Monaco and the FATF grey list: where the Principality stands, and what it obliges
Written by Julien Rossi, Tax, licensing and compliance lead. Reviewed by Camille Perrin. Updated 20 September 2026. Status checked on 19 September 2026. Reading time 12 minutes.
Short answer
Monaco was placed under increased monitoring, the list everyone calls the FATF grey list, in June 2024. On the FATF's own list page, read on 19 September 2026, Monaco was still named there. The latest statement was dated 19 June 2026, and in it the FATF made an initial determination that Monaco has substantially completed its action plan.
On this page
- Is Monaco listed today
- What increased monitoring means
- High risk, or a different list
- Why Monaco was listed in June 2024
- What has changed since 2022
- Enhanced due diligence, and who asks for it
- The EU list of high-risk third countries
- The two lists side by side
- What the listing obliges a company to do
- What an obliged entity risks
- Accounts and company formation
- What has to happen before the listing ends
- What no official source publishes
- From our practice
- Sources
- Frequently asked questions
Is Monaco on the FATF grey list today?
Monaco was named under "Jurisdictions under Increased Monitoring (i.e. 'grey list')" on the Financial Action Task Force's own list page when we read it on 19 September 2026, and the statement linked above that list was "Jurisdictions under Increased Monitoring, 19 June 2026". Nothing published since supersedes it.
Status callout. Read on the FATF's list page on 19 September 2026: Monaco is named under Jurisdictions under Increased Monitoring. The statement above the list is dated 19 June 2026. This page is re-read and re-dated before publication and after every FATF plenary.
A listing describes how a jurisdiction's anti-money-laundering system performs against the FATF Recommendations. It says nothing about whether a company may lawfully be formed there, hold domiciliation in Monaco or trade, and it imposes no tax, no rate and no filing on a Monegasque company.
The newest official word of any kind is the Government's release of 11 September 2026: the FATF's ICRG process is en cours, under way, and an on-site visit in the Principality is planned. No official source announces an exit.
What is the FATF grey list, and what does "increased monitoring" mean?
"Grey list" is the world's word. The FATF's own heading is Jurisdictions under Increased Monitoring, and the FATF's own definition is short: "When the FATF places a jurisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring."
Two documents carry the two lists, and the FATF describes them as "two FATF public documents that are issued three times a year". That rhythm is the only published clock in the whole process. No statute, no FATF page and no Monegasque release gives a deadline for a country's exit.
Is Monaco a high-risk country for money laundering?
"High-risk" is the name of the other list. The FATF keeps two, and Monaco is on the one that describes a country working through an agreed action plan, not the one that calls for counter-measures. After MONEYVAL's follow-up of December 2024 the Government recorded that 39 of a total of 40 Recommendations were rated positively.
| The list | The FATF's own name | What the FATF says it means | On it when we read the page |
|---|---|---|---|
| Grey list | Jurisdictions under Increased Monitoring | the country "has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring" | 22 jurisdictions, our count on 19 September 2026, Monaco among them |
| Black list | High-Risk Jurisdictions subject to a Call for Action | the FATF calls on members to act against the risk the jurisdiction presents | 3 jurisdictions: the Democratic People's Republic of Korea, Iran and Myanmar. Monaco is not one of them |
| Neither | Jurisdictions No Longer subject to Increased Monitoring by the FATF | the country has left the grey list at a plenary | Algeria and Namibia, removed by the statement of 19 June 2026 |
Why was Monaco put on the grey list in June 2024?
In June 2024 Monaco "made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime", and its action plan was set that month. The day of the month circulates widely and is in none of the official texts cited here, so this page writes June 2024. The action plan itself is the answer to why, and the FATF enumerates it as six reforms.
- (1) "strengthening the understanding of risk in relation to money laundering and income tax fraud committed abroad".
- (2) "demonstrating a sustained increase in outbound requests to identify and seek the seizure of criminal assets abroad".
- (3) "enhancing the application of sanctions for AML/CFT breaches and breaches of basic and beneficial ownership requirements".
- (4) "completing its resourcing program for its FIU and strengthen the quality and timeliness of STR reporting", the financial intelligence unit and suspicious-transaction reporting.
- (5) "enhancing judicial efficiency, including through increasing resources of investigative judges and prosecutors and the application of effective, dissuasive and proportionate sanctions for money laundering".
- (6) "increasing the seizure of property suspected to derive from criminal activities".
What has Monaco changed since the 2022 evaluation?
The reforms did not start with the listing and did not stop at it. Each step below is dated because a document is dated, not because a period was running.
- 01
fourteen dated points from the 2022 on-site visit to the Government's release of 11 September 2026
- 02
then the status read point
- 03
and beyond it two explicitly indeterminate markers for the visit and the plenary decision
Figure 1. The process so far, and what is not dated: fourteen dated points from the 2022 on-site visit to the Government's release of 11 September 2026, then the status read point, and beyond it two explicitly indeterminate markers for the visit and the plenary decision
1. MONEYVAL's on-site visit ran from 21 February to 4 March 2022, and the mutual evaluation report that followed is dated 31 January 2023 on the FATF site.
2. Five anti-money-laundering laws were adopted in December 2022, ahead of the report, and the Government describes a deep overhaul of the legislation after its publication in January 2023.
3. The national coordination and monitoring committee was created in December 2021, and a Sovereign Ordinance of February 2023 strengthened its missions. That page gives no number for the ordinance, so this page prints none.
4. SICCFIN became the Autorité Monégasque de Sécurité Financière (AMSF), an independent administrative authority holding three services in one: financial intelligence unit, supervision and sanction.
5. In August 2024 the Secrétariat Permanent LBC/FT, the permanent anti-money-laundering secretariat, was installed beside the Minister of State.
6. On 30 October 2024 the committee met in full for the first time after the listing, and the Government wrote that "la Principauté a une obligation de résultat", the Principality is bound to deliver a result.
7. MONEYVAL's follow-up of December 2024 re-rated 15 Recommendations, which brought the count rated positively to 39 of 40.
8. On 24 October 2025 the second progress report was adopted, with three magistrates recruited and two of them assigned to the new pôle économique et financier, the economic and financial crime unit. The Stratégie Nationale 2025-2027 followed on 24 November 2025.
Does the FATF tell banks to apply enhanced due diligence to Monaco?
No, and the FATF says so in the same statement that keeps Monaco on the list: "The FATF does not call for the application of enhanced due diligence measures to be applied to these jurisdictions." It adds that its Standards "do not envisage derisking, or cutting-off entire classes of customers, but call for the application of a risk-based approach", and it asks members to take the listing into account in their risk analysis.
An automatic duty does exist in this story. It belongs to a different instrument, made by a different body, and it binds banks and other gatekeepers inside the European Union rather than the FATF's members generally. Section 7 gives it, with the Commission's own words, and section 9 sets the two side by side.
Monaco is also on the EU list of high-risk third countries
Monaco is listed twice over, by two bodies, on two clocks. The second listing is the European Union's, it is younger than the FATF's, and it is the one that carries an automatic obligation. Monaco is outside the European Union, so the EU list binds EU obliged entities dealing with Monaco; it does not bind Monaco.
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The FATF grey list and the EU list, side by side
Two bodies, two instruments, two dates and two clocks. Reading them as one list produces the error the field runs on: attributing to the FATF an automatic duty that the FATF explicitly disclaims, and missing the duty that genuinely is automatic.
| Question | FATF grey list | EU list of high-risk third countries |
|---|---|---|
| Who makes it | the Financial Action Task Force, at a plenary | the European Commission, by delegated regulation |
| The instrument | a public statement, Jurisdictions under Increased Monitoring | Delegated Regulation (EU) 2016/1675, as amended |
| Monaco's date | June 2024 | 5 August 2025, entry into force |
| What it obliges | no call for enhanced due diligence, no de-risking, a risk-based approach and the information taken into members' risk analysis | increased checks by gatekeepers, as the Commission describes Article 18a |
| Who it binds | FATF members, in their own risk analysis | EU obliged entities dealing with Monaco, not Monaco |
| How often it moves | three times a year, when the two documents are issued | no published rhythm |
| How it ends | an on-site assessment, then a plenary decision | no rule and no period is published |
the FATF's members in their risk analysis
EU obliged entities dealing with Monaco under Article 18a
Article 18a
and Monegasque obliged entities applying enhanced vigilance to the States that Monaco's own ministerial order names
Figure 2. Who each listing actually binds, in three panels: the FATF's members in their risk analysis, EU obliged entities dealing with Monaco under Article 18a, and Monegasque obliged entities applying enhanced vigilance to the States that Monaco's own ministerial order names
One observation, and it is an observation rather than a rule: Algeria and Namibia left the FATF list by the statement of 19 June 2026 and were still in the Commission's table when we read it three months later, each with 5 August 2025 beside it. No official sentence states that a lag exists.
What the listing actually obliges a Monaco company to do
1. Declare the beneficial owner. Every company on the Répertoire du Commerce et de l'Industrie (RCI) declares the natural person holding at least 25% of capital or voting rights, or control by other means. Changes are declared within one month, and the formalities are free (Loi n° 1.362, Art. 22-1).
2. Why that register, and why now. Reform (3) of the action plan is about sanctions for breaches of basic and beneficial-ownership requirements, so the register is the part of a company file the process is looking at directly.
3. A beneficial owner is a person, not a stand-in. Whether a name may be put in front of another person is a question Monegasque law answers on its own terms, in the nominee director guide.
4. What a documented set-up looks like. The activity, the premises and the gérant (manager) named in the autorisation d'exercer (business authorisation) are the same facts a supervised counterparty asks about, which is why choosing between the authorised business-centre formulas in Monaco and renting an office in Monaco belong to the file rather than to the decoration.
5. What does not follow. No tax, no rate and no filing follows from the listing. Nothing in either instrument reaches a Monegasque company's profits, its returns or its accounts.
What an obliged entity risks under Loi n° 1.362
The heavy figures in Monegasque anti-money-laundering law fall on obliged entities: banks, corporate-services providers, estate agents and the other categories listed in Art. 1er of the act. An ordinary trading company is not one of them, and confusing the two is how a EUR 1 million ceiling ends up quoted at a founder who owes a free declaration. The act also fixes Monaco's own list of high-risk States, which is a third list again.
| Duty or sanction | Who owes it or faces it | Figure or period | Article |
|---|---|---|---|
| Declare the beneficial owner to the register annexed to the RCI | every company on the RCI | at least 25% of capital or voting rights, or control by other means; changes within one month; free | Art. 22-1 |
| Apply enhanced vigilance to the States on Monaco's own high-risk list, fixed by arrêté ministériel (ministerial order) | obliged entities | the order is n° 2021-703 of 8 November 2021; the due-diligence rules apply "sous la forme de mesures de vigilance renforcées" | Arts. 14-1 and 14-2 |
| Administrative fine | obliged entities | up to EUR 1 million, or 10% of net banking income or annual turnover excluding tax, or twice the gain, the highest figure being retained; up to EUR 10 million for the entities of Art. 1er 1° to 4° and 24° to 28° | Art. 65-8, 7° |
| Suspension or revocation of the autorisation d'exercer or of the company's constitution authorisation, and publication of the decision | obliged entities | no figure; the sanction decision may be published | Art. 65-8, 9° and 12° |
| Settlement of a sanction by an accepted proposal | obliged entities | only where the fine does not exceed EUR 100,000; one month to accept or refuse | Art. 65-2 |
Does the grey list make it harder to open an account or form a company?
No official measurement exists. Neither the FATF, nor the Commission, nor the Monegasque authorities publish account-opening times, refusal rates or transaction costs for Monaco, before or after June 2024. Two advisers wrote in 2024 and 2025 that scrutiny of corporate services and of account opening had tightened [market: boldergroup.com, delforgelaw.com, accessed 2026-09-08], and those are advisers' statements, not measurements. The FATF's own position is the one quoted in section 6: a risk-based approach, and no call for de-risking.
What the law gives is narrower and firmer. A company in formation is within the statutory right to a deposit account under Loi n° 1.492 of 8 July 2020, Art. 2, 4°, on the receipt issued by the Direction du Développement Économique, and the documents a bank may ask for are listed in arrêté ministériel n° 2020-664 of 5 October 2020; that subject belongs to a corporate account with a Monegasque bank. On formation itself, no source read for this page says the listing changes the authorisation procedure, and no page here will say what an individual bank or authority will decide.
What has to happen before Monaco leaves the grey list?
1. The initial determination, 19 June 2026. The FATF found that Monaco "has substantially completed its action plan and warrants an on-site assessment to verify that the implementation of AML/CFT reforms has begun and is being sustained". The Government describes it as a fourth progress report following three earlier submissions.
2. The on-site visit. Announced the same day, with its date "encore à déterminer", still to be fixed, and its purpose to confirm that the reforms are fully embedded and durable.
3. The process as at 11 September 2026. The coordination committee met on 10 September to take stock of the ICRG process, which is under way, and the Government wrote that the progress has led the FATF to plan an on-site visit in the Principality.
4. Then a plenary decides. The FATF issues its two public documents three times a year. No date is published for the visit, and none for the decision, so this page gives neither.
The Government's own account of what follows an exit is worth the last line of this section: the third Évaluation Nationale des Risques (national risk assessment) and MONEYVAL's next evaluation of Monaco are ahead. The listing ends at a plenary; the scrutiny of files does not.
What no official source publishes
- The exact day of the June 2024 listing: the FATF statement of that month was not read.
- Whether the on-site visit has taken place, and on what date.
- The date of the next FATF plenary, or of any future one.
- How and when the EU removes a country after an FATF exit.
- Which amending act added Monaco to the EU list: EUR-Lex was not read.
- Which directive carries Article 18a, asserted by us: the Commission attributes it to Directive (EU) 2018/843.
- MONEYVAL's December 2024 report itself, so the compliance count here is the Government's 39 of 40.
- Monaco's effectiveness ratings: the FATF country page's ratings widget is headed "4th round France ratings" and is unusable.
- Any measured effect on account opening, refusals or costs; and the contents of arrêté ministériel n° 2021-703.
From our practice
Julien Rossi, Tax, licensing and compliance lead, thirteen years in the work and the last seven on Monaco.
From our practice. The question we are asked is whether a listing makes a Monaco company unusable. What we actually handle is the file: the authorisation dossier, the registration and the filings that follow, and the part of it this page touches is the beneficial-owner declaration, which every registered company owes, runs on one month and costs nothing. We do not run anti-money-laundering programmes, audit compliance, speak for the AMSF or predict what a bank will do.
Sources
Official pages and texts only. The FATF and the Commission publish in English themselves, so those are the originals; every Monegasque government release is linked in French, because the project holds recorded cases of an English government page differing from its French source. The ratings widget on the FATF's Monaco page was not used.
- FATF, "Black and grey" lists: the status line, the definition of increased monitoring, the three jurisdictions on the call-for-action list, the three-times-a-year rhythm, and the source of our own count. Read 19 September 2026.
- FATF, Jurisdictions under Increased Monitoring, 19 June 2026: the initial determination, the six reforms, and the two sentences on due diligence and de-risking. Accessed 6 September 2026.
- European Commission, high-risk third countries: Monaco in force 5 August 2025, the delegated regulations, and the Article 18a sentence. Read 19 September 2026.
- Government of Monaco, release of 19 June 2026: the fourth progress report, the preliminary conclusion, the on-site visit with no date. Read 19 September 2026.
- Government of Monaco, release of 11 September 2026: the ICRG process under way, the planned visit, and what comes after an exit. Read 19 September 2026.
- Loi n° 1.362 of 3 August 2009: Arts. 14-1, 14-2, 22-1, 65-2 and 65-8 (7°, 9°, 12°). Accessed 6 September 2026.
- FATF, Monaco country page: MONEYVAL membership, the 2022 on-site dates, the follow-up of 23 December 2024. Read 19 September 2026.
- Government of Monaco, anti-money-laundering action page: the committee, the February 2023 ordinance, SICCFIN to AMSF, the legislative history, the Stratégie Nationale 2025-2027. Accessed 6 September 2026.
- Government of Monaco, release of 24 October 2025: the second progress report and the pôle économique et financier. Accessed 6 September 2026.
- Government of Monaco, release of 10 June 2025: "39 sur un total de 40", and the sentence that grey-listed third countries are then entered on the EU's equivalent list. Accessed 6 September 2026.
- Government of Monaco, release of 30 October 2024: "la Principauté a une obligation de résultat". Accessed 6 September 2026.
- AMSF, reminder of the beneficial-owner declaration: the 25% test, the one-month period, and the fact that the formalities are free. Accessed 6 September 2026.
Where your own file actually sits
Answered with the article
+ Is Monaco on the FATF grey list today?
Read on the FATF's own list page on 19 September 2026: Monaco was named under Jurisdictions under Increased Monitoring, and the statement linked above that list was dated 19 June 2026. No official source announces an exit. A status can change at a plenary, so check the list page itself.
+ When was Monaco added to the grey list, and why?
June 2024, when Monaco made a high-level political commitment to work with the FATF and MONEYVAL, and its action plan was set. The reasons are the six reforms the FATF enumerates, from risk understanding to the seizure of suspected criminal property. The exact day is in none of the official texts cited here.
+ What is the FATF grey list, and what does "increased monitoring" mean?
In the FATF's words, the country "has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring". The FATF issues its two public documents three times a year. MONEYVAL, the Council of Europe committee, is the body that evaluates Monaco.
+ Is the grey list the same as the black list?
No. The black list is High-Risk Jurisdictions subject to a Call for Action, and it held three jurisdictions when we read it on 19 September 2026: the Democratic People's Republic of Korea, Iran and Myanmar. Monaco is not one of them. Monaco is on the increased-monitoring list, which describes a country working to an agreed action plan.
+ Which countries are on the FATF grey list and the black list in 2026?
Our count of the FATF's list page on 19 September 2026: 22 jurisdictions under increased monitoring and 3 on the call-for-action list. The FATF does not print those numbers, and the lists move three times a year, so the reliable answer is the FATF page itself rather than a roster here.
+ Does the FATF tell banks to apply enhanced due diligence to Monaco?
No. The FATF states that it "does not call for the application of enhanced due diligence measures to be applied to these jurisdictions", and that its Standards "do not envisage derisking, or cutting-off entire classes of customers, but call for the application of a risk-based approach". The automatic duty is the European Union's; see the next answer.
+ Is Monaco on the EU list of high-risk third countries, and since when?
Yes, in force since 5 August 2025 in the European Commission's table of high-risk third countries, carried by Delegated Regulation (EU) 2016/1675 as amended. Not proposed: in force. The EU tax list of 17 February 2026, on which Monaco is cooperative with no pending commitments, is a separate instrument.
+ What does the EU listing change for a Monaco company dealing with a bank or a counterparty in the EU?
The Commission's page states that "gatekeepers, such as banks, are obliged to carefully consider business relationships and transactions involving high-risk third countries through increased checks and control measures defined under Article 18a of the Directive", which it attributes to Directive (EU) 2018/843. Monaco sits outside the EU, so the duty falls on EU obliged entities.
+ What is the difference between the FATF list and the EU list?
Two bodies, two instruments, two dates, two clocks. The FATF lists by plenary statement, from June 2024, and calls for a risk-based approach rather than enhanced due diligence. The Commission lists by delegated regulation, in force for Monaco since 5 August 2025, and its list carries the Article 18a duty on EU gatekeepers.
+ If the FATF removes Monaco, does the EU listing end on the same day?
The Commission publishes no rule and no period for removal. One observation, from two official pages: Algeria and Namibia left the FATF list by the statement of 19 June 2026 and were still in the Commission's table on 19 September 2026. No official sentence states that a lag exists, so treat the two lists as two clocks.
+ When could Monaco leave the grey list, and what has to happen first?
The FATF made an initial determination on 19 June 2026 that an on-site assessment is warranted; as at 11 September 2026 the visit was planned and the ICRG process under way; then a plenary decides. The FATF issues its statements three times a year. No date is published. Bloomberg reported an expected exit on 16 September 2026, as press expectation.
+ Does the grey list make it harder to open a bank account in Monaco?
No official measurement of account-opening times, refusals or costs is published. The FATF calls for a risk-based approach and not for de-risking; two advisers report tighter onboarding, as advisers' statements. A company in formation has a statutory route to a deposit account, which belongs with a corporate account with a Monegasque bank.
+ Does the grey list affect setting up a company or obtaining the business authorisation?
No source read for this page says the listing changes the authorisation procedure, and this page asserts nothing further. What a founder's file does owe is the beneficial-owner declaration to the register annexed to the RCI, and reform (3) of the action plan, on sanctions for beneficial-ownership breaches, is why that register is under scrutiny now.
+ What anti-money-laundering duties does a Monaco company itself have?
The beneficial-owner declaration: the natural person holding at least 25% of capital or voting rights, or control by other means, with changes declared within one month, and the formalities free (Loi n° 1.362, Art. 22-1). The enhanced-vigilance and sanction regimes of Arts. 14-2, 65-2 and 65-8 bind obliged entities, not an ordinary trading company.
+ What is MONEYVAL, and what is a mutual evaluation report?
MONEYVAL is the Council of Europe committee that evaluates Monaco. Its mutual evaluation measured Monaco against the 40 Recommendations after an on-site visit from 21 February to 4 March 2022, in a report dated 31 January 2023. Its follow-up of 23 December 2024 re-rated 15 Recommendations, after which 39 of 40 were rated positively. ---
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