Monaco Comes Off the FATF Grey List: What It Means for Property Deals

The Financial Action Task Force removed Monaco from its grey list on 30 October 2026, 28 months after adding it. For estate agents in Monaco and their clients, the due diligence rules are exactly as they were. The decision matters mainly to banks and other parties abroad that send money to Monaco or do business there. Monaco also remains on the EU’s list of high-risk third countries.

The FATF announced the move after its October plenary. Bulgaria, Côte d’Ivoire and the Democratic Republic of the Congo came off the list of jurisdictions under increased monitoring alongside Monaco. The FATF cited “significant progress” and asked Monaco to keep working with MONEYVAL, the Council of Europe’s anti-money-laundering body.

The grey list is aimed at the outside world. It tells banks and regulators elsewhere that a country has strategic weaknesses and is working to fix them. Coming off it leaves Monegasque law untouched. What shifts is how foreign institutions classify Monaco.


The rules in Monaco

Monaco’s anti-money-laundering statute, Law No. 1.362 of 3 August 2009, covers almost everyone involved in a property sale. Estate agents fall within it for sales, and for lettings where the monthly rent reaches a threshold set by sovereign ordinance. So do property dealers and banks. Notaries are caught whenever they take part in a property transaction or act for a client who is buying or selling.

Each must identify the client, anyone acting on the client’s behalf and the beneficial owner: the individual who ultimately owns or controls the client. When a property sits in a company, the duty goes further. Registered commercial companies and sociétés civiles must keep accurate, up-to-date records of their beneficial owners.

The FATF decision relaxes none of this. Nor was any of it new when Monaco was grey-listed in June 2024. The FATF’s complaint was about enforcement, not the rulebook.


What the evaluators found

MONEYVAL’s mutual evaluation, published in January 2023, rated three of the 11 areas it examined as “low”: supervision, money-laundering prosecutions and asset confiscation.

The evaluators found major gaps in access to beneficial ownership information. Sanctions, they said, were “limited, not proportionate, not dissuasive” and slow to arrive. Non-financial professions, estate agents among them, trailed the banks on compliance culture. The FATF’s June 2024 action plan reflected this: one of its six items called for tougher sanctions, including for beneficial ownership breaches.


A new watchdog, and fines

The main reform was Law No. 1.549 of 6 July 2023. It replaced SICCFIN with the Autorité monégasque de sécurité financière (AMSF), an independent authority that acts as Monaco’s FIU, supervisor and enforcer. The same law stiffened the penalties linked to the beneficial ownership register.

In December 2024 MONEYVAL upgraded Monaco’s ratings on 15 of the FATF’s 40 Recommendations. Only one is still rated “partially compliant”.

The evaluators also wanted evidence that the rules were being enforced. The AMSF has imposed about €10m in fines since April 2025, €6m of it on UBS, according to the Frankfurter Allgemeine Zeitung. The paper says property developers were not previously required to check the source of funds. It quotes Bruno Dalles, the AMSF’s director, calling real estate “a risk sector, especially in Monaco”. In June 2026 the FATF judged the action plan substantially complete and scheduled an on-site visit.


The EU list still applies

For counterparties abroad, leaving the grey list does not settle matters. The FATF does not ask anyone to apply enhanced due diligence to the jurisdictions it monitors. The EU does, through its own list of high-risk third countries. Monaco was added by Delegated Regulation (EU) 2025/1184, which took effect on 5 August 2025. Under Article 18a of Directive (EU) 2015/849, obliged entities in the EU, banks first among them, must apply enhanced due diligence to business relationships and transactions involving listed countries. According to the European Commission’s latest published update, Monaco is still on the list.

So an EU bank lending on a Monaco purchase, or receiving the proceeds of a sale, must keep applying those measures for as long as the listing stands.

Removal needs a new Commission delegated regulation, open to scrutiny by the European Parliament and the Council. No date has been set. The United Arab Emirates and Gibraltar offer a precedent: they left the FATF grey list in February 2024, but the EU removed them only in its June 2025 update.


Unchanged in practice

For an agency in Monaco and its clients, files are handled just as they were before 30 October. The parties and beneficial owners are identified, the source of funds is verified and the supporting documents are kept. The national framework moves on its own schedule: the government has already planned a third national risk assessment and Monaco’s next MONEYVAL evaluation.