A review of the year with the Monegasque Association of Compliance Officers

2024 02 12 Emmanuel MONTIGAUD

The AMCO has more than 200 members from 12 different industries. They include banks, management firms, TCSPs and MFOs, lawyers and legal advisors, certified accountants, estate agents, yacht brokers, sports agents, insurers, casinos, and consultants. We spoke to Emmanuel MONTIGAUD, President of the AMCO and Chief Compliance Officer at BNP Paribas Monaco.

What were the key events of the last year?

Last year was very busy. In June 2022, we analysed the implications of the sanctions adopted against Russia in response to the conflict with Ukraine.
We worked in tandem with the AMPA (Association of Independent Corporate Service Providers) to help our members on the TCSP Committee interpret certain regulatory provisions.
And we also explored the concerns raised with the Budget and Treasury Department by professionals in the yachting sector. That event inspired us to forge a partnership with the Yachting Cluster, with the aim of sharing best practices and expertise for mutual benefit.
Also in June, we examined Sovereign Ordinance No. 1,284 relating to Act No. 1,338, and more specifically its implications for the rules governing the way conflicts of interest are handled in the financial services industry.
The summer of 2022 saw the publication of the EU’s 6th AML-CFT Directive, which we looked at in detail. Since the Directive will not just have a local impact, we decided to approach the GCO or Group of Compliance Officers, in French-speaking Switzerland. And in fact we attended their General Meeting.
Building on our efforts to establish working relationships with Monegasque institutions, we met with the CCAF (Financial Activities Supervisory Commission) at the end of 2022. The aim of the meeting was to discuss current issues in the field of financial services. It took place shortly after the publication of amendments to Act No. 1,338, which seek to “MiFID-ise” Monaco’s banking and financial centre. It was the ideal opportunity to share our thoughts and ideas about the major changes.

Can you tell us about your work in the first half of 2023 ?

The Moneyval report was published early in 2023. Since then, all stakeholders in Monaco’s financial centre have been processing the evaluation’s findings, and more importantly looking to address the deficiencies identified. Our association was very quick to let the authorities know that we stood ready to take part in any action plan.
Participants in the Ongoing Professional Training course organised by the AMCO at the start of the year were addressed by three stakeholders offering their assistance with anti-money laundering in Monaco, each of whom gave a remarkable speech:

  • The Business Development Agency;
  • Mr Régis Bergonzi, Chairman of the National Council's Committee for monitoring negotiations with the European Union.

These contributions provided essential information about AML-CFT issues in Monaco.
Our General Meeting was held on 3 April 2023, and proved a success with more than 110 members attending.
Finally, for the AMCO, the first six months of 2023 culminated with an analysis of draft bill No. 1,077, which was tabled before the National Council in June.

Do you have a final word regarding AMCO’s activities?

Yes, absolutely. As regards the Association’s day-to-day business, we have continued to work at a steady pace with each Committee meeting once every quarter.
Our website is now up and running, and contains details of all of the work done by the Association since our election in 2021.
We are delighted to see that our membership has doubled to more than 200 since then. That figure represents more than one hundred professionals.
We are proud to announce the signing of a new partnership agreement with the Chambre Monégasque de l’Assurance (Monegasque Chamber of Insurance).
More than ever, the focus in 2023 is on action. We are in the process of drafting best practices guides on topics such as crypto-currency regulation, management of conflicts of interests, and many other subjects in the future.
And still to come, we will be analysing the forthcoming draft legislation on money laundering (2nd part) and personal data protection.
Finally, the association has provided practical support to members, as demonstrated by recent meetings with SICCFIN on the issue of the STRIX surveys, which raised a lot of questions.