Monaco – CM CO

2025, Cross-border, Update

Country Manual Cryptos Overview Update

Monaco

BRP has updated its Country Manuals Cryptos Overview for

Monaco

out of Crypto-Asset service provider’s country of establishment (DEF, RS & RT)

SOURCE OF CHANGESANSWERS
  Law/Regulation  No
  New Position of the Authorities  No
  Evolution of Expert’s interpretation  No

Definitions & Concepts, Regulatory Summary and Behaviour Template

The Country Manual Cryptos Overview has been reviewed to ensure that the content of all the documents remain accurate and up to date.

Material changes

The Cryptos Overview Behaviour Template (BT) reflects the principles set out in the Regulatory Summary document (RS) using schematic “dos and don’ts” that now cover both types of investors (Retail and Professional). The position with respect to Professional Investors is generally more permissive than for Retail Investors.

However, please note that the definition of “Professional Investors” in Art. 2 of the Ordinance n° 9.737, is only relevant for locally licensed financial institutions, and not for those acting on a cross-border basis without a local license. Therefore, the definition of “Professional Investors” is based on the Monegasque authorities’ interpretation of the concept of “Institutional Investors”: only the Monegasque Government, the Sovereign Fund, the Prince’s Foundation, insurance companies, and pension funds are considered “Professional Investors”.

Non-material changes

Some comments and content have been slightly rephrased in the CM, without introducing any substantive changes to better reflect the regulatory situation/current interpretation of the regulatory framework more accurately

For more information, please contact us: info@brpsa.com

Geneva, June 3rd 2025