This list, initially established by Ministerial Order No. 2021-703 of 8 November 2021, is a key component of Monaco's AML/CFT-PF/CFT framework, adopted pursuant to Article 14-1 of Law No. 1.362 of 3 August 2009, as amended.
Key update
Ministerial Order No. 2026-433 adds the following jurisdictions to the ETHR list:
- Bosnia and Herzegovina
- Iraq
Extended reporting obligations
Article 2 of Ministerial Order No. 2026-433 further confirms that the reporting obligations under Chapter V of Law No. 1.362, as amended, pursuant to Article 41 thereof, remain extended to any transactions and facts concerning natural or legal persons domiciled, registered, or established in the Democratic People’s Republic of Korea and the Islamic Republic of Iran.
Updated list of high-risk jurisdictions (ETHR)
As updated by Ministerial Order No. 2026-433, the Monégasque ETHR list now comprises the following 30 States and territories:
- Afghanistan;
- Algeria;
- Angola;
- Bolivia;
- Bosnia and Herzegovina;
- Bulgaria;
- Cameroon;
- Democratic Republic of the Congo;
- Democratic People's Republic of Korea;
- Ivory Coast;
- Haiti;
- British Virgin Islands;
- Iraq;
- Islamic Republic of Iran;
- Kenya;
- Kuwait;
- Lao People's Democratic Republic;
- Lebanon;
- Myanmar/Burma;
- Namibia;
- Nepal;
- Papua New Guinea;
- Russian Federation;
- South Sudan;
- Syria;
- Trinidad and Tobago;
- Vanuatu;
- Venezuela;
- Vietnam;
- Yemen.
Alignment with international standards
The Monégasque ETHR list is aligned with international standards, in particular:
- the Financial Action Task Force (FATF) lists; and
- the European Union's list of high-risk third countries, annexed to Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016, as amended, supplementing Directive (EU) 2015/849.
Regulatory implications
Jurisdictions included on the ETHR list are deemed to present strategic deficiencies in their AML/CFT regimes. As a result, any business relationship or transaction connected with one of these jurisdictions is subject to an enhanced due diligence regime under Monégasque law.
Obligations for reporting entities
A link with a State or territory on the ETHR list triggers, for entities subject to Law No. 1.362, as amended, a set of enhanced obligations, including:
- implementing enhanced due diligence measures for any business relationship or transaction presenting such a link, pursuant to Article 14-2 of Law No. 1.362, as amended;
- documenting the assessed level of risk;
- adjusting, where necessary, the frequency of file reviews and transaction monitoring;
- retaining documentation evidencing the due diligence carried out.
Operational impacts to anticipate
Beyond its regulatory scope, this update typically calls for prompt operational adjustments. Reporting entities are advised to review:
- their internal high-risk country reference lists;
- the configuration of their screening and transaction monitoring tools;
- the consistency of their internal procedures and risk mapping in light of this change;
- client files with a connection to the newly listed jurisdictions, with a view to reassessment;
- training provided to compliance and operational teams.
How Rosemont can assist
Rosemont International supports clients in:
- monitoring regulatory developments in AML/CFT-PF/CFT matters;
- analysing jurisdictional risk exposure;
- adapting compliance frameworks;
- supporting private wealth and international structures.
For more information, please contact consulting@rosemont.mc.
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