Monaco

The APDP President ordered the school to supply the missing personal data and information required by art. 12 within 15 days of receipt. A parent's access request of 14 April 2026 was answered on 13 May 2026 with incomplete information and no reasoned notice of an extension. The notice is published and the decision is to be anonymised within six months.

The CCAF withdrew the company's approval after upholding four grievances: annual report, accounts and auditors' reports not filed within the deadlines, no two persons responsible for strategic direction and management, no account in its name at a Monaco credit institution, and insufficient human and technical resources. The decision was published in the Journal de Monaco on 6 March 2026. The CCAF site notes that on 21 May 2026 the President of the Tribunal Suprême suspended execution of the decision while an annulment application is pending.

The committee upheld four grievances covering client identification documents, knowledge of clients' background and source of funds, absent periodic reviews and weak PEP screening. It fined the agency 50,000 euros, and the anonymised decision is published for five years. The entity has six staff and no dedicated compliance employee.

Following a June 2024 inspection, the sanctions committee found breaches of know-your-customer, risk-assessment, politically-exposed-person and suspicious-transaction-reporting obligations, upholding the grievances except one branch. It fined the company 500,000 euros and ordered publication by name for two years, then without the name for three years.

The committee dismissed the first grievance and upheld eight others, on risk assessment, client identification, source of funds, PEP and high-risk jurisdiction measures, confidentiality of suspicious transaction reports, delegation to third parties and remote identification. It fined the company 50,000 euros with anonymised publication for five years.

The committee upheld all eight grievances, which covered outdated internal procedures, missing training and AML officer designation, no formal risk assessment, and gaps in identification, source-of-funds checks, monitoring and PEP detection. It imposed an 18,000 euro fine with anonymised publication for five years.

The committee upheld all five grievances: procedures not updated after a 2023 change, a former PEP client, a high-value coin sale without specific review, remote onboarding on one identity document, and cash payments above the legal threshold. It imposed a 7,000 euro fine with anonymised publication for five years.

The CCAF examined ten structured-product transactions carried out for one client between August 2020 and December 2022, totalling GBP 135 million, and found the bank's internal control mechanisms inadequate. It dismissed the grievances on suitability assessment and on human and technical resources, imposed a reprimand and ordered publication.