As the FATF (Financial Action Task Force) prepares to announce its decision regarding Monaco, attention naturally focuses on one question: will the Principality exit enhanced monitoring or remain subject to increased scrutiny? Beyond the outcome of this upcoming milestone, recent developments point to a more fundamental shift: international expectations are now primarily focused on the effectiveness of anti-money laundering, counter-terrorist financing and counter-proliferation financing (AML/CFT/CPF) frameworks. The decision taken by the FATF in February 2026 confirmed that the issue no longer lies so much in the alignment of the legislative framework with international standards, but rather in the ability of jurisdictions to demonstrate the practical effectiveness of their systems. This evolution is reflected in both the supervisory approach and enforcement activity of the Monegasque Financial Security Authority (AMSF), which place increasing emphasis on the governance of compliance functions, the quality of KYC procedures and the ability of regulated professionals to demonstrate the effectiveness of their controls. Recent decisions have also highlighted that remedial actions implemented after deficiencies have been identified are not necessarily sufficient to mitigate their consequences. For regulated professionals, the challenge therefore extends beyond the outcome of the June 2026 FATF plenary. It lies in ensuring that compliance frameworks are not only technically sound, but are also capable of withstanding an increasingly demanding level of regulatory scrutiny. Gordon S. Blair advises regulated professionals on AML/CFT/CPF governance, compliance reviews and preparation for AMSF inspections.

Longevity is increasingly recognised as one of the defining challenges of our time. As life expectancy increases, families, entrepreneurs and wealth holders are increasingly confronted with new questions relating to governance, succession, wealth preservation, international mobility and long-term planning.   Addressing these long-term challenges is at the heart of the discussions led by the Private Longevity Council, an independent initiative bringing together experts from a broad range of disciplines. In a recent interview published by La Gazette de Monaco, Michel Bouquier explains the Council's mission: to encourage reflection and develop practical responses to the societal, economic and human implications of longer lives.   As part of this initiative, Xavier de Sarrau, Managing Partner of Gordon S. Blair, contributes the legal and tax perspective to these discussions. His involvement reflects the firm's longstanding commitment to helping international families and entrepreneurs anticipate change and organise their affairs with a long-term vision.   For more than a century, Gordon S. Blair has advised clients on protecting, structuring and transmitting their interests across generations and jurisdictions. In a world where longevity is redefining traditional planning models, this expertise remains more relevant than ever.   Read Michel Bouquier’s interview in La Gazette de Monaco. (hyperlink) https://lagazettedemonaco.com/actualites/societe/michel-bouquier-une-structure-pour-repondre-aux-problematiques-de-la-longevite   

Bill No. 276, submitted by the National Council to the Princely Government on 3 April 2026, could mark a significant development in the legal framework governing foreign structures owning real estate in the Principality. Should it be enacted, the proposed reform may substantially alter the legal and tax regime applicable to foreign entities holding real estate assets in Monaco.   A legislative initiative reflecting enhanced transparency objectives The proposed legislation seeks to establish a more comprehensive framework for foreign legal entities holding real property rights in the Principality. Among the measures under consideration is the possibility for a foreign entity owning real estate in Monaco to transfer its registered office or domicile to the Principality while retaining its original legal personality, subject to compliance with the conditions set out in the proposed legislation. Beyond this structural aspect, the bill reflects a clear policy objective of strengthening transparency regarding the identification of the beneficial owners of the entities concerned.   An unprecedented tax mechanism The proposed legislation introduces an annual levy applicable to foreign entities owning real estate in Monaco that do not voluntarily disclose the identity of their beneficial owners. The levy would be set at 1% of the market value of the real estate assets held, potentially resulting in a significant financial burden for certain holding and wealth-structuring arrangements. To facilitate potential restructuring or compliance measures, the bill also contemplates a transitional regime providing for an exemption from registration duties for a limited period of three years.   What comes next? At this stage, the proposal remains a bill and has not yet been enacted. The Princely Government has until 3 October 2026 to communicate its position and any observations on the proposed legislation. While the outcome remains uncertain, the initiative nonetheless reflects the Principality's continuing efforts to enhance transparency and strengthen beneficial ownership disclosure requirements. Property owners and investors concerned may wish to assess the potential implications of the proposed measures and review, where appropriate, the suitability of their existing holding structures in light of the policy direction reflected in the bill.   The teams at Gordon S. Blair are closely monitoring developments and remain available to assist clients in assessing the legal, tax and wealth-planning implications of this proposed legislation.