On 30 October 2026, the Financial Action Task Force (FATF) officially announced Monaco’s removal from its list of jurisdictions under increased monitoring, commonly known as the “grey list”. This decision marks a significant milestone for the Principality and recognises the substantial efforts undertaken in recent years to strengthen its framework for combating money laundering and terrorist financing (AML/CFT).   A Positive Signal for Monaco’s International Reputation and Attractiveness Beyond its regulatory significance, this development represents an important step forward for Monaco’s international reputation and economic attractiveness. It contributes to strengthening the confidence of investors, financial institutions and international business partners, while reinforcing the Principality’s position as a financial and business centre committed to upholding international standards.   A Continued Commitment to Transparency and Compliance Monaco’s removal from the FATF grey list reflects the progress achieved in enhancing financial transparency, regulatory supervision and the prevention of money laundering risks. It also highlights the importance of maintaining these efforts to ensure lasting improvements and preserve a legal and regulatory framework aligned with international requirements.   Gordon S. Blair welcomes this significant development, which reflects the Principality’s sustained commitment to strengthening financial transparency and meeting international standards in the fight against money laundering. This achievement represents a positive step for Monaco’s legal and economic environment, as well as for the wider business community contributing to its international standing.   Source: Official Press Release – Government of Monaco

Ministerial Order No. 2026-548 of 30 September 2026, published in the Journal de Monaco on 16 October 2026, establishes the list of countries, territories and international organisations recognised as providing an adequate level of protection for personal data. This development has important implications for Monaco-based businesses transferring personal data internationally. Adopted pursuant to Article 97 of Law No. 1.565 of 3 December 2024 on the Protection of Personal Data, the Ministerial Order clarifies the legal framework governing international data transfers from Monaco. Jurisdictions Recognised as Providing Adequate Protection The list includes the Member States of the European Union, the United Kingdom, Switzerland, Andorra, Argentina, Brazil, New Zealand and Uruguay. It also covers Iceland, Liechtenstein, Norway, Guernsey, Jersey, the Isle of Man, the Faroe Islands and the European Patent Organisation. Canada is also included, although its adequacy recognition specifically applies to private-sector organisations subject to the Personal Information Protection and Electronic Documents Act (PIPEDA) in the course of their commercial activities. Notably, the United States, Japan, the Republic of Korea and Israel are not included in the final list, although their inclusion had initially been contemplated. What Are the Implications for Monaco-Based Businesses? Transfers of personal data to jurisdictions recognised as providing adequate protection may be carried out without specific prior formalities relating to the transfer, provided that all other applicable legal obligations are met. Transfers to jurisdictions not benefiting from an adequacy recognition remain possible, subject to the mechanisms provided under Law No. 1.565, including: Article 98: Appropriate safeguards, such as standard data protection clauses approved by Monaco's Personal Data Protection Authority (APDP) or binding corporate rules. Article 99: Statutory derogations applicable under specific conditions. Article 100: Prior authorisation from the APDP based on specific safeguards. The publication of the APDP's standard data protection clauses, which could take place by the end of 2026, is expected to provide further guidance on international data transfers. A Key Compliance Consideration These developments are particularly relevant for Monaco-based businesses relying on international service providers, cloud services or IT solutions involving cross-border transfers of personal data. Businesses should therefore review their international data flows and ensure that appropriate legal safeguards are in place. How Gordon S. Blair Can Assist Gordon S. Blair advises businesses, investors and executives on the structuring and development of their projects in Monaco, providing legal guidance tailored to their needs and the Principality's regulatory environment. Drawing on its expertise in corporate and business law, risk management and regulatory compliance, the firm assists its clients in identifying and anticipating legal and regulatory challenges. The evolving personal data protection framework highlights the importance of integrating compliance considerations into business operations and projects to mitigate legal risks and support their long-term development.

Gordon S. Blair and its Managing Partner, Xavier de Sarrau, are featured in the 2026 edition of the Global Law Experts & Global Advisory Experts Handbook, published in September 2026, in the Monaco – Wealth Management Law section.   An international reference guide Published by Global Law Experts and Global Advisory Experts, the Handbook presents law and advisory firms around the world each year, organised by jurisdiction and practice area. It is aimed at business leaders and decision-makers seeking international advice.   More than a century advising on international wealth Founded in Monaco in 1920, Gordon S. Blair advises private individuals, entrepreneurial families, family offices, financial institutions and international groups on the structuring, protection and management of their private and corporate interests. Led by Xavier de Sarrau, a multidisciplinary team of around 50 legal and tax professionals advises on wealth management, international tax and estate planning, family governance, real estate, corporate law, M&A and cross-border projects.   Key expertise highlighted in the profile The profile published in the Handbook highlights several of the firm's areas of work: Relocation to Monaco: support at every stage of the process, from residency and international tax to wealth structuring, business establishment and regulatory matters. Wealth preservation and succession: trusts, foundations, family offices, holding structures and governance frameworks designed across generations and jurisdictions. High-value assets: yachts, aircraft, real estate and art collections, from acquisition to transmission, integrating legal, tax and regulatory advice.