AMSF sanctions 2025: Critical lessons for Monaco yacht brokers

On 28 November 2025, the Journal de Monaco published two anonymised sanction decisions of the AMSF Sanctions Commission (procedures 2025-2145 and 2025-2147). Although one case involved a real-estate agent and the other concerned a brokerage firm active in high-value asset transactions, the findings directly affect all Monaco yacht brokers, particularly those involved in large yacht sales, cross-border deals, complex structures or crypto-funded purchases.

These decisions now serve as the clearest indication of how the AMSF interprets Law 1.362 and OS 2.318 in practice. Below is a dedicated synthesis for the yachting industry.
1. Governance: AML manuals must be current and yacht-specific
In both decisions, the AMSF highlighted outdated AML manuals as a core deficiency. In one case, procedures had not been updated for over a decade (Decision 2025-2147), treated as a serious breach alone.
For Monaco yacht brokers, the implication is clear:

• AML manuals must be updated regularly, not only after inspections.
• Procedures must be sector-specific: high-value assets, offshore structures, nominee arrangements, PEP exposure, ETHR jurisdictions, remote onboarding and crypto.
• The AML/CTF officer and AMSF correspondent must be formally designated and documented.

Updating after the fact, as the AMSF emphasised in both decisions, does not remedy historical non-compliance.

2. A written risk assessment is mandatory, and must fit yachting realities
Both sanction decisions found weaknesses in risk assessments. In Decision 2025-2145, the AMSF noted that even obvious high-risk factors, such as Panama or Gibraltar involvement, or a crypto-funded deal, were missing from the risk matrix.
For yacht brokers this means:

• A written, up-to-date business risk assessment is essential.
• The Monaco ETHR list must be integrated, not only the FATF lists.
• Crypto exposure must be captured, the AMSF specifically cited a Bitcoin-funded yacht transaction as high-risk.
• Remote onboarding, intermediaries and highly mobile international clients must be explicitly addressed.

If it is not written down, the AMSF will treat it as not performed.

3. Full KYC on all parties to a yacht transaction
Decision 2025-2145 found multiple identification failures: missing director IDs, missing trust controllers, and incomplete documents on both buyers and sellers.
For yacht brokers, full CDD must cover:

• Buyer, seller and any UBOs, directors, trustees, foundation council members, attorneys-in-fact.
• Valid ID + proof of address (expired documents were sanctioned).
• For entities: statutes, registers, director lists, signing authority.
• For trusts/foundations: trustees’ and controllers’ identification.

Remote onboarding was expressly treated as high-risk and subject to enhanced measures (Decision 2025-2145, Grief IX).
Meeting the client “when they arrive for the sea trial” does not fix initial CDD deficiencies.

4. Source of Wealth & Source of Funds: the decisive issue for yacht brokers
Both sanction decisions make SoW/SoF the central compliance challenge.
The AMSF ruled that the following were insufficient:

• Verbal explanations (“successful businessman,” “long-standing client”).
• Press articles or internet notoriety.
• A bank “good standing” letter on its own.
• Statements like “crypto early adopter,” without documentation.
• Relying on introducers’ knowledge or files.
• Assuming that elderly or long-known clients do not require checks.

In Decision 2025-2145, the AMSF criticised a yacht transaction funded partly in Bitcoin, noting that the crypto origin was not documented and that no financial evidence corroborated the client’s wealth.
The AMSF accepted only:

• Evidence supported by reliable documentation: bank statements, audited accounts, payslips, tax returns, asset sale agreements, loan contracts.
• Clear evidence of the specific funds used for the transaction (not general wealth).
• Documented attempts to obtain missing items + a justified high-risk classification where full documentation cannot be obtained.

For Monaco yacht brokers, this is the supervisory line:
If you cannot evidence it, you cannot accept it.

5. Delegation to intermediaries, prohibited
Both decisions reinforce that AML responsibilities cannot be delegated to independent brokers or introducers. Decision 2025-2145 sanctioned a firm for allowing brokers to collect KYC and even to access sensitive AML documents.
For yacht brokers, this means:

• Freelance brokers, “finders,” family offices or introducers cannot perform CDD on your behalf.
• You must hold the original KYC and SoW/SoF files.
• SAR information must never be shared outside the regulated entity.

6. Ongoing monitoring and training
Decision 2025-2147 emphasised that constant vigilance is required under Art. 5. Client files must be periodically updated, and AML training must be conducted regularly.
For yacht brokers, ongoing monitoring must include:

• Updating IDs, addresses, SoW/SoF and risk scoring.
• Documenting periodic reviews.
• Ensuring all client-facing staff receive AML training.

How Rosemont Consulting can support Monaco yacht brokers
Rosemont Consulting Monaco assists brokers with:

• AML manual updates tailored to yachting.
• Risk assessments integrating crypto, offshore structures and ETHR jurisdictions.
• Practical SoW/SoF procedures for yacht purchases and charters.
• Training, PEP/ETHR screening and ongoing file review processes.
• Pre-inspection AML audits aligned with AMSF expectations.
• LEXCO compliance monitoring and screening tool.

With Decisions 2025-2145 and 2025-2147, the AMSF has set a clear compliance baseline.
For Monaco yacht brokers, now is the moment to strengthen frameworks before the next regulatory cycle.

For more information, please contact rys@rosemont-yacht.com

Follow us on LinkedIn and don't miss our weekly updates.

12/2025