For professionals in the trust and corporate services, yachting, and real-estate sectors - all of which fall under the definition of professions non financières - the report provides a clear picture of the regulator’s priorities and expectations for 2025.
1 – A strengthened institutional framework
Throughout 2024 the AMSF consolidated its three-pillar structure:
- The Financial Intelligence Unit (CRF), responsible for analysing suspicious transaction reports and financial intelligence;
- The Supervision Department, conducting off-site and on-site AML/CFT controls;
- The Sanctions Department, operational since November 2024, empowered to impose administrative penalties.
2 – Sharp increase in suspicious-transaction reporting
In 2024, the CRF received 1,351 Suspicious Transaction Reports (STRs), up 13 % from 2023 .
Financial institutions submitted 843 reports (62 % of the total, -4 %).
- Non-financial professions (DNFBPs) filed 508 reports (38 % of the total, +58 %).
Breakdown by main non-financial sectors (2024):
- Gaming establishments - 196 STRs (+51 %)
- Notaries - 75 (+121 %)
- Chartered accountants - 53 (+56 %)
- Real-estate agents - 53 (+96 %)
- Yachting & shipping - 28 (+17 %)
- Company service providers - 24 (–11 %)
- Multi-family offices - 10 (+233 %)
3 – Cooperation and intelligence transmission
The CRF sent 46 reports to the Parquet Général in 2024 (+59 %) - 28 initial and 18 supplementary - based on serious indications of money laundering or related offences .
It also exercised its legal power to suspend eight transactions for up to five working days, covering over €57 million .
At the international level, cooperation remained intense:
- 91 requests received (-2 %), 126 requests sent (+22 %), and 94 spontaneous disclosures received (+45 %) .
- Most exchanges occurred with European partner FIUs, though cooperation with Asia and the Middle East increased notably.
The report includes practical examples of financial-crime typologies analysed in 2024 that concern the fiduciary, yachting, and real-estate fields:
- Typology 1 – Yachting: A Monaco-based yacht sale used to transfer multi-million-euro proceeds from an individual under investigation abroad for human trafficking .
- Typology 2 – Corporate services: Use of consultancy invoices and offshore structures to disguise taxable income and possible corruption proceeds.
- Typology 3 – Real estate: Purchase of a villa in Monaco by a foreign family linked to embezzlement and tax-evasion cases overseas .
5 – Supervision and sectoral observations
The AMSF’s Supervision Department conducted 36 on-site inspections in 2024 ( +56 %) and 28 Risk and Compliance meetings, reaching 64 entities in total . 61 % of these missions concerned non-financial professions, demonstrating the shift of regulatory focus toward DNFBPs.
Off-site supervision (desk reviews):
- 1 167 documents reviewed (+1 %) including internal procedures and activity reports.
- 1 169 risk questionnaires completed (+33 %), with an 84 % response rate ( up from 71 %) .
- Yachting and high-value-goods sectors recorded the highest growth in participation (+474 % and +703 % respectively).
A dedicated division now maintains the DRAKKAR register of all obliged entities ( 1 824 as of 31 December 2024 ) and their designated AML officers.
More than 400 continuous background checks were conducted during the year .
Follow-up and enforcement:
26 recommendation letters and 9 follow-up missions were completed in 2024 ( vs 7 and 8 in 2023 ) .
The newly established Sanctions Department received 14 inspection files for review in 2025 and can impose fines up to €10 million or revoke licences for serious breaches .
6 – Common findings and compliance challenges
The report’s annexes summarise the most frequent strengths and weaknesses observed across financial and non-financial sectors.
Positive practices
- Formalized, regularly updated risk assessments (EGR/BWRA).
- Clear, documented internal procedures consistent with activities.
- Management involvement in AML governance.
- Improved training programs and higher awareness of reporting duties.
- Late or incomplete risk assessments; limited treatment of terrorist-financing and proliferation risks.
- Inconsistent identification of beneficial owners and inadequate documentation of source of wealth/funds.
- Weak risk-based classification of clients and transactions.
- Limited or untested internal-control frameworks.
- Incomplete or infrequent staff training.
- Slow submission or missing annual activity reports (only 38 % of entities).
- Gaps in enhanced due diligence for politically exposed persons (PEPs) and high-risk countries.
- Insufficient monitoring of cash transactions, with some cumulative payments above €30 000 over six months.
7 – Implications for TCSP, Yachting and Real-Estate Sectors
Trust & Corporate Services Providers (TCSPs)
TCSPs remain pivotal in detecting and preventing misuse of corporate vehicles. The AMSF expects more systematic verification of beneficial-ownership information, tighter control of cross-border structures, and formal evidence of risk-based client monitoring.
Yachting Businesses
Yacht brokers, dealers, and managers now fall fully under the AML/CFT regime. The report’s typology 1 demonstrates the sector’s exposure to international criminal proceeds. Firms must ensure pre-transaction screening of clients, maintain documentary proof of funds, and promptly file STRs via goAML.
Real-Estate Agents and Developers
The near-doubling of STRs from this sector shows progress, but the AMSF still identifies shortcomings in verifying source of funds and purpose of transactions. Agencies are urged to keep detailed due-diligence files and update their risk assessments annually.
8 – Outlook for 2025
The AMSF plans to:
- Expand staff to 80 and strengthen follow-up inspections.
- Refine use of STRIX for more granular, risk-based analysis.
- Continue training and guidance for non-financial professions.
- Prioritise enforcement of the new sanctions framework.
The AMSF 2024 Report confirms a decisive step in Monaco’s AML/CFT regime: stronger institutional independence, deeper supervision, and growing participation from the non-financial sector.
For TCSPs, yachting companies, and real-estate professionals, the key takeaway is the same compliance expectations are rising. Each firm should reassess its AML/CFT risk management, update internal controls, and maintain open, timely cooperation with the AMSF.
By doing so, the industry will not only meet the Authority’s standards but also contribute to safeguarding Monaco’s reputation as a transparent and secure international financial centre.
For more information and help navigating compliance issues, please contact Peter Brigham: p.brigham@rosemont-mc.com
(Source: Autorité Monégasque de Sécurité Financière – Rapport d’activité 2024)
Credit Picture Antoine Contenseau