Monaco’s coordination committee for anti-money laundering strategy met on Thursday 4th December to review progress on reforms required to exit the Financial Action Task Force (FATF) grey list. Minister of State Christophe Mirmand chaired the meetings, which brought together government services, the National Council and private sector representatives.

The Principality was placed on FATF’s grey list in June 2024 following identification of strategic deficiencies in its anti-money laundering and counter-terrorism financing framework. The classification requires Monaco to address specific weaknesses under international monitoring.

Reform implementation recognised

Mirmand acknowledged advances made in 2025, thanking services, authorities, the National Council and private sector representatives for implementing major reforms in recent months. The international community has recognised this progress through FATF’s adoption of Monaco’s first two progress reports since the grey listing.

These reports represent formal milestones in the monitoring process, confirming Monaco is addressing identified deficiencies. However, grey list removal requires sustained demonstration of effectiveness across multiple criteria, not merely legislative changes.

Dual evaluation process

The meetings reviewed Monaco’s third progress report and upcoming stages in the FATF International Cooperation Review Group (ICRG) monitoring process. Participants were encouraged to maintain current reform efforts.

Beyond FATF compliance, Monaco must prepare for evaluation by Moneyval, the Council of Europe’s anti-money laundering monitoring body. The meetings addressed Monaco’s third national risk assessment, which identifies money laundering and terrorism financing vulnerabilities within the Principality.

This dual evaluation requirement means Monaco faces continuous international scrutiny of its financial integrity systems, even as it works to satisfy FATF criteria for grey list removal.

Private sector impact

Private sector representatives provided feedback on how grey listing affects their operations. The classification has increased scrutiny of Monaco transactions by international banks, raised compliance costs for financial services firms, and complicated cross-border business relationships.

Grey-listed jurisdictions face enhanced due diligence requirements from international financial institutions, which can affect transaction processing times and banking relationships. For Monaco’s financial sector, which depends on international connectivity, these operational impacts are significant.

The private sector’s inclusion in coordination meetings reflects government recognition that grey list removal serves both regulatory compliance and economic interests.

Path to delisting

FATF grey list removal requires jurisdictions to demonstrate measurable improvements in their anti-money laundering frameworks. This includes not only legislative reforms but evidence of effective implementation—enforcement actions, prosecutions and disruption of illicit financial flows.

Monaco’s progress reports to FATF document reforms enacted and their implementation. The ICRG monitors whether actions taken address the deficiencies that led to grey listing. Countries typically remain on the grey list for 12 to 24 months, though timelines vary based on progress demonstrated.

The coordination committee serves as Monaco’s internal mechanism for maintaining reform momentum and ensuring different sectors—public and private—work towards the common goal of restoring the Principality’s standing in international anti-money laundering frameworks.

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Photo credit: Stephane Danna, Government Communications Department