Illustrative firm examples
France country research brief
Research dated 2026-10-10 · Reviewed 2026-10-10
Version 6b487a2d02c4
6b487a2d02c4db9d7d6b6c0ce6e1304ef7bd4c45b4ab87294221bf8c249011b6Scope: Illustrative firm examples. The selector is not an authorisation or legal-applicability determination. Source-check observations concern retrieval/access only and do not establish legal currentness; the research date is the content date boundary. Source health: review-required, checked 2026-10-12T06:00:11.310Z.
Framework and authorities
Use the register as guidance, not law
The 229-unit ACPR/Tracfin register is a reviewed edition of joint supervisory guidance, not a statutory code. ACPR still labels the 23 April 2025 document Version en vigueur (checked 10 October 2026). That is guidance-edition status only: its cover says updated through 22 January 2025, while its introduction uses texts in force on 1 September 2024. Do not turn either date into a current-law statement.
Current statutory perimeter remains on hold
The relevant CMF title VI original could not be retrieved from Legifrance: the access response was a security challenge, not law text. The official DILA daily update archive inspected was not a consolidated CMF original. This brief therefore makes no current claim about who is obliged, ACPR/AMF or other supervisor allocation, current CDD/reporting law, Tracfin’s present statutory remit, or current freeze-law conditions. Obtain and review the complete relevant CMF provisions and implementing texts before applying a profile or treating a guidance example as a legal duty.
Three reviewed guidance examples
In the reviewed 2025 guidance edition, paragraph 17 describes customer and, where applicable, beneficial-owner identification before a relationship, purpose-and-nature information and regular updating. Paragraph 19 describes risk-classification inputs and ties vigilance to exposure; its no-simplified-measures statement is limited to a relationship with ML/TF suspicion. Paragraph 71 describes enhanced examination for the transactions in paragraphs 69-70 and a Tracfin declaration only where appropriate. These are guidance explanations, not confirmed current statutory duties; the linked rows retain exact register hashes and their conditions.
Risk, FATF and sanctions context
Dated national risk assessments
The COLB’s January 2023 ML/TF assessment identifies tax, social and customs fraud, drug trafficking, theft and fraud among the leading ML threats. It describes complex financial arrangements, digital assets and some cash-related activity as channels susceptible to misuse, and notes real estate exposure particularly around acquisitions. The report also describes terrorist financing as predominantly micro-financing through collectors, innovative methods and, to a lesser extent, misuse of non-profits. These are dated national findings, not individual customer ratings or a 2026 reassessment. The separate June 2022 PF assessment rates threats around sensitive exports and attempted acquisition of sensitive know-how as high, and sanctions-evasion threats as moderate; it reports residual vulnerabilities after mitigation. Keep PF and sanctions analysis distinct from ML/TF and consult the full sector context before applying its matrix.
FATF evidence is historical; lists are unverified
A DG Trésor summary dated 17 May 2022 reports adoption of France’s FATF mutual evaluation on 3 March 2022 and describes selected effectiveness findings and improvement areas. It is a government summary, not the underlying FATF report; no technical-rating or follow-up conclusion is drawn here. Direct retrieval of the complete FATF report and both June 2026 list statements was blocked, so no current FATF list position is asserted.
Sanctions depend on the applicable regime
DG Trésor describes French, EU and UN sanctions resources; this is not live designation data. Identify the actual instrument, prohibited conduct, ownership/control, licences, reporting route and persons/territory covered. U.S. measures require their own regime-specific connection; neither a French firm label nor a cross-border payment alone creates universal foreign-law scope. No person, entity, live list or licence was checked.
Selected firm implications
Meaning: Paragraph 17 describes pre-relationship identification and verification, relevant purpose-and-nature information and updating. Its referenced 2009 information list and separate ACPR customer-knowledge guidance are dependencies, not a universal checklist. This summarises guidance, not current statutory duty.
Conditions: The 2025 non-binding guide covers financial organisations within its defined scope and the pre-relationship trigger; beneficial-owner measures apply where relevant. Current legal scope and case-specific information requirements are unverified.
Exceptions: No broader audience or exception is inferred. Do not require identical evidence from every customer; check current provisions and applicable branches. Current statutory applicability is unverified.
Suggested action: The dated, non-binding guide expects in-scope financial organisations to identify and verify customers and relevant beneficial owners before onboarding, collect relevant purpose-and-nature details and keep them updated.
Guidance / Guidance / Retained guidance edition · Paragraph 17Meaning: Paragraph 19 points to statutory risk factors, Tracfin typologies and alerts, national/sector assessments and authority material. It says simplified measures cannot be used where the relationship involves ML/TF suspicion. This is the guide's expectation, not a verified current duty.
Conditions: The dated non-binding guide addresses risk classification and business relationships of organisations in its defined scope. Its suspicion statement applies only where suspicion exists; current statutory conditions remain unverified.
Exceptions: This is not a blanket ban on simplified measures: use them only where current law permits. The adjacent Tracfin AAV process is separate. Current statutory applicability is unverified.
Suggested action: The 2025 non-binding guide expects in-scope organisations to use relevant risk information in classification and calibrate vigilance to assessed exposure.
Guidance / Guidance / Retained guidance edition · Paragraph 19Meaning: Paragraph 71 places examination before any declaration and keeps filing conditional; it does not call for an automatic report on every identified transaction. This is guidance, not a verified current statutory duty.
Conditions: The dated guide limits this example to paragraphs 69-70 transactions and financial organisations within its defined scope. The legal trigger and current statutory application are unverified.
Exceptions: No automatic filing or broader trigger is inferred. Preserve 'where appropriate'; check current CMF provisions, procedure and professional restrictions. Current statutory applicability is unverified.
Suggested action: For transactions described in paragraphs 69-70, the 2025 non-binding guide expects enhanced examination and a Tracfin declaration only where appropriate.
Guidance / Guidance / Retained guidance edition · Paragraph 71Notices and limitations
- Illustrative bank, payments and crypto examples, not an assessed firm profile.
- Product/customer exposure alone is not statutory applicability. This is not a licensing guide.
- Local entity / domestic activity selected.
- 3 representative requirements and guidance examples; see the full register for other duties.
- Guidance from a retained reviewed edition; current statutory applicability is not verified.
- Source observations are unavailable, stale, failed or review-required. This dated brief does not confirm today's legal position.
- CMF title VI and implementing originals were not retained (HTTP 403); current legal scope, duties, supervisors and FIU remit are unverified.
- FATF original and June 2026 lists were not retained (HTTP 403); the 2022 DG Trésor summary is historical. No current list position is claimed.
- The 2023 ML/TF and 2022 PF assessments are dated national analyses, not firm or customer ratings; sanctions overviews are not live lists or case decisions.
- The 2025 non-binding guide cites earlier law; current statutory applicability is unverified and reuse rights are pending.
Evidence sources
Original source documents are not reproduced in this brief. Retained originals are private research evidence; use the official-source links.
- Official Supervisory Guidance Original · Autorité de contrôle prudentiel et de résolution / Tracfin · 23 Apr 2025; update through 22 Jan 2025; texts stated in force 1 Sep 2024; ACPR marked in force 10 Oct 2026 · Paragraphs 17, 19, 69-72; complete original with annexes and footnotes retained
- Official Publication Record · Autorité de contrôle prudentiel et de résolution · Complete official page captured 10 October 2026; labels the 23 April 2025 guidance Version en vigueur · Publication status of the identified guidance edition only; not current-law confirmation
- Official National Risk Assessment · Conseil d’orientation de la lutte contre le blanchiment de capitaux et le financement du terrorisme / Direction générale du Trésor · Complete 194-page French PDF, adopted January 2023; retrieved 10 October 2026 · Executive summary pp. 8-10; threat analysis ch. 3 pp. 34-54; sector analyses chs. 7-15 pp. 78-189; source tables and annexes retained in full
- Official National Risk Assessment · Secrétariat général de la défense et de la sécurité nationale / COLB / Direction générale du Trésor · Complete 52-page French PDF, June 2022 edition; retrieved 10 October 2026 · French operational/regulatory framework pp. 15-22; threat analysis pp. 23-30; vulnerabilities and mitigations pp. 31-50; full tables retained
- Official Government Report · Direction générale du Trésor · Complete six-page French government summary of the FATF mutual evaluation, dated 17 May 2022; reports evaluation adoption on 3 March 2022 · pp. 1-2 and 4: dated historical effectiveness summary and areas for further work; not the FATF report or technical-ratings table
- Official Sanctions Information · Direction générale du Trésor · Complete official page captured 10 October 2026; published 23 September 2026 · UN/EU/French measures; no live list checked
- Official Sanctions Guidance · European Commission · Official Commission page captured 9 October 2026; shared retained original reused from existing brief evidence fixture · Identify the applicable EU restrictive-measure instrument and its conditions; shared original reused by exact hash
- Official Foreign Sanctions Guidance · U.S. Treasury, OFAC · Official FAQ page, captured 9 Oct 2026; shared original reused · FAQ 11: U.S.-person scope; no France nexus inferred
ACPR/Tracfin guidance, 23 Apr 2025
23 Apr 2025; update through 22 Jan 2025; texts stated in force 1 Sep 2024; ACPR marked in force 10 Oct 2026 · Paragraphs 17, 19, 69-72; complete original with annexes and footnotes retained
Source record
Retrieved 2026-10-10T06:13:09Z. SHA-256: a1eae0e3d31d648b330c0e273d6ff524459a26e849bde7b69345b681bb74b4c0
Source retrieval check
observed · Checked 2026-10-12T06:00:01.473Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
ACPR publication record, checked 10 Oct 2026
Complete official page captured 10 October 2026; labels the 23 April 2025 guidance Version en vigueur · Publication status of the identified guidance edition only; not current-law confirmation
Source record
Retrieved 2026-10-10T06:15:52Z. SHA-256: e8c783f31c228dfa47f71c40bc91bd27641560b0bc3b0a147ce4199fb17d06e1
Source retrieval check
review-required · Checked 2026-10-12T06:00:03.320Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
COLB ML/TF NRA, adopted Jan 2023
Complete 194-page French PDF, adopted January 2023; retrieved 10 October 2026 · Executive summary pp. 8-10; threat analysis ch. 3 pp. 34-54; sector analyses chs. 7-15 pp. 78-189; source tables and annexes retained in full
Source record
Retrieved 2026-10-10T06:13:23Z. SHA-256: eb15343d4a20d162e84f6d8782aece96b94e5b18544f9296130f91885da30229
Source retrieval check
observed · Checked 2026-10-12T06:00:04.636Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
COLB/SGDSN PF NRA, June 2022
Complete 52-page French PDF, June 2022 edition; retrieved 10 October 2026 · French operational/regulatory framework pp. 15-22; threat analysis pp. 23-30; vulnerabilities and mitigations pp. 31-50; full tables retained
Source record
Retrieved 2026-10-10T06:13:23Z. SHA-256: c28c468f6eb5c086765b83a4fab316df43717ac82a1824e68c08e5bd2f7b4001
Source retrieval check
observed · Checked 2026-10-12T06:00:05.866Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
DG Trésor FATF MER summary, 17 May 2022
Complete six-page French government summary of the FATF mutual evaluation, dated 17 May 2022; reports evaluation adoption on 3 March 2022 · pp. 1-2 and 4: dated historical effectiveness summary and areas for further work; not the FATF report or technical-ratings table
Source record
Retrieved 2026-10-10T06:15:37Z. SHA-256: ff29303212fad8864549676749a26f2427f04a3345b05f398ce751eac2ce9485
Source retrieval check
observed · Checked 2026-10-12T06:00:08.661Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
DG Trésor sanctions overview (23 Sep 2026)
Complete official page captured 10 October 2026; published 23 September 2026 · UN/EU/French measures; no live list checked
Source record
Retrieved 2026-10-10T06:13:37Z. SHA-256: 2b3ee4f6b31dec7ca29fc1a517f1bf5b5a740024d8add44a6e1928f751dfccf1
Source retrieval check
observed · Checked 2026-10-12T06:00:09.329Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
EU sanctions overview, captured 9 Oct 2026
Official Commission page captured 9 October 2026; shared retained original reused from existing brief evidence fixture · Identify the applicable EU restrictive-measure instrument and its conditions; shared original reused by exact hash
Source record
Retrieved 2026-10-09T19:54:30Z. SHA-256: 84d90e3b6d3d7ca27c33d98783660ea6e86c7f837a8006418763b4e96dab98c4
Source retrieval check
review-required · Checked 2026-10-12T06:00:10.454Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
OFAC FAQ 11 (21 Aug 2024)
Official FAQ page, captured 9 Oct 2026; shared original reused · FAQ 11: U.S.-person scope; no France nexus inferred
Source record
Retrieved 2026-10-09T19:54:40Z. SHA-256: 92cfe8932dd817a5c2371d265ae1ecbaf62970f798c0d5c6ab77fd96897e0e99
Source retrieval check
review-required · Checked 2026-10-12T06:00:11.310Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
Retail bank
Meaning
Paragraph 17 describes pre-relationship identification and verification, relevant purpose-and-nature information and updating. Its referenced 2009 information list and separate ACPR customer-knowledge guidance are dependencies, not a universal checklist. This summarises guidance, not current statutory duty.
Full public provision explanation
Before a business relationship starts, the guidance describes identifying and verifying the customer and, where applicable, the beneficial owner. It also expects collection and analysis of information on the relationship’s purpose and nature and regular updating of that information. The referenced 2 September 2009 list and separate ACPR customer-knowledge guidance are dependencies, not a universal document checklist; the current legal text and which items apply to a particular customer have not been verified.
Suggested action
The dated, non-binding guide expects in-scope financial organisations to identify and verify customers and relevant beneficial owners before onboarding, collect relevant purpose-and-nature details and keep them updated.
Conditions
The 2025 non-binding guide covers financial organisations within its defined scope and the pre-relationship trigger; beneficial-owner measures apply where relevant. Current legal scope and case-specific information requirements are unverified.
- Financial organisations in the defined scope, before a business relationship; beneficial-owner steps apply where relevant. Information items are those relevant under the cited texts/list, not a universal fixed dossier.
Exceptions
No broader audience or exception is inferred. Do not require identical evidence from every customer; check current provisions and applicable branches. Current statutory applicability is unverified.
- No broader audience or exception is inferred beyond the original paragraph. Current legal scope is not verified.
Payments and e-money
Meaning
Paragraph 19 points to statutory risk factors, Tracfin typologies and alerts, national/sector assessments and authority material. It says simplified measures cannot be used where the relationship involves ML/TF suspicion. This is the guide's expectation, not a verified current duty.
Full public provision explanation
The guidance expects the organisation to calibrate vigilance to its exposure and to build/update its risk classification using the listed legislatively identified risks, Tracfin typologies and alerts, national and sectoral risk assessments, competent authorities’ material, and cases where simplified measures are permitted. It expressly says simplified measures cannot be used for a business relationship where there is ML/TF suspicion. Adjacent Box 2 explains Tracfin AAV handling separately. Every cited statutory reference and the claimed boundary between measures requires current-law verification; the paragraph does not independently establish a 2026 legal prohibition. The citation to article L. 561-4-1 carries footnote marker 24 in the PDF; the marker is not part of the article number.
Suggested action
The 2025 non-binding guide expects in-scope organisations to use relevant risk information in classification and calibrate vigilance to assessed exposure.
Conditions
The dated non-binding guide addresses risk classification and business relationships of organisations in its defined scope. Its suspicion statement applies only where suspicion exists; current statutory conditions remain unverified.
- Defined financial organisations; their risk classification and business relationships, with intensity linked to assessed ML/TF exposure. The explicit no-simplified-measures statement is limited to a business relationship for which suspicion exists; other statutory conditions remain unverified.
Exceptions
This is not a blanket ban on simplified measures: use them only where current law permits. The adjacent Tracfin AAV process is separate. Current statutory applicability is unverified.
- No broader audience or exception is inferred beyond the original paragraph. Current legal scope is not verified.
Crypto and digital assets
Meaning
Paragraph 71 places examination before any declaration and keeps filing conditional; it does not call for an automatic report on every identified transaction. This is guidance, not a verified current statutory duty.
Full public provision explanation
The guidance describes enhanced examination after identifying the transactions in paragraphs 69-70, followed by a suspicious-transaction declaration only where appropriate. “Where appropriate” is retained; no automatic report rule is inferred. Footnote 67 is separately recorded at PDF page 22 and cites the ACPR Sanctions Commission decision of 15 February 2023, proceeding 2022-01, paragraphs 32-33. This historical citation does not establish current statutory wording.
Suggested action
For transactions described in paragraphs 69-70, the 2025 non-binding guide expects enhanced examination and a Tracfin declaration only where appropriate.
Conditions
The dated guide limits this example to paragraphs 69-70 transactions and financial organisations within its defined scope. The legal trigger and current statutory application are unverified.
- The guidance describes enhanced examination after identifying the transactions in paragraphs 69-70, followed by a suspicious-transaction declaration only where appropriate. “Where appropriate” is retained; no automatic report rule is inferred. Footnote 67 is separately recorded at PDF page 22 and cites the ACPR Sanctions Commission decision of 15 February 2023, proceeding 2022-01, paragraphs 32-33. This historical citation does not establish current statutory wording.
Exceptions
No automatic filing or broader trigger is inferred. Preserve 'where appropriate'; check current CMF provisions, procedure and professional restrictions. Current statutory applicability is unverified.
- No broader audience, automatic trigger, or exception is inferred beyond the source paragraph. Current legal scope is unverified.