Taken together, the decisions provide an increasingly clear picture of what the AMSF expects from regulated financial institutions, and, by extension, useful guidance for other Monaco obliged entities applying the same AML/CFT framework.
The three sanctions concern UBS (Monaco) S.A., Banque Havilland (Monaco), now Moncrief Private Bank (Monaco), and Julius Baer Wealth Management (Monaco) S.A.M. All decisions may be appealed.
UBS Monaco — €6 million
In April 2026, the AMSF imposed a €6 million administrative penalty on UBS (Monaco) following an inspection conducted in 2024.The regulator identified a broad range of deficiencies affecting the effectiveness of the bank’s AML framework. These included delays in establishing an adequate institutional risk assessment, shortcomings in internal controls and transaction monitoring, deficiencies in identifying ownership and control chains within complex structures, insufficient corroboration of customers’ socio-economic background and source of wealth, and delays in submitting suspicious transaction reports.
The AMSF emphasised that effective KYC requires more than identifying the immediate shareholder of a company: institutions must understand and verify the ownership and control chain behind complex structures.
The decision was ordered to be published nominatively for five years.
Banque Havilland / Moncrief Private Bank — €1 million
In June 2026, the AMSF imposed a €1 million penalty on Banque Havilland (Monaco), subsequently renamed Moncrief Private Bank (Monaco).Again, the regulator identified deficiencies across several fundamental components of the AML framework.
The AMSF considered that the bank’s risk-classification methodology had underestimated the actual risk presented by its client base, despite significant exposure to non-resident customers, foreign private holding companies and higher-risk clients.
The decision also identified deficiencies relating to source of wealth and source of funds, updating of customer and beneficial-owner information, transaction monitoring and enhanced examination of unusual transactions.
Significantly, the AMSF found that two business relationships had been maintained despite the institution being unable to fulfil the required customer-due-diligence obligations.
Julius Baer Wealth Management Monaco — €1.5 million
The most recent decision, dated 25 August 2026 and published on 4 September, imposed a €1.5 million penalty on Julius Baer Wealth Management (Monaco).The decision focuses particularly on the relationship between the Monaco wealth-management company (asset manager) and another Julius Baer Monaco group entity (the bank) to which a number of AML functions had effectively been delegated.
The AMSF concluded that the intra-group arrangements did not adequately define responsibilities, risk classification, supervision and information-sharing mechanisms.
The regulator’s message is important: delegation does not transfer regulatory responsibility. A Monaco obliged entity must retain sufficient knowledge, oversight and ability to challenge AML work performed elsewhere in the group.
The decision also highlights transaction monitoring. Fixed cash thresholds, including €10,000 for withdrawals and €2,000 for deposits, were criticised because they did not sufficiently reflect individual customer risk, PEP status, geography or expected behaviour.
The AMSF also sanctioned delays in filing suspicious transaction reports.
What common themes emerge?
Although the facts differ, several consistent supervisory expectations can be identified.Risk assessments must reflect reality. Generic or group-level models are insufficient where they do not accurately capture the particular risks of the Monaco business and client population.
Understanding beneficial ownership means understanding control. Regulators increasingly expect firms to look beyond formal shareholdings and understand the complete ownership and control structure.
Source of wealth and source of funds must be corroborated. Client explanations alone may be insufficient where the relationship is higher risk.
Transaction monitoring must be contextual. Automated thresholds and alerts are tools, not substitutes for informed analysis. A transaction should be assessed against the client’s risk profile, expected behaviour, geography and economic background.
Outsourcing does not outsource responsibility. Whether AML work is performed by another group company or an external provider, the regulated Monaco entity remains accountable.
Finally, suspicious transaction reporting must be timely. Once suspicion has crystallised, lengthy internal investigation cannot be allowed to deprive the FIU of the opportunity to act.
These decisions indicate a clear evolution in Monaco supervision: the focus is increasingly on whether AML systems are effective in practice, rather than simply whether policies and procedures formally exist.
For all Monaco obliged entities, not only banks, that is perhaps the most important lesson.
Rosemont Consulting SARL in Monaco provides advice and assistance with respect to Monaco and France compliance obligations.
For more information, please contact us at consulting@rosemont.mc
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