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wanted to know if someone had a bank account example, the salesperson must refuse the
somewhere, we had to query all the banks in transaction because, if behind this couple a
money laundering network is dismantled which
writing and wait for them to respond. Since
© Michael Alesi / Direction de la communication Stéphane Puppo, banks have provided data on accounts and along to bother this little jeweller one day.
2021 and the implementation of FICOBAM,
finances Hamas, the law will inevitably come
safes. We thus have access to all accounts
However, we must not get paranoid either: in
Monaco, those subject to the rules are often
and safes, as do now the other competent
authorities, who can use it only for the fight
competent and generally know how to profile
against the financing of terrorism or money
their clients.
laundering. Moreover, the tool approved by
Responsable du pôle informatique de l’AMSF
Head of the Computer Science Department of AMSF
Monaco Cyber Security Agency (AMSN), the
data processing of which has been declared Are professionals afraid of losing some of
their client base?
Council on developments in the regulatory to the Personal Data Protection Authority SP: Is it better to lose doubtful clients or to
framework, whilst determining a trajectory in (CCIN), logs everything. We are very attentive risk bringing down the curtain? The issue
the fight against money laundering. to IT security because this data is critical and is there. On the contrary, they will gain new
a leak could be catastrophic. In addition to virtuous customers and we will be there to
How did you view the Moneyval report? controls from the IT Department (DSI), once support them. We are not in an ivory tower -
Did it put the cat amongst the pigeons to a year a third-party IT company checks our IT we understand that sometimes it is difficult
accelerate developments or is it too harsh security to prevent any hacking. to say no to a transaction.
a political statement? LD: When Switzerland was forced to abandon
LD: It is, above all, a report which talks about a STRIX files also make it possible to better banking secrecy, everyone thought that it
past period (before March 2022). The mapping map risks in the Principality. How is this would be an end to the predominance of the
of this period is quite accurate, to the extent done? banking centre, that banks would disappear.
that Monaco had fallen behind in this area. LD: We are the only ones in Europe to have this On the contrary - it is never a bad idea to invest
However, this report looks in the rear view tool permanently and completely across all in compliance. It is necessary and pragmatic.
mirror and does little justice to the tools being subject sectors. STRIX is a questionnaire on the I think everyone understands this, apart from
developed in Monaco such as FICOBAM, STRIX risks of entities (size, customer base, products some people who are worried about the future.
or goAML, which had not been in place long marketed, payment terms, geographical origin The economy is still adapting.
enough. The report in itself is neither a bad of customers etc) and the controls (internal
nor a good thing; we simply need to adapt our procedures) which make it possible to mitigate Monégasque bankers will soon be in court
practices and methods as quickly as possible them. According to Moneyval, there was a for having accepted hundreds of thousands
and be pragmatic. lack of granularity and very precise data on of euros in cash from a client. Would this
financial flows, following the geographical type of transaction still be possible today?
How do you see the evolution since this origins of funds entering and leaving Monaco. LD: Honestly, no. There are regular bank
report? We have overcome this problem thanks to checks which attest to this. From memory,
SP: The process started a year ago consisted STRIX. We now have a comprehensive analysis we haven't seen this for at least 10 years.
of reforming all procedures and recruiting of where funds come from and where they go, Banks have become very cautious about the
highly-specialised and varied staff (compliance jurisdiction by jurisdiction. Indeed, as Monaco use of cash. Let's not forget that these are
professionals, auditors, IT specialists, project does not have a central bank and a balance of all branches or subsidiaries of international
managers, lawyers etc). There are 34 of us payments, we had to find out how to answer groups which have very strict procedures.
today compared to 17 a year ago (and 13 two these questions ourselves. Thanks to STRIX, we This practice existed but no longer exists, as
years ago) and we need to recruit around 30 were able to determine that Monaco is more of we see today. The automatic exchange of tax
more individuals in 2024! We are banking on a transit place in terms of financing terrorism information was a real game-changer and was
these vital sparks to give a new dynamic to and not a place where operations are set up. the first vector of change.
the authority. The other important change is
technological, notably with goAML which, from For some professionals, it is sometimes You are part of the Moneyval Coordination
January 1 2024, makes it possible to register difficult to know how far to go. Should they Committee. Do you work on good terms with
st
suspicious transaction reports online. We have block a transaction in case of suspicion? other authorities?
also consolidated the Monaco Bank Accounts LD: There is no single answer. Everything LD: Yes: there is now a common strategy and
and Safes File (FICOBAM), the bank account depends on the situation. When a transaction an aligned discourse. Everyone moves forward
management tool in Monaco, and opened is pending, the first instinct should be to together. At the last Moneyval plenary meeting
it to other state authorities (police, public contact the Financial Intelligence Unit (FIU). in December, representatives of the AMSF and
prosecutor's office, the Business Development We are listening - but be careful, suspicious the Department of Justice (DSJ) participated
Agency (DDE), tax services etc). transactions are statistically extremely rare together under the aegis of a delegation led by
for many obliged entities. the Minister of Finance and the Economy. The
What does such a tool change in real terms? SP: Clearly, if a couple arrives at a boutique fight against money laundering has become
SP: It changes everything! Previously, when we with €60,000 in cash to buy jewellery, for a multi-party domain, whereas before it was

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