Prime real estate in Monaco: from mandate to AML due diligence

In Monaco, a real estate agency handles transactions worth millions of euros, for clients who are often international and sometimes act through companies. It is also a link in the anti-money laundering system, supervised by the AMSF. In late 2025, the Authority sanctioned two agencies. Their decisions, published in anonymised form, say little about suspicion: they talk about expired documents, a company that appeared on signing day, searches carried out but not kept. Due diligence plays out in the everyday steps of a mandate, and that is where a tool can help, without ever deciding in the agent’s place.

Transactions

493sales and resales in 2025, worth €5.9 billion

Resale

7.6million euros: the average resale price in 2025

Lettings

10thousand euros in monthly rent: the threshold from which a letting falls within scope

Retention

5years at least of retention after the relationship ends

Sources: IMSEE, Real Estate Observatory 2025; AMSF, practical guide n°1 “Real estate agent”; law n°1.362, Article 23.

Law n°1.362 covers the professionals governed by law n°1.252 for their transaction activities only. The AMSF’s practical guide n°1, devoted to real estate agents, sets out its scope. The essentials fit into six reference points:

Sales

Purchase, sale or exchange of property, built or not, unfurnished or furnished; businesses, leasehold rights, commercial premises; non-negotiable shares in a company whose assets include a property or a business. A sale is generally an occasional transaction.

Lettings

From €10,000 in monthly rent including VAT, excluding service charges, seasonal or not. A letting is generally a business relationship, which calls for ongoing due diligence for as long as it lasts.

Timing

Before the transaction for a sale, before entering into the relationship for a letting. If due diligence cannot be carried out, the agent may neither establish the relationship nor execute the transaction (Article 7).

Other professionals

The bank and the notary have their own obligations (our article on AI in private banking describes the banks’); according to the guide, their involvement does not release the agent from his or her own.

The record

Five years’ retention: after the relationship ends for identification documents, after execution for transactions (Article 23). The guide recommends adding a copy of the searches carried out.

Every year

An activity report to the AMSF within three months of the financial year-end (Article 33), the Authority’s annual questionnaire, before the end of February, staff training (Article 30) and an up-to-date risk assessment of the agency (Article 3).

The AMSF guide answers with scenarios, which can be read as a decision tree:

1. Does the transaction fall within the scope of the law?

   A sale, a transfer of a business or of shares in a property-holding company: yes. A letting: from €10,000 in monthly rent.

   NoThe transaction falls outside the scope of law n°1.362.

   YesQuestion 2.

2. Do you represent both parties?

   The client is the party the agent represents: the buyer, the seller, or both; for a letting, generally the landlord and the tenant.

   YesDue diligence on each of the two parties, then question 3 for each.

   NoDue diligence on the party who gave you the mandate; the other party’s agency identifies its own client. Question 3.

3. Is the client a company, a trust or a foundation?

   A selling property company, a foreign buying company, a wealth-holding structure.

   YesIdentify the entity, its directors and its beneficial owners, who are natural persons. Question 4.

   NoIdentify the person, any representative, and the person on whose behalf the transaction is carried out. Question 4.

4. Does a high-risk factor appear?

   A politically exposed person, a family member or close associate; a remote relationship; a link with a high-risk country; a complex transaction or an unusually high amount.

   NoStandard due diligence, or simplified if the risk is low and the analysis justifies it.

   YesEnhanced due diligence: for an exposed person, approval from a senior member of the hierarchy, source of wealth and funds established, enhanced ongoing monitoring (Article 17); remotely, copies of two official documents bearing a photograph (Article 13); for a high-risk country, the measures under Articles 14-1 and 14-2; for an unusual transaction, specific review and a written report (Article 14).

One point in the guide is worth remembering: identification means knowing all the natural persons involved in the transaction. The guide also flags as an indicator the presence of an unidentified third party, a business introducer or someone close to the client, whose behaviour suggests that he or she is the ultimate beneficiary.

For each of the six steps of a sale or letting mandate: the point of vigilance drawn from the texts and the AMSF decisions, what AI can prepare and what remains with the agent.

The AMSF’s sanction decisions are published on its website. Two of them, issued on 18 November and 22 December 2025, concern real estate agencies. The first targets a sole-trader agency focused mainly on property management and lettings: eight findings, €18,000. The second, a small, fast-growing transaction agency: four findings, €50,000. Their findings overlap:

1. Incomplete identification

   Expired identity documents, missing proof of address, missing articles of association for a foreign company, landlords not identified in two letting files, insufficiently documented beneficial owners.

2. The company that appears at signing

   A purchase planned in the name of a natural person was completed by a legal entity; the agency only learned of it on signing day and requested the documents the same day.

3. Source of funds on a single document

   For a tenant, a single bank reference letter, confirming that the account was run properly, was not enough to support the socio-economic background and source of funds.

4. The search done, but not kept

   The agency had checked a client’s activity in public sources, without keeping a copy of its searches. In an inspection, only what is in the file counts.

5. Risk never assessed, review never carried out

   No risk level assigned in one case; in the other, periodic reviews provided for in the internal procedures according to risk level, but nowhere to be found in the files inspected.

6. Exposed persons, with neither procedure nor tool

   No procedure for politically exposed persons and no procedure for counterparties linked to a high-risk country in one case; no screening tool in the other.

Drawn from the texts, the guide and these two decisions, here is what a sale or letting file should contain on the day the AMSF opens it:

1. The nature of the relationship: occasional transaction or business relationship, and why.
2. Each client’s identity, from a valid official document bearing a photograph, and their address.
3. For a company: articles of association or a register extract less than three months old, directors, beneficial owners.
4. The representative, if any, and the person on whose behalf the transaction is carried out; in the event of a substitution before signing, identification of the new party.
5. The payer and the means of payment, matched against the client and their profile.
6. Socio-economic background and source of funds, supported by documents, not merely declared.
7. The screening result (exposed persons, sanctions, asset freezes), dated, with a copy of the search, and the date of the latest asset-freeze list check.
8. The risk level assigned, with a short justification.
9. Enhanced measures applied where relevant: senior approval for an exposed person, a written report for an unusual transaction.
10. For a letting: the date of the next file review.
11. A record of each decision: who approved it, and when.

AI provides three services, under the agent’s eye; the fourth cannot be delegated.

1. AIReadarticles of association, ID documents, registers, in several languages and alphabets
2. AIMatcha name, a payer, an amount, from one step of the mandate to the next
3. AIRecordeach check, dated, with its source, in the file
4. The agentDecidethe risk level, the next step, the report

Three conditions follow. First, due diligence files contain some of the most sensitive personal data an agency holds, governed by law n°1.565; where the chosen tool hosts them, or where they can be accessed from, matters as it does for any other tool (see our article on data transfers out of Monaco). Second, every suggestion from a tool should point to its source, so it can be checked at a glance. Finally, nothing goes to a client, another professional or the AMSF without approval from an authorised person.

According to the AMSF guide, internal procedures should enable teams to apply each measure in practice. A tool is only worthwhile if it makes them workable, mandate after mandate.

In a transaction worth several million euros, clients expect their agent to know the market, the property and the parties. The 2025 decisions are a reminder: in an inspection, knowledge of a client that is not documented does not count. Documentation is made of up-to-date documents, retained searches and recorded decisions: putting things in order, work that a tool can prepare, leaving the agent time for viewings and negotiation.

What if the due diligence file, kept up to date from the mandate onwards, also became one of the agency’s arguments with sellers who entrust it with a property in confidence?