A private intelligence layer for the family office.

A family office holds the whole picture of a family: entities, trusts, property, advisers, correspondence and decisions that span generations. That picture is its value and its exposure. Intelligence added to the archive should narrow risk, not widen it.

The Monaco frame

Monaco regulates the multi family office through Law No. 1.439 of 2 December 2016. The activity needs prior authorisation by ministerial order and must be carried on by a Monegasque société anonyme. Where the office also carries on certain financial activities, it needs approval from the CCAF. Article 9 places everyone who exercises the activity under professional secrecy, as defined by article 308 of the Criminal Code. The law does not cover family office activity carried on privately among members of a single family.

Multi family offices are also obliged entities under Law No. 1.362 on anti-money laundering, listed at article 1, 19°. Its article 23 requires due diligence documents to be kept for five years after the relationship ends, with possible extension. And any office that processes personal data falls under Law No. 1.565.

Three duties therefore meet in one archive: secrecy, retention for anti-money laundering purposes, and data protection.

Map the documents before adding a model

Begin with an inventory, not a model. Common classes:

• identity and beneficial ownership files;
• entity, trust and foundation records;
• property, art and asset registers;
• adviser engagement letters and invoices;
• board minutes and committee papers;
• correspondence with principals and family members;
• health, education or household details that drift into the file.

The last class may hold sensitive data as defined in article 2 of Law No. 1.565, which calls for stricter handling. The same inventory feeds the record of processing the APDP expects.

Access governance comes first

Article 23 requires protection by design and by default: only the data each purpose needs. The Sovereign Ordinance No. 11.327 adds that people acting under the controller’s authority process data only on instruction. For sensitive processing it lists objectives such as being able to verify who entered which data, and when.

In practice:

• define roles by function, not seniority;
• separate branches of the family where interests differ;
• give external advisers access scoped to one matter, with an end date;
• log each retrieval, including those an assistant makes for a user.

An assistant inherits the user’s permissions. It never searches more than that person could open by hand.

What local AI changes, and what it does not

A model running on hardware the office controls keeps prompts and documents away from outside inference services. That can reduce the processors to contract with under article 26 and the transfers to assess under articles 96 to 101. It also keeps logs and retention within reach.

It does not change who is responsible. The office stays the controller. It still needs a lawful basis for each purpose, an impact assessment where article 35 applies, and a breach process that meets article 32. Local deployment also brings work in-house: patching, backups, key management and physical security.

Human review as a design rule

Article 19 gives people the right not to be subject to a decision with legal or similarly significant effects based solely on automated processing, save in listed cases with safeguards. A family office has little reason to want such decisions. Patterns that work:

• every answer cites its source document and page;
• the assistant drafts, a named person approves;
• summaries touching legal, tax or investment matters go to the responsible adviser, not straight to a principal;
• each approval is logged with the document version reviewed.

The tool helps people find and read. Advice stays with licensed advisers.

Retention with two masters

Anti-money laundering rules require due diligence records for five years after the relationship ends (article 23, Law No. 1.362). Data protection requires data to be kept no longer than the purpose needs (article 4, Law No. 1.565). Both apply. Set retention by document class, record the legal reason for each period, and run deletion as a scheduled task.

In 2026 the APDP drew attention to a cyberattack on Liechtenstein’s register of beneficial owners, which exposed names, dates of birth and nationalities linked to legal entities. Ownership data draws attackers. An office should know where each copy sits and who can reach it.

Limits of this note

This piece covers infrastructure and governance. It gives no legal, tax, investment or licensing advice. The text of Law No. 1.439 consulted is the consolidated version Legimonaco shows in force on 21 September 2026, checked on 22 September 2026; confirm it with counsel. Offices outside that law should confirm which duties their activities trigger. A private model supports people. It does not replace their judgement or their obligations.