Page 9 - MONACO LAW REVIEW 2025-2

MONACO LAW REVIEW | DECEMBER 2025 | SPECIAL REPORT
The FATF also exercises a monitoring function through a
mutual evaluation process. This peer-review mechanism
involves an in-depth assessment of national frameworks, both
in terms of technical compliance with the Recommendations
and the operational effectiveness of the measures
implemented. The conclusions of these evaluations are made
public.
The FATF brings together 40 members (including France, Italy
and the European Commission), as well as several regional
bodies (FSRBs), including MONEYVAL, which works in close
cooperation with the FATF. MONEYVAL, established in 1997
by the Council of Europe, applies the FATF methodology and
conducts mutual evaluations of its members, including the
Principality of Monaco.
The combined action of the FATF and MONEYVAL thus
rests on the standardisation of rules, peer monitoring, and the
pressure created by transparency in country evaluations and
possible inclusion on FATF lists.
THE PERMANENT SECRETARIAT
To support the work of the Coordination and Monitoring Committee for the national AML/CFT-P-C strategy, a Permanent Secretariat
was established in August 2024. Placed under the authority of the Minister of State, it is an interministerial unit headed by an Executive
Coordinator.
The Permanent Secretariat serves as the technical, administrative and operational arm of the Committee. It prepares the Committee’s
meetings, drafts the national strategy and the national action plan, and monitors their implementation by the relevant government
departments and authorities. It also coordinates the national risk assessment, an essential instrument for identifying the risks to which
the country is exposed, determining the measures to be taken and setting priorities.
In practical terms, the Permanent Secretariat’s team maintains continuous dialogue with the authorities and services concerned, enabling
it to track ongoing progress, share information, and address any diffi culties that may arise. The Secretariat regularly reports on these
matters to the Minister of State.
At present, the Permanent Secretariat is fully engaged in the implementation of the FATF action plan following Monaco’s listing on
the FATF grey list, which requires regular contact with the FATF Secretariat, the preparation of progress reports with the relevant
authorities, and the organisation of the various face-to-face meetings with FATF evaluators scheduled throughout the action plan. As part
of its mandate, the Secretariat may also call upon external service providers, such as expert consultants or translators.
At the same time, it is important to begin preparing for Monaco’s next MONEYVAL evaluation, and substantial work has already begun
in this regard.
The Permanent Secretariat also plays an international role. Its representatives attend the plenary sessions of the FATF and MONEYVAL,
accompanied by experts from other State services. This engagement helps track the evolution of international standards, maintain direct
communication with FATF and MONEYVAL teams, and strengthen cooperation with other member jurisdictions.
The Permanent Secretariat is also tasked with coordinating awareness-raising initiatives involving government departments and
administrative authorities. These initiatives are designed to strengthen obliged entities’ understanding of their legal obligations and to
foster a culture of compliance.
A dedicated page on the Prince’s Government website is regularly updated by the Permanent Secretariat team. It sets out Monaco’s anti-
money-laundering framework, provides the timeline of planned actions, and offers access to key information and links.
7