Title: Monaco’s Struggle against Money Laundering and Terrorism Financing: Insights from the MONEYVAL Report

Overview

The Council of Europe’s Money Valuation Committee (MONEYVAL) conducted Monaco’s fifth evaluation round, revealing modest effectiveness in preventing and combating money laundering (ML) and terrorism financing (TF) (MONEYVAL Report). Key concerns include risk understanding, international cooperation, private sector compliance, use of financial intelligence, and transposition of United Nations targeted financial sanctions.

Areas of Concern

ML/TF Risk Understanding and Supervision

• Needs improvement in sectors like casinos, company services providers, trusts, virtual assets, and organized crime.
• Lack of effective ML investigations and prosecutions.
• Insufficient confiscation of proceeds of crime.

Transparency and Oversight

• Limited progress in addressing transparency of legal persons.
• Effectiveness of supervision needs improvement.

Human and Technical Resources

• SICCFIN faces a significant lack of human and technical resources.
• High-quality analyses not fully utilized by investigative authorities.

Complex ML Cases

• Lack of prioritization and addressing of complex ML cases.
• Low confiscation measures ordered.
• Legal framework for TF- and PF-related TFS in place, but implementation delayed.

TF Cases

• No convictions or prosecutions for TF.
• May not be consistent with country’s risk profile.

International Cooperation

• Needs significant improvements in counterpart cooperation.
• Systemic and unusual legislative obstacles hinder mutual legal assistance.
• Extradition requests subject to restrictive interpretation of dual criminality principle, leading to one out of two requests being refused.

Conclusion

Monaco needs to address these issues to effectively counter ML and TF threats and improve its compliance with international standards.