Yachting, AML and anti-terrorist financing – reporting obligations, beneficial ownership transparency and the updated monegasque framework

Beyond the general compliance obligations (see our previous article), Regulation (EU) 2024/1624 introduces a systematic reporting obligation for sales of certain high-value goods, together with a strengthened beneficial ownership transparency regime. This second note of a series of three, details both requirements and presents, for the Principality of Monaco, the sector-specific practical guide for yachting as updated in May 2026.

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1. The systematic reporting obligation for certain high-value goods

The Regulation introduces an obligation to report to Financial Intelligence Units (“FIUs” — Tracfin in France, Italy’s Financial Intelligence Unit in Italy) all transactions involving the sale of certain high-value goods, including watercrafts for a price of at least €7,500,000. This reporting obligation applies only to goods acquired “for non-commercial purposes”, thereby excluding transactions of a commercial nature. It applies both to “persons trading in high-value goods” — without further definition in the Regulation — and to credit and financial institutions providing services related to the purchase of such goods, regardless of whether they are otherwise subject to general anti-money laundering and countering financial terrorism (AML/CFT) obligations. However, the Regulation includes in the list of the obliged entities, the persons storing, trading or acting as intermediaries in the trade of cultural goods and high-value goods within free zones and customs warehouses, where the value of the transaction reaches at least €10,000.

Unlike the traditional suspicion-based reporting regime under Article L. 561-15 of the French Monetary and Financial Code, the current wording of the Regulation requires systematic reporting of transactions involving the relevant High-Value Goods, irrespective of any suspicion of money laundering. This obligation goes beyond existing reporting requirements. The Regulation leaves it to the FIUs to determine the deadlines for submitting such reports.

The Regulation’s recitals clarify that, although the reporting obligation applies only to sales for private, non-commercial purposes, it should not be limited to cases where the client is a natural person: it should also extend to legal entities and legal arrangements, particularly where such structures are used to manage the wealth of their beneficial owner.
  

2. Beneficial ownership transparency obligations

The Regulation includes a dedicated chapter on beneficial ownership transparency, under which legal entities established outside the European Union must submit beneficial ownership information to the central register of the relevant Member State, notably when they:

• enter into a business relationship with an Obliged Entity assessed as posing medium-high or high AML/CFT risk; or

• acquire, directly or through intermediaries, a High-Value Watercraft in an occasional transaction for non-commercial purposes, from Professional Traders or Intermediaries in the Trade of High-Value Goods.

The beneficial ownership information must be accompanied by a declaration specifying which of the above activities it relates to, along with any relevant supporting documents. Where a business relationship is entered into with an Obliged Entity posing medium-high or high risk, the information must be provided prior to commencement of the relationship; for the acquisition of a High-Value Good, it must be submitted before completion of the purchase. Obliged Entities are responsible for informing legal entities established outside the Union where the associated risk is assessed as medium-high or high, and for requesting proof of registration or an extract of the beneficial ownership information recorded in the central register.
   

3. Monaco: update to the sector-specific yachting framework (May 2026)

A sector-specific practical guide for yachting, published by the Service d'Information et de Contrôle sur les Circuits Financiers (SICCFIN — now the Monaco Financial Security Authority, “AMSF”) in January 2022, was updated on 13 May 2026. The AMSF published its Practical Guidance — Yachting 2026, reflecting AML/CFT-PF legislation and regulation in force at that date, applicable to professionals subject to AML/CFT-PF obligations under Article 1(15° bis) of Law No. 1.362 of 3 August 2009, as amended.
 

a) Economic weight and risk level of the sector:

The Guide recalls the weight of Monaco’s maritime economy (835 entities, 3,268 employees, €1.8 billion in revenue, representing roughly 10% of the Principality’s revenue), of which the yachting sector alone accounts for 411 entities, 1,429 jobs and €600 million in revenue — split between the sale of superyachts (203 entities, 431 jobs, €309 million) and chartering activity (€44 million). In line with the National Risk Assessment No. 2 (2021), the yachting sector continues to be classified as “high” risk in Monaco.
 

b) Identified risk factors:

• the risk that Monaco is used to channel funds of illicit origin derived from offences committed abroad, or serves as the final destination for placing such funds;

• increasing complexity linked to the share of legal entities, trusts and similar legal arrangements among clients, making it harder to identify beneficial owners;

• risks presented by distribution channels (multiple intermediaries, brokerage arrangements, business introducers, remote identification);

• an emerging risk linked to the settlement of certain purchases or services in crypto-assets.

It should be recalled that the EU threshold of €7.5 million does not apply under Monegasque law: the local regime covers, regardless of size or amount, any person acting as an intermediary or carrying out transactions involving the purchase, sale, chartering or administrative management of pleasure or commercial vessels.
 

c) Three categories of obligations:

The Guide distinguishes “basic” obligations (fit-and-proper checks on directors, shareholders and beneficial owners; appointment of an AML/CFT-PF officer; overall risk assessment; internal procedures; internal reporting and control mechanisms), annual obligations (the STRIX annual questionnaire; staff training) and operational obligations (client identification, determination of the applicable level of vigilance, ongoing transaction monitoring, and qualitative suspicious activity reports). Practical case studies illustrate these obligations, and an FAQ section addresses, among other things, the treatment of politically exposed persons and Monegasque asset-freezing measures.

This Guide forms part of a broader body of guidance, which also includes the Generic Guidelines for Monegasque professionals, published on 21 April 2026, which serve as its cross-sectoral complement.