Financial Crime World

MONACO AML/CFT SURVEY: DEFINITIONS AND INSTRUCTIONS

The Financial Intelligence Unit (FIU) of Monaco has released a comprehensive survey to assess the effectiveness of anti-money laundering and combating the financing of terrorism (AML/CFT) measures in the country. The survey aims to gather crucial information from financial institutions, trust and company service providers, and other relevant entities.

Definitions

Primary Nationality

For the purpose of this questionnaire, an individual with multiple nationalities should be reported as having a primary nationality, which should be based on the following ordering:

  • Nationality of birth country
  • Nationality that is their country of residence
  • Other nationality

Resident and Non-Resident

  • Resident: A natural person who is a Monégasque or has a legal right to work and live in Monaco.
  • Non-Resident: A non-Monégasque national who does not have residency in Monaco.

Senior Management

An officer or employee with sufficient knowledge of the institution’s money laundering and terrorist financing risk exposure and with sufficient seniority to take decisions affecting its risk exposure.

Key Terms

  • SICCFIN (AMSF): The national central authority responsible for collecting, analyzing, and disseminating information related to the fight against money laundering, terrorist financing, and corruption.
  • Sports Agent: Any person who brings interested parties together to make a contract, either for the paid exercise of a sporting activity or for the agreement of an employment contract for the paid exercise of a sporting or training activity.
  • TFS (Targeted Financial Sanctions): Measures imposed by the government on individuals and organizations suspected of engaging in terrorist financing activities.
  • Trust and Company Service Providers: Individuals or businesses that provide services such as:
    • Acting as agents, directors, or secretaries of companies
    • Providing registered offices
    • Performing trustee functions
    • Arranging for others to act as nominees

Ultra-High Net Worth Individuals (UHNWIs) and Groups

  • Ultra-High Net Worth Individual: A natural person whose sum of all accounts and net assets is more than EUR 50 million.
  • Ultra-High Net Worth Group: A group of family-related natural persons whose sum of all accounts and net assets is more than EUR 50 million.

VASP (Virtual Asset Service Provider)

An entity that provides services related to virtual assets, such as: + Cryptocurrency exchanges + Custodial services

Survey Instructions

The survey consists of two main sections: Customer Risk and Inherent Risk. Respondents are required to provide information on their clients, including:

  • Number of unique clients by primary nationality
  • Country of headquarters or incorporation
  • Other relevant details

For more information on how to complete the survey, please visit the FIU’s website at www.fiu.mc.