The Foreign Exchange Office has published circular no. 2/2026 on the due diligence and internal monitoring obligations of offshore holding companies. The text adopts a risk-based approach and sets out the compliance organisation expected of these structures.
What changes
Each holding company concerned must put in place a framework suited to the nature of its activity and to its level of exposure. The circular covers in particular the knowledge of clients and beneficial owners, the monitoring of transactions and the internal organisation of compliance.
A risk-based approach means that a uniform level of control should not be applied to every relationship. The company must identify the risk factors, define the appropriate due diligence measures and step up its checks where the situation warrants it.
Who is concerned?
The text is directly aimed at offshore holding companies. It also concerns their directors, compliance officers and the service providers responsible for incorporation, corporate secretarial work or the monitoring of international transactions.
In practice
The structures concerned should review their onboarding procedures, the collection of information on beneficial owners, how often files are updated and the arrangements for reviewing unusual transactions. Classification decisions and the checks carried out must be documented, so that the consistency of the framework can be demonstrated if the authority asks for it.
An initial collection of documents is not enough on its own: due diligence must continue throughout the relationship.
Sources
- Foreign Exchange Office — Publication of Circular no. 2/2026 on the due diligence and internal monitoring obligations of offshore holding companies, 10 August 2026.
Aurion assists its clients with these procedures. → Contact us
This publication is provided for information purposes only and does not constitute personalised tax or legal advice.