Since the publication of the Moneyval report in January 2023, the Monegasque real estate sector has been facing a major shift in combating money laundering. Real estate agencies, already subject to stringent obligations since 2009, now have to contend with reinforced procedures and increased oversight. Let’s analyze the impacts of these new requirements and the strategies implemented to address them. A Constantly Evolving Legislative Framework Combating money laundering is not a new issue in Monaco. Since Law No. 1.362 of August 3, 2009, real estate professionals have been required to adhere to strict procedures. However, the Moneyval report highlighted the need to strengthen these measures. Taking advantage of the efficiency and structural flexibility that only Monaco’s state services could activate so quickly, a strengthening of legislative and regulatory measures was enacted in record time. The supervisory body (formerly SICCFIN) was consolidated through the creation of the AMSF (Monegasque Financial Security Authority). The AMSF can now oversee compliance failures and, more importantly, directly impose sanctions on defaulting companies (previously the responsibility of the Minister of State). The Principality’s ambition is clear: Monaco cannot tolerate any approximation in compliance. A Significant Impact on Agencies’ Daily Operations The new rules impose heavier obligations on information collection and transaction monitoring, significantly increasing the administrative burden for real estate agencies. Brokers must perform rigorous checks as soon as a client shows serious interest in a property. This includes collecting and analyzing identification documents, proof of address, as well as information on the source of funds and the client’s socio-economic background to verify the legitimacy of the economic transaction. While banks have significant human and financial resources to handle these procedures, smaller agencies—constituting the majority of the real estate sector in Monaco—struggle to meet these obligations. Without dedicated compliance staff, they often rely on specialized firms to ensure regulatory compliance. At Miells-Christie’s, one of Monaco’s leading agencies, we have established an internal compliance team and provided extensive training for all employees. To ensure strict compliance, we also collaborated for several months with a specialized law consulting firm. Outsourcing, even partially, does not relieve agencies of their legal responsibility. The agent remains on the front line for collecting information, while respecting confidentiality. A More Understanding Clientele The increased administrative procedures might seem off-putting to some clients, but the reality is more nuanced. With the standardization of procedures between real estate agents, banks, and notaries, these requirements are now perceived as an essential norm. Monegasque banks, subject to the same obligations, have gradually familiarized their clients with providing and updating the necessary confidential information, making these processes more accepted and integrated. For more complex transactions, such as those involving companies, administrative procedures sometimes require additional investigations. However, real estate agents can rely on local tax experts to ensure compliance with the processes. This ensures optimal support, even in more technical situations, without disrupting the transaction process. Many clients, particularly local residents, are now well-versed in these procedures. They understand that these requirements are not driven by intrusive curiosity, but by a legal obligation to prevent money laundering. Thus, business relationships are established on new foundations, strengthened by greater transparency and a clearer socio-economic context. This process allows clients to demonstrate their reliability, significantly reducing reluctance. Despite some variations in client responsiveness, refusals to cooperate remain rare. This shift in mindset greatly facilitates the work of real estate agents, allowing them to establish strong relationships of trust while respecting their legal and ethical obligations. A Clear Goal: Exiting the GAFI Grey List Monaco’s efforts to strengthen its regulatory framework and compliance aim to improve its international reputation. The primary goal is to exit the Financial Action Task Force (FATF) grey list by January 2026, a strategic priority for the country. This process includes intermediate evaluations scheduled for May and September 2025 to measure progress and adjust actions if necessary. These steps will not only track the progress of reforms but also reassure international partners of Monaco’s commitment to transparency and anti-money laundering standards. Finding a Balance Compliance represents a significant challenge for real estate agencies in Monaco. Between increasing requirements and the need to maintain smooth client relationships, professionals must strike a balance. Adequate training, collaboration with external experts, and transparent communication with clients are key to successfully navigating this transition while maintaining service quality. Discover also ...The Role of Notaries in the Principality of MonacoA GUIDE TO REAL ESTATE INVESTMENT IN MONACOCelebrating 25 Years of Solidarity with the No Finish Line Monaco