Monaco's financial security authority, the AMSF, has fined Moncrief Private Bank, formerly Bank Havilland Monaco, one million euros over significant shortcomings in its anti money laundering and counter terrorist financing controls. The sanction comes as the principality continues working to exit the Financial Action Task Force grey list by the end of 2026 and remains under scrutiny over the effectiveness of its legislative reforms.
The fine follows a string of recent penalties from the Monegasque regulator, after a six million euro fine against UBS Monaco in April and a 75,000 euro penalty, 25,000 of it suspended, against Guardian Management, a provider linked to foreign legal structures. The AMSF's sanctions committee also chose to name the bank publicly, despite its requests for anonymity citing a recent change in ownership, its limited size and the risk of reputational damage.
According to the AMSF's 53 page report, inspectors were present at the bank's premises on Boulevard des Moulins between July 9 and September 5, 2024, when the institution employed 19 people and managed 449 million euros in assets for 360 clients. The regulator identified seven failings, three of them considered repeat breaches following a 2017 audit and a sanction imposed by the Minister of State in 2021, with the corrective measures introduced since apparently failing to fix the shortcomings.
Among the findings was a flawed risk classification methodology that led the bank to underestimate its clients' risk profile, even though 45 percent of them were non residents: only 2 percent of clients were actually classified as very high risk and 29 percent as high risk, compared with the 0 percent and 18 percent the bank had reported, and those clients alone accounted for 61 percent of assets under management. The AMSF also flagged an insufficient understanding of the source of funds in several high risk cases, along with one unusually flagged transaction involving three million euros in dividends transferred in 2024 without enhanced scrutiny, tied to a Russian client based in the United Arab Emirates.
In its response, the bank disputed all seven findings raised by the regulator. In a statement sent to the press, Moncrief Private Bank said its new shareholders had invested in a full overhaul of its financial crime controls since taking over the institution, introducing updated internal procedures and commissioning a compliance audit from a specialist firm, backed by an expanded compliance team.