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SOCIÉTÉ GÉNÉRALE PRIVATE BANKING MONACO:

“It appears very likely that the grey list would impact

international transactions”

By Milena Radoman
80% of suspicious transaction reports are generated by banks. Nicolas Feit, Managing Director
of Société Générale Private Banking Monaco, explains how this happens in practice for a wealth
management establishment.

In concrete terms, if a bank has suspicions Beyond legal obligations, what specific their domestic operations, particularly because
about a transaction, how can it intervene? measures has Société Générale taken in our level of requirements is already high. On
Delay an operation? Refuse to execute it? Monaco? the other hand, it appears very likely that this
Who then makes the decision, the manager Obviously, our private bank (Société Générale would impact international transactions carried
or compliance? Private Banking Monaco) and our retail bank (SG out by our clients, in particular due to tighter
When a manager has doubts about an Monaco) have implemented all of the measures controls by our banking correspondents. In the
operation, he or she has the obligation to imposed by our Monégasque obligations. In meantime, our teams are actively participating
inform the compliance department, whose addition, as a subsidiary of the Société Générale in all actions and initiatives taken by the
experts will analyse the operation and decide Group, they can apply more restrictive measures authorities to meet Moneyval’s requirements.
on the actions to be carried out, both with if requested by the group and which do not Most recently, Société Générale in Monaco was
regard to the client and with respect to the conflict with Monégasque provisions. One a pilot establishment for the deployment of the
authorities. This requires strong awareness of our measures, for example, was to ensure GoAML suspicious reporting tool.
by our sales teams on compliance issues and the proper distribution of our advisors’ assets,
a fluid relationship between the sales and in particular to ensure that our bankers have * Monégasque Financial Security Authority
** Know Your Customer
compliance teams. In addition, our compliance the right expertise based on the risk of their *** Financial Action Task Force
team is equipped with transactional analysis client portfolios.
tools which filter our clients’ operations and
evaluate the alerts raised according to various Have these controls become common
scenarios. practice? How do customers react to all the
Subsequently, when the bank confirms a requests for information (identity, origin of
suspicion, it notifies the authorities, in this funds etc)?
case the AMSF , who will decide what action We no longer really encounter any difficulties in
*
to take. Likewise, the law clearly specifies that carrying out our due diligence with our clients.
in case of doubt, the bank must refrain from This is consistent with the awareness efforts
carrying out the transaction. of the authorities and our bankers.
Also, in the event of suspicion in relation to
an operation which could potentially be the Is there a different awareness depending on
subject of an attempted fraud or which could a client’s nationality?
be linked to a cybercriminal action, the local International clients with multiple bank
operational risks and information security accounts are very familiar with and accustomed
teams may be contacted in order to carry out to banks’ KYC procedures.
**
additional analyses with the help, if necessary,
of central services. How many suspicious transaction reports
have you made this year?
When does a transaction become suspicious? We do not communicate this type of data but
Do you make an assessment based on the risk it should be noted that the Monaco authorities
to an establishment’s reputation? received more than 900 suspicious transaction
The reputation of an establishment is not a reports in 2022, 80% of which were generated
criterion for analysing an operation. The law by banks.
and the AMSF guidelines are very clear on
this subject. On this basis, many criteria can What would happen if Monaco appeared on
be taken into account in order to consider an the FATF grey list ?
***
operation as suspicious and report it to the Beyond the strong image and reputation
authorities. risk for the market, the impact would, in our © FreePik
opinion, be moderate on our customers and

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