depending on the amounts involved,
the age of the case, and its complexity or simplicity, the Court
has, in the vast majority of cases, imposed custodial penalties
- whether unsuspended or suspended. Moreover, in Monaco,
a custodial sentence imposed is a custodial sentence served.
Thus, of the 54 cases adjudicated since 2019, 40 resulted
in unsuspended custodial sentences (nine of which were
mixed sentences) and 33 in suspended custodial sentences.
These sentences are usually accompanied by fi nes and by the
confi scation of seized sums, as well as assets acquired with
funds originating from a criminal offence (vehicles, luxury
goods, works of art, real estate, etc.).
What about Disciplinary Sanctions?
The Monaco Bar Council as Supervisory Authority
In 2020 and 2023, supervisory responsibilities in AML matters
were transferred from the Public Prosecutor to the President
of the Bar Association and subsequently to the Monaco Bar
Council. The Bar Council was also granted sanctioning powers,
which it exercises under a procedure adopted in its resolution of
6 September 2024. Through several resolutions, it approved its
inspection procedures, its fi t and proper check framework, the
terms of reference for its supervisory activity, and its 2024–26
supervision plan. In 2024, the Bar Council appointed Maître
Xavier-Alexandre BOYER, Avocat-Défenseur, as its “AML”
focal point to assist with its supervisory functions, as well as a
Supervision Delegate.
100% of Chambers Subject to Verifi cation
Inspections are conducted in various forms, both in terms of their
method and scope: some are carried out on-site, others off-site based
on documents, and others still through individual interviews at
the Maison de l’Avocat. As regards scope, reviews may consist
of a full assessment of the chamber’s AML/CFT/CPF framework
(the so-called “full scope” reviews) or focus on targeted themes.
Since 2023, the Bar Council has conducted two on-site full-scope
reviews in June 2024 and April 2025, two targeted on-site reviews
in October 2024 and September 2025, one off-site document-based
review in November 2025, and fi fteen individual interviews on
AML/CFT/CPF procedures. In total, 100% of the supervised
chambers have been subject to verifi cation of their AML/CFT/
CPF framework.
A First Disciplinary Sanction
Despite the positive trend emerging from the inspections
conducted, one review nevertheless led to disciplinary proceedings.
In July 2025, the Bar Council’s disciplinary panel imposed, for the
fi rst time, a fi nancial penalty of EUR 10,000 on a chamber for
failure to comply with the obligations set out in Law No. 1.362 of
3 August 2009. As no appeal was lodged against that decision, it
has now become fi nal.
Twelve Suspicious Transaction Reports
Suspicious Transaction Reports (STRs) are submitted via
the GOAML system to the Financial Intelligence Unit of the
AMSF by the Bar Council. Twelve STRs have been fi led to
date, confi rming the chambers’ full engagement in meeting their
cooperation obligations with the supervisory authorities.
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