Monaco’s financial-crime regulator has publicly defended the €6 million fine imposed on UBS Monaco, responding to commentary it says has misrepresented the ruling and clarifying the obligations on banks to verify complex corporate ownership structures.
In a statement dated 28th September, the Autorité Monégasque de Sécurité Financière (AMSF) said it wanted to set out the “foundations and scope” of the decision after what it called “inaccurate or approximate” comments published recently. Some analyses, it said, had questioned how it interpreted the law and used its own guidance, and had warned of the effect on legal certainty for the Principality’s banks and finance firms.
The fine, and the pushback
The penalty was handed down on 28th April and made public on 8th May. It followed an inspection between March and June 2024 of UBS’s Monaco subsidiary — the local arm of the Swiss banking giant, and one of the largest private banks in the Principality — and identified a series of anti-money-laundering failings, from too few compliance staff to weak checks on where some wealthy clients’ money came from. At €6 million, set against the bank’s average annual net banking income of around €132 million over the preceding three financial years, it was the largest fine imposed by the AMSF since its establishment in 2023.
The reasoning behind it drew unusually pointed commentary from lawyers and compliance specialists — enough for the regulator to respond in public so that, it said, “the debate rests on a legally accurate reading of the decision”.
No blanket requirement to collect articles of association
At the centre of the dispute is one of the findings: that UBS had not done enough to establish who ultimately owned and controlled some of its corporate clients — companies held through layers of other companies, an arrangement that can be used to obscure the real person behind an account.
Some commentary read this as the AMSF demanding that banks collect the founding documents, or articles of association, of every company in such a chain — an onerous burden. The regulator says that is a misreading. The finding, it stressed, “does not rest in any way on a general and systematic obligation to collect the articles of association of all interposed companies”, but on something more basic: that UBS simply did not hold enough documentation to establish, reliably, who was behind the accounts. In the words of the ruling itself, the bank “did not have, for the files examined, sufficient documentation allowing it to reconstruct, in an exhaustive and probative manner, the ownership and control structure of the complex structures concerned”.
Nor was the requirement a surprise, the AMSF added, pointing to UBS’s own internal procedures, which already required documentation to verify complex ownership and control structures. It said the bank could therefore not reasonably argue that the requirement was insufficiently clear or foreseeable.
‘They do not replace the law’
The second criticism was that the AMSF had leaned on its own guidelines as though they created new legal obligations. Not so, the authority said: the guidelines exist to help firms understand and apply the law, and “do not replace the law and do not constitute, in themselves, a new source of legally enforceable obligations”. A sanctions panel may refer to the guidelines to explain how existing legal and regulatory obligations apply in practice, the AMSF said, without creating or extending those obligations. In the UBS case, grievance number four, concerning the identification and verification of underlying corporate structures, was established “without reference to the guidelines”.
The authority framed its statement around what it called the “public-private partnership” at the heart of its work, pledging to “favour dialogue, education and transparency” while ensuring anti-money-laundering rules are fully obeyed, and inviting the sector to read the full decision rather than the commentary around it.
A year of sanctions
The UBS ruling is the most prominent of a run of AMSF penalties Monaco Life has reported over the past year. In December 2025, the authority fined two company-services firms — Landmark Management €800,000 and International Corporate Structuring (ICS) €500,000. In 2026 it turned to the banks and larger houses: UBS Monaco’s €6 million in May, €1 million for Moncrief Private Bank, formerly Banque Havilland (Monaco), in July, and €1.5 million for the Monaco arm of Julius Baer in September.
Its most recent annual report showed enforcement rising sharply, with on-site inspections up by half and a record number of suspicious-transaction reports.
See also:
Monaco’s financial crime watchdog blocks €87 million as reports hit record high
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Main photo credit: Cassandra Tanti