Crypto assets and Metaverse in the Principality of Monaco: a new legal framework for investors.

Accueil - Publications - Crypto assets and Metaverse in the Principality of Monaco: a new legal framework for investors.

by David de Pariente, partner.

Since the adoption of Law 1.528 on July, 7 2022, the “digital investors” can rely on a dynamic and more detailed legal framework in Monaco.

This technical law is in line with the European legislations adopted recently and provides several definitions which are essential to its understanding.

For instance, the Law 1.528 defines:

The metaverse as “a persistent and synchronous platform creating one or more virtual and immersive spaces offering simultaneously products and online services to several users in the form of avatars, the latter being able to move and to interact socially and economically”. In this regard, it should be noted that any supply or operating of a metaverse representing a part of the Principality’s national heritage shall be subject to the granting of a prior approval from the State Minister.

The crypto assets as financial tokens (assimilated to financial instruments) or digital assets (virtual financial assets, usage tokens, and non-fungible tokens commonly referred to as NFTs).

In a nutshell, Law 1.528 introduces a series of conditions in relation to the provision of services on digital assets and the provision of investment services on crypto assets (I) and also clarifies the legal regime of the Initial Coin offerings (ICOs), as already set forth by Law 1.491 dated June 23 2020 and Sovereign Order 8.258 (II).

I. Conditions applicable to the provisions of services on crypto assets

Law 1.528 operates a distinction between the provisions of services on crypto assets which are necessarily subject to a prior approval from the State Minister, and the provisions of services on crypto assets subject to a prior approval from the Commission de Contrôle des Activités Financières (“CCAF”).

A mandatory prior approval for several provisions of services on crypto assets

A prior approval from the State Minister is required to operate the following activities in the Principality:

• Issuance of crypto assets ;

• Deposit or administration of crypto assets or access to crypto assets;

• Operating of a negotiation platform displaying sale and purchase interests to crypto assets;

• Transfer of digital assets with other digital assets, or with a legal tender;

• Operating of a negotiation platform of digital assets.

The prior said approval will only be delivered subject to certain conditions (i.e. registration of the service provider in Monaco, good reputation of the service provider’s managers, implementation of an AML/CTF procedure regarding the freezing of assets corresponding to the criteria of the Monegasque Financial Circuits Information and Control Service, etc.).

A prior approval from the CCAF for certain provisions of services on crypto assets

Obtaining a prior approval from the CCAF pursuant to the conditions set up by Law 1.338 of September 7, 2007 on financial activities, is required for the following activities:

• Investments in crypto assets;

• Execution of orders on crypto assets;

• Reception-transmission of orders on crypto assets;

• Advice on crypto assets.

An exemption from obtaining a prior approval is provided to the benefit of financial providers of services which are already authorized by the CCAF to perform such class of financial activities in Monaco, subject however to a prior information to the regulator.

II. Clarification of the legal regime applicable to ICOs in the Principality

As a reminder, an ICO (Inital Coin Offering) is defined as an “Offering of tokens consisting in a proposal to subscribe such tokens by any means whatsoever” (see Law 1.491 of July 23, 2020 and Sovereign Order 8.258). These fundraising transactions dedicated to companies registered in Monaco or in the process of being incorporated in Monaco are subject to a prior administrative approval issued by the State Minister, whether they qualify as public or private.

The private nature of the ICOs involving tokens is subject to at least one of the following criteria:

• Offer targeting qualified investors only;

• Offer targeting less than 150 non-qualified investors;

• Offer targeting investors who purchase tokens for a total price of at least EUR 100,000;

• Offering of tokens with a nominal value of at least EUR 100,000 per token.

It should be noted that when the prior approval concerns a token with a unit nominal value of at least EUR 100,000, such an approval takes the form of a label/certification issued after examination of:

• Information provided on the issuer and the project sponsors;

• A summary note;

• A «white paper» to the investors’ attention;

• The terms and conditions for the deposit of the investor’s funds in escrow.

Law 1.528 of 7 July 2022 provides that the offer of tokens cannot concern non-fungible tokens, and that when the ICO targets the public, the offer of tokens cannot be done with financial tokens. Furthermore, it is specified that the issuer shall determine the nature of the token and its related rights, the nature of the issuance (either public or private), or the nominal value of a token.

Gordon S. Blair’s expertise in Cryptoassets

Gordon S. Blair Law Offices (Monaco) assists various actors involved in the crypto assets sector, in particular in the context of their relocation or installation in the Principality. The firm also assists banking and financial entities in this regard.

Our last news

June 2026 FATF plenary: the effectiveness of compliance frameworks at the heart of international expectations

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: anticipating the legal and wealth implications of longer lives

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

Real estate and transparency: proposed legislation could reshape the framework applicable to foreign structures holding property in Monaco

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.