Rosemont Monaco SAM

As governments across Europe compete to attract internationally mobile entrepreneurs, executives and high net worth individuals, several jurisdictions now offer highly differentiated residence and tax frameworks. The duration of these regimes has become an increasingly important factor for individuals considering long-term relocation and wealth structuring.

The Court of Justice of the European Union (CJEU) has delivered an important judgment on the treatment of trust assets under EU sanctions regimes. In T Trust (Case C-483/23) and the joined cases FZ AR and SX (Cases C-428/24 and C-476/24), the Court confirmed that assets held through trust structures may be frozen where a sanctioned settlor or beneficiary retains sufficient influence or control over those assets, even if the trust documentation appears to remove their legal ownership or formal control.

Monaco’s National Council has this week adopted a proposition de loi (bill) to create a new “fondation patrimoniale monégasque,” a private patrimonial foundation structure for wealth management. Unlike a government-initiated projet de loi, this measure originates from the Conseil National (National Council) and is currently at the bill stage. It must still go through legislative approval – including a final vote by the Council – and formal enactment before becoming law. If adopted, the new vehicle would mark a significant development in Monaco’s legal toolkit, offering onshore estate planning options previously unavailable in the Principality.

On 4 June 2026, the European Commission published an important pre-closure letter concerning the compatibility of Article 913, paragraph 3 of the French Civil Code with the EU Succession Regulation (Regulation (EU) No 650/2012). Although this is not a court judgment and the provision itself has not been amended, the Commission’s intervention provides welcome clarification for internationally mobile families holding assets in France. Whilst focused on English-Law wills this matter is also highly relevant for all international families with French connections.

Recent U.S. court rulings involving the superyacht Amadea highlight growing judicial willingness to look beyond legal title and examine the reality of yacht ownership and control.

The recent decision of the United States Court of Appeals for the Second Circuit in the long-running Amadea litigation may become one of the most influential judicial rulings affecting superyacht ownership structures in recent years.

This week’s 60-second piece is dedicated to Peter Brigham, Managing Director at Rosemont Monaco SAM.