AMSF • New practical guide on internal AML/CFT procedures (15 January 2025)

On 15 January 2025, the Monegasque Financial Security Authority (AMSF) published a Practical Guide #4 - Internal procedures to combat money laundering, the financing of terrorism and the proliferation of weapons of mass destruction, and corruption (AML/CFT-P/C), which reflects the legal and regulatory obligations in force on 1 January 2025.

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SUMMARY

Points covered by the Guide:

1. Obligations relating specifically to AML/CFT-P/C procedures:
   • Drafting and updating of AML/CFT-P/C procedures in French.
   • Appointment of an AML/CFT-P/C Officer with a high hierarchical position.
   • Communication of AML/CFT-P/C procedures to the AMSF and incorporation of periodic updates.
2. Detailed content of AML/CFT-P/C procedures:
   • Assessment of the risks associated with the business, activities.
   • Internal organisation and staff training.
   • Due diligence measures based on client and transaction profiles.
   • Identification of beneficial owners and treatment of politically exposed persons (PEPs).
3. Practical approach:
   • Adaptation of vigilance levels according to identified risks.
   • Operational requirements for complex transactions or transactions involving high-risk jurisdictions.
   • Application of financial sanctions and suspicious transaction reports.

Case studies and practical tools included in the Guide:

• A structured methodology for identifying and verifying the identity of clients.
• Explanatory diagrams to clarify the due diligence process.
• A fictitious case study taken from an AMSF engagement report, which exposes common errors and suggests appropriate solutions.

Points to watch and common errors identified during audits:

• Lack of formal approval of procedures.
• Procedures that are too theoretical or not adapted to actual practice.
• Lists of countries at risk or regulatory definitions that have not been updated.

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