Crypto-funded debit card in Monaco

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.

Fit & Proper Requirements:

Customer Due Diligence (CDD): Implementing robust procedures for identifying and verifying the identity of clients (Know Your Customer - KYC), including beneficial owners, and understanding the purpose and intended nature of the business relationship.

Ongoing Monitoring: Continuous monitoring of business relationships and transactions to ensure consistency with the institution's knowledge of the customer and their risk profile.

Record-Keeping: Maintaining records of customer identification data, transactions, and risk assessments for a specified period (typically 5-10 years).

Suspicious Transaction Reporting (STR): Establishing internal procedures for identifying and reporting suspicious transactions to SICCFIN.

Risk Assessment: Implementing a comprehensive, risk-based approach to AML/CFT, including institutional risk assessments and client risk profiling.

Internal Controls: Developing and implementing internal AML/CFT policies, procedures, and controls, including the appointment of an AML/CFT Compliance Officer.

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

Identification and Verification of the Client:

Identification of the Beneficial Owner (BO):

Non-Face-to-Face Relationships: Enhanced measures are required to mitigate the higher risk associated with non-face-to-face onboarding.

Ongoing Monitoring of the Business Relationship:

Enhanced Due Diligence (EDD):

Evidence fact mc.aml.monaco-is-itself-identified-as-a-high-risk-third-country not found (may have been renamed).

E-money: A stablecoin could be classified as e-money if it meets the definition under Monaco's Law No. 1.339 of 7 September 2007 on Payment Services and Electronic Money.

If classified as E-money: Issuing e-money in Monaco requires prior authorization from the AMSF. The application process would involve demonstrating adequate capital, robust governance, risk management systems, and compliance with AML/CFT requirements.

Law No. 1.339 of 7 September 2007 on Payment Services and Electronic Money: Relevant for e-money classification.