Skip to content

AML/CTF compliance in France


Money laundering and terrorism financing laws in France?

In France, money laundering and terrorism financing are serious offences and are governed by the Monetary and Financial Code (Code monétaire et financier) and the French Criminal Code (Code pénal)


Key obligations reporting entities have under French laws?

The key obligations under the AML/CTF laws in France include:

  • Customer Due Diligence (CDD) - covered entities, including banks, financial institutions, insurance companies, notaries, lawyers, accountants, real estate agents, and other professionals, are required to establish and implement risk-based CDD measures. This includes verifying the identity of customers, obtaining beneficial ownership information, and assessing the risk associated with each customer.
  • Enhanced Due Diligence (EDD) - in cases where there is a higher risk of money laundering or terrorism financing, covered entities are required to apply enhanced due diligence measures. This may include obtaining additional information, conducting enhanced monitoring, and obtaining senior management approval for high-risk relationships.
  • Reporting Suspicious Transactions - covered entities must report any knowledge, suspicion, or reasonable grounds for knowledge or suspicion of money laundering or terrorism financing to the French Financial Intelligence Unit (Tracfin). The reports should be made promptly when suspicion arises.
  • Record-Keeping - covered entities must maintain records of transactions, customer identification information, and supporting documentation for at least five years from the date of the last transaction. These records should be readily available for examination by regulatory authorities.
  • Compliance Programs - covered entities are expected to establish and maintain effective AML/CFT compliance programs. This includes implementing internal policies, procedures, and controls to detect, prevent, and report money laundering and terrorism financing activities. Staff training and regular independent audits are also important components of these programs.


ML/TF regulators in France and what functions do they perform?

In France, the regulators responsible for overseeing and enforcing anti-money laundering (AML) and counter-terrorism financing (CTF) measures are primarily:

  • Tracfin - Tracfin is the French Financial Intelligence Unit (FIU). It operates under the Ministry of the Economy and Finance and is responsible for receiving, analysing, and disseminating reports of suspicious transactions to relevant law enforcement and judicial authorities.
  • Autorité de Contrôle Prudentiel et de Résolution (ACPR) - the ACPR is the French prudential supervision and resolution authority. It oversees and regulates banks, insurance companies, and other financial institutions to ensure compliance with AML/CTF regulations.
  • Autorité des Marchés Financiers (AMF) - the AMF is the French financial markets regulator. It supervises and regulates the securities market, including stock exchanges, investment firms, asset management companies, and other entities operating in the capital markets.
  • Prudential Control and Resolution Authority (ACPR) - the ACPR is responsible for regulating and supervising insurance companies and intermediaries to ensure compliance with AML/CTF obligations in the insurance sector.
  • Banque de France - the Banque de France is the central bank of France. It collaborates with other regulatory authorities and plays a role in monitoring AML/CTF compliance in the financial sector.

There are other Government agencies that support prevention of money laundering and terrorism financing activities including:

France actively cooperates with international counterparts in combating money laundering and terrorism financing. This involves exchanging information, cooperating on investigations, and providing assistance to other jurisdictions when requested.


Industry sectors subject to ML/TF regulations?

The regulated industry sectors in France subject to AML and CTF regulations include, but are not limited to:

Banks and Financial Institutions

Including banks, credit unions, fintechs, leasing companies, financial planners and other non-bank FIs.

Learn more

Insurance companies

Including various types of insurance companies.

Learn more

Payment service providers

Including payment processing service providers.

Learn more

Investment firms and asset managers

Including wealth, asset, fund and hedge fund managers.

Learn more

Securities and capital markets

Including stockbrokers, trading houses and securities dealers.

Learn more

Money service businesses

Including foreign exchange traders, bureau de change and money services businesses (with and without agency networks).

Learn more

Legal professionals and law firms

Including legal professionals such as lawyers, barristers and small, medium-sized and large law firms.

Learn more

Accountants and auditing firms

Including accounting professionals such as accountants, bookkeepers and auditors working in small, medium-sized and large accounting firms.

Learn more

Real estate agents and property developers

Including commercial and residential real estate agents, property financiers and property developers working in small, medium-sized and large real estate firms.

Learn more

Gambling operators and casinos

Including casinos, hotels, pubs and clubs, racetracks, online gaming and on/off-course bookmakers.

Learn more

Precious metals and stones dealers

Including gold, silver and other precious metals and stone dealers.

Learn more


Penalties for non-compliance with AML/CTF laws?

The penalties for non-compliance with money laundering and terrorism financing laws in France can include the following:

  • Administrative Penalties - the regulatory authorities, such as the French Anti-Money Laundering Authority (Traitement du renseignement et action contre les circuits financiers clandestins - TRACFIN) or the French Prudential Supervision and Resolution Authority (Autorité de contrôle prudentiel et de résolution - ACPR), have the power to impose administrative fines for breaches of AML/CTF requirements. These fines can vary depending on the nature and severity of the violation. The maximum administrative fine that can be imposed is €5 million for individuals and €5 million or 10% of the average annual turnover for legal entities.
  • Criminal Offences - individuals or entities convicted of money laundering or terrorism financing offences can face fines imposed by the courts. The fines can be substantial and are typically based on the value of the illicit funds involved in the offence.
  • Imprisonment - convictions for money laundering or terrorism financing offences can result in imprisonment for individuals involved in such activities. The length of imprisonment can vary depending on the offence.
  • Forfeiture of Funds and Assets - Authorities have the power to seize and confiscate funds and assets that are determined to be involved in or derived from money laundering or terrorism financing activities. This includes freezing bank accounts, seizing properties, or confiscating other assets.


Largest fines for non-compliance with AML/CTF laws?

French regulators have shown they are willing to take action for non-compliance with AML/CTF laws and have used their powers extensively, below is an example of some of the largest fines for non-compliance with anti-money laundering laws:

  • Western Union - In 2019, ACPR cited the U.S.-headquartered money services business for 10 breaches of AML rules from January 2014 to June 2017, including failures to vet high-risk clients adequately and report suspicious activity to Tracfin, the country's financial intelligence unit, and fined them €1 billion.
  • UBS - In 2019, a French court fined Swiss Bank UBS a record €3.7 billion for tax fraud.
  • Société Générale - In 2018, Société Générale, one of the largest banks in France, was fined €5 million by the French Prudential Supervision and Resolution Authority (ACPR) for shortcomings in its anti-money laundering controls. The fine was related to deficiencies in customer due diligence processes and internal controls.
  • HSBC - In 2017, HSBC's French subsidiary was fined €3.7 million by the ACPR for failures in its anti-money laundering framework. The fine was imposed due to weaknesses in customer due diligence, record-keeping, and internal controls.  Also in 2017, HSBC agreed to pay USD$352m to settle charges that it helped wealthy clients of its private Swiss bank evade taxes in France.
  • BNP Paribas: In 2016, BNP Paribas, one of the largest banks in France, was fined €10 million by the ACPR for deficiencies in its anti-money laundering procedures. The fine was related to shortcomings in customer due diligence and transaction monitoring processes.