Julius Baer Wealth Management (Monaco) has been fined €1.5 million by the Monegasque Financial Security Authority after regulators identified serious shortcomings in its anti-money laundering controls and delays in reporting suspicious activity…
The decision by the AMSF’s sanctioning body, published in the Journal de Monaco on September 4, follows an inspection carried out at the wealth management company in October 2024. Both grievances brought against the firm were upheld in their entirety.
The first concerned the organisation of anti-money laundering and counter-terrorist financing controls between Julius Baer Wealth Management Monaco and sister company Julius Baer Bank Monaco.
The AMSF found that the arrangements governing delegated due diligence, transaction monitoring, periodic reviews and the sharing of information were not sufficiently clearly defined. While the company argued that internal procedures, compliance meetings and group-wide controls compensated for shortcomings in the formal agreement, the sanctioning body concluded that these measures did not provide sufficiently robust oversight.
The decision said the failings were not simply matters of documentation. Regulators identified practical weaknesses including the application of identical transaction-monitoring thresholds regardless of whether clients were considered low, high or “highest” risk.
The AMSF also highlighted examples involving significant cash withdrawals. One high-risk client regularly withdrew at least €50,000 per month, while another client classified as “highest risk” made six cash withdrawals totalling €91,000 within 90 days.
A second grievance concerned three suspicious transaction reports that the AMSF found had been filed late.
In one case, the authority concluded that information capable of giving rise to suspicion existed by May 2021, but the report was not filed until June 2022, a delay of 393 days. Another concerned an unexplained €5 million payment identified during a review in 2020, with the suspicious transaction report eventually submitted in July 2023. A third report involving unusual payments was filed 239 days after the first transaction concerned.
Julius Baer Wealth Management argued that some transactions had been executed by custodian banks rather than by the management company itself. The AMSF rejected that position, ruling that a management company remains responsible for continuously monitoring its business relationships and reporting suspicions without delay.
The authority said the shortcomings affected “several essential and complementary components” of the company’s anti-money laundering framework and represented a significant degree of seriousness.
JBWM also sought to prevent publication of the decision in its name, arguing that it could cause substantial commercial and reputational damage. The AMSF rejected that request, saying insufficient evidence had been provided to demonstrate disproportionate harm.
The decision will remain published under the company’s name for three years before being anonymised. Julius Baer Wealth Management Monaco has two months from notification to appeal the ruling before Monaco’s Court of First Instance.