AMSF • Strategic Analysis "Professional Money Laundering" (Report)

On 14 April 2025, the Monegasque Financial Security Authority (AMSF) published a Strategic Analysis Report on "Professional Money Laundering" (March 2025), service providers "who use their expertise to implement sophisticated money laundering techniques on behalf of other individuals, organisations and criminal networks" (available in English and in French).

As part of its operational and strategic analysis missions, the AMSF's Financial Intelligence Unit (FIU) is shedding light on the methods used and the multiple forms that their involvement is likely to take in the Monegasque context.

The AMSF Report, which is informative in nature, is in line with the Financial Action Task Force (FATF) Report on "Professional Money Laundering" of July 2018.

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Contents of the Report

Overview

The Report first describes the functions and characteristics of "professional money laundering" who provide "money-laundering services in exchange for a commission, fee or other type of profit", using their expertise (knowledge of regulatory loopholes, banking systems, legal structures) which can be combined with technological tools (darknet, encrypted exchange platforms, etc.) to conceal the nature, source, location, ownership, control, origin and/or destination of funds.

Typological analysis

The Report then proposes two operational typologies based on analyses of specific cases, linked to the Monegasque context, illustrating the cross-border use of "professional money laundering":

• Typology 1 - Exploiting false insurance policies to hide illicit trade. A transport company located abroad, holding accounts with Monegasque financial institutions, pays abnormally high premiums to an accomplice insurance company registered in another foreign country, concealing illicit commercial activities.
• Typology 2 - Moving funds through a legal intermediary ("blender", transposable to payment aggregators for online merchant services, invoice factoring firms, cryptocurrency tumblers). A foreign law firm centralises funds from various sources, then transfers them to a commercial company registered in Monaco, in a single transaction under generic headings ("contract", "escrow release").

Red-flag indicators

Lastly, the Report lists a series of warning indicators of illicit activities noted by the FIU in recent operational cases and international publications:

• professional intermediaries (role without apparent economic motive, management of funds on behalf of an anonymous end client, frequent change of intermediaries, etc.)
• insurance-based mechanisms (disproportionate insurance premiums, frequent indemnities, etc.)
• transaction patterns (use of escrow mechanisms to move funds without contractual justification, sudden and significant development of intangible services, etc.).
• trade-based money laundering (absence of any apparent link with the client's declared activity, inconsistent commercial supporting documents, falsification for the purpose of over/under-invoicing, etc.)
• adverse media (negative - general or investigative - press)
• companies and corporate structures (complex structures, frequent changes in shareholders or management, short-lived company, etc.)
• financial statements (signs of parallel accounting, cash flow inconsistent with business, auditors with no verifiable address, etc.)
• advertising (low-quality, uninformative advertising, signs of concealed promotion, etc.)
• international linkages (high-risk jurisdictions, or with potential advantages for financial crime, etc.)

Conclusion

The Report highlights the rapid development of modus operandi and the need for information and coordination between public and private players to detect and to identify professional money laundering.

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