Declaring beneficial ownership is not merely an administrative formality. Monaco businesses must ensure that the information they provide is accurate, complete and regularly updated. Any failure to do so may have significant legal and administrative consequences.   Significant penalties for inaccurate declarations Where an inaccurate or incomplete declaration is made in bad faith, the penalties may include: imprisonment for up to six months; • a fine of up to €90,000. Even where bad faith has not been established, a failure to comply with the relevant reporting obligations may result in administrative measures. Monaco’s Business Development Agency may issue a formal notice requiring the company concerned to rectify the situation. The irregularity may also be referred to on the relevant register extract, while certain companies may face administrative fines of up to €20,000. If the failure persists, the matter may be referred to the Court of First Instance.   The obligation to report discrepancies Professionals subject to obligations relating to anti-money laundering, counter-terrorist financing, counter-proliferation financing and anti-corruption – AML/CFT-P-C – must also report any discrepancy between the information recorded on the beneficial ownership register and the information available to them through their own due diligence procedures. Failure to report a discrepancy may expose those concerned to: imprisonment for up to six months; • a fine of up to €180,000, which may be increased depending on the status of the person concerned; • additional penalties which, in the most serious cases, may extend to the dissolution of the legal entity.   Compliance as a core component of corporate governance Reliable beneficial ownership information and an effective compliance framework are not simply regulatory requirements. They are also essential components of responsible corporate governance, effective risk management and transparency within legal structures. Businesses and regulated professionals must therefore be able to demonstrate the relevance of their procedures, the effectiveness of their controls and the regular updating of the information they hold.   How Gordon S. Blair can assist Gordon S. Blair assists businesses and regulated professionals with: implementing and updating their AML/CFT-P-C frameworks; • conducting compliance audits; • carrying out mandatory periodic reviews; • identifying and addressing potential compliance weaknesses; • strengthening internal control and governance procedures. Should you have any questions regarding your obligations or wish to assess your compliance framework, our teams remain at your disposal.

A milestone for Monaco company law. On 5 October 2026, Monaco's National Council unanimously approved Bill No. 1112 concerning accounting professionals, statutory auditors and corporate financial statements. Here is what it means for groups, and the questions worth asking now.   Building on the 2025 reforms This reform does not come out of nowhere. It follows the modernisation of company law in 2025 and tackles a core issue for trust in financial information: the independence of those who audit it. In practice, the reform strengthens auditor independence and addresses conflicts of interest.   Consolidated accounts enter the picture The second key change: the bill introduces a framework for certain parent companies to prepare and file consolidated financial statements, subject to the applicable conditions and thresholds. For groups organised around a parent company, this may change how financial information is presented and managed.   Practical questions for directors and shareholders For directors and shareholders, the focus is now practical. The questions concern both governance and financial reporting: Consolidation: does the group fall within the consolidation requirements? Organisation: how should reporting be organised? Independence: do auditor appointments meet the independence rules? Addressing these questions early makes it possible to approach implementation without pressure.   Next steps Parliamentary approval marks a significant step, but not the final one. Publication of the final legislation and the relevant implementing provisions will clarify the applicable timetable and requirements. In the meantime, one thing is clear: groups that plan ahead will be best placed for the transition.

On 2 April 2026, Monaco’s National Council adopted Legislative Proposal No. 276. The proposal pursues a dual objective: encouraging foreign entities owning real estate in Monaco to relocate to the Principality, and enhancing their transparency. It was transmitted to the Prince’s Government on 3 April 2026.   Relocation to Monaco with continuity of legal existence The first key element of the proposal concerns the relocation mechanism itself. Subject to certain conditions, the entities concerned could relocate to Monaco while preserving their legal existence. The relocation would nonetheless be subject to a framework. In particular, the entities would need to correspond to a legal form recognised under Monaco law and comply with the applicable Monaco rules.   A temporary exemption from proportional registration duties To facilitate these transactions, the proposal provides for exemptions from proportional registration duties for certain relocations and property contributions. This favourable regime would be time-limited: it would apply for a three-year period following the future law’s entry into force.   Introduction of a 1% annual levy In parallel, the proposal would introduce an annual levy equal to 1% of the market value of the relevant property or property rights, calculated without deducting debt. Entities disclosing the identity of their ultimate beneficial owners annually would notably be exempt. This exemption is therefore consistent with the proposal’s objective of enhancing transparency.   A legislative process still under way Adoption of a legislative proposal by the National Council does not bring it into force. The measures described above remain subject to the further legislative process, and their final terms may still change.   Do you hold Monaco real estate through a foreign structure? Our team is available to assess the implications.