Crypto ATM / kiosk operator in Monaco
Physical kiosks that exchange cash for crypto (and sometimes vice versa). High-cash AML risk profile.
Crypto ATM is conditionally permitted in Monaco with a local entity, subject to AML obligations and medium licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- Medium
- Last updated
- 2026-07-13
AML Obligations
- Registration with SICCFIN (Monaco's FIU) for AML/CFT purposes as a VASP - required for any entity facilitating exchange between virtual assets and fiat currencies
- Customer Due Diligence (CDD) under Loi n° 1.362: identify and verify client identity, including beneficial owners, using reliable independent source documents
- Non-face-to-face Enhanced Due Diligence (EDD): enhanced measures required for non-face-to-face onboarding, which applies to kiosk remote onboarding
- EDD for PEPs, clients from high-risk third countries, complex/unusually large transactions, and relationships involving new technologies or products favoring anonymity (e.g., cash-to-crypto kiosks)
- Ongoing monitoring of business relationships and transactions to ensure consistency with client risk profile
- Suspicious Transaction Reporting (STR) to SICCFIN
- Record-keeping of customer identification data, transactions, and risk assessments for 5-10 years
- Institutional risk assessment and client risk profiling on a risk-based approach
- Appointment of an AML/CFT Compliance Officer and implementation of internal AML/CFT policies, controls, and procedures
Key Restrictions
- Local entity (Monégasque company) required with physical presence, management, and operational substance in Monaco
- Must register with SICCFIN as a VASP before commencing operations
- If the kiosk operator also handles traditional fiat payment processing (e.g., money remittance beyond crypto), a CCAF license may additionally be required
- Monaco is classified as a high-risk third country by the EU and under FATF increased monitoring — this triggers heightened scrutiny and EDD for cross-border relationships
- No specific minimum capital requirement for pure SICCFIN registration, but operator must demonstrate financial solvency and sufficient resources
- Fit & proper requirements apply to management, key personnel, shareholders, and beneficial owners
Key Risks
- Cash-intensive business model (crypto ATM/kiosk) presents inherently high AML risk profile — likely attracts enhanced supervisory scrutiny from SICCFIN
- Monaco's designation as a high-risk third country by the EU and FATF creates regulatory ambiguity and potential pressure for even more stringent measures
- No explicit cash-transaction reporting threshold identified in provided facts — gap creates compliance uncertainty for cash-in/cash-out operations
- Physical kiosk operators may face difficulty implementing robust non-face-to-face EDD measures for anonymous cash transactions, which conflicts with Monaco's AML requirements
- Potential dual regulatory oversight (SICCFIN + CCAF) if services extend into traditional payment services
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
SICCFIN (Service d'Information et de Contrôle sur les Circuits Financiers): This is Monaco's Financial Intelligence Unit (FIU) and the primary authority for AML/CFT supervision. SICCFIN is responsible for defining and overseeing the AML/CFT obligations of VASPs.
Requirement: Registration with SICCFIN for AML/CFT purposes.
Scope: This applies to platforms facilitating the exchange between virtual assets and fiat currencies, and between one or more forms of virtual assets.
If handling virtual assets (e.g., converting crypto to fiat for merchants): The virtual asset component of the service would likely qualify the entity as a VASP, requiring registration with SICCFIN.
If handling traditional fiat payments (e.g., processing card payments, traditional money remittance): These activities fall under existing payment services regulations. Depending on the exact nature, a license or authorization from the CCAF might be required if the activity constitutes a regulated financial service.
A local entity (e.g., a Monégasque company) is generally required to operate as a VASP in Monaco.
The entity must have a physical presence, management, and operational substance within the Principality.
For pure AML/CFT registration with SICCFIN, there are generally no specific prescribed minimum capital requirements directly stemming from the AML law itself for VASPs, unlike for CCAF-regulated entities.
However, the entity must demonstrate financial solvency and sufficient resources to operate its business responsibly and comply with its obligations. If a CCAF license is also required for certain activities, then specific capital requirements will apply for those licensed activities.
Fit & Proper Requirements:
Loi n° 1.362 du 3 août 2009 relative à la lutte contre le blanchiment de capitaux, le financement du terrorisme et la corruption (consolidated version often available through legal databases): Access via Journal de Monaco – search for "Loi 1.362" and its modifications for the most up-to-date text
Ordonnance Souveraine n° 8.182 du 10 mars 2021 portant modification de l'ordonnance souveraine n° 2.318 du 3 août 2009 d'application de la loi n° 1.362 du 3 août 2009 modifiée, relative à la lutte contre le blanchiment de capitaux, le financement du terrorisme et la corruption, modifiée (Sovereign Ordinance No. 8.182 of March 10, 2021 amending Sovereign Ordinance No. 2.318 of August 3, 2009 implementing Law No. 1.362 of August 3, 2009, as amended, on the fight against money laundering, terrorist financing, and corruption)
This is the critical piece of legislation specifically bringing virtual asset activities and VASPs under the scope of Monaco's AML/CFT regime. It defines virtual assets and virtual asset service providers and subjects them to the same AML/CFT obligations as traditional financial institutions.
Non-Face-to-Face Relationships: Enhanced measures are required to mitigate the higher risk associated with non-face-to-face onboarding.
Enhanced Due Diligence (EDD):
When Required: In situations presenting a higher risk of money laundering or terrorist financing. This includes, but is not limited to:
Monaco is itself identified as a high-risk third country by the EU and is under increased monitoring by the FATF
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — crypto ATM/kiosk operators may operate in Monaco but must: (1) register with SICCFIN as a VASP with AML/CFT obligations, (2) establish a local Monégasque company with physical substance, and (3) implement enhanced due diligence for cash transactions and non-face-to-face relationships, though specific cash-transaction reporting thresholds are not clearly defined in the available facts.
Questions this verdict aims to answer
- What money-transmitter / kiosk-specific license is required?
- What cash-transaction reporting thresholds apply?
- What enhanced-KYC obligations attach to cash-in / cash-out?