AML/CFT Compliance in France: ACPR, AMF, and the 2026 Regulatory Landscape

France's AML/CFT regime is under heightened scrutiny as the Autorité de Contrôle Prudentiel et de Résolution (ACPR) and the Autorité des Marchés Financiers (AMF) intensify their oversight. The €600,000 fine imposed on Banque Delubac et Cie in June 2025 for deficiencies in AML/CTF systems highlights the regulators' focus on enforcement. With the EU's Anti-Money Laundering Regulation (AMLR) set to apply directly from 10 July 2027, French institutions must adapt quickly to evolving regulatory expectations.

The Regulatory Landscape

France's AML/CFT framework is built on the Code monétaire et financier (CMF), specifically Book V, Title VI, Articles L. 561-1 to L. 561-50 and Articles R. 561-1 et seq., which transposes successive EU directives. The ACPR and AMF share supervisory responsibilities, with the ACPR overseeing banks, insurance companies, and payment institutions, while the AMF regulates capital markets and asset managers. The TRACFIN, a service under the Ministry of Economy, Finance, Industry, serves as the Financial Intelligence Unit (FIU).

The European framework is being reinforced with the implementation of the AMLR (Anti-Money Laundering Regulation), which will apply directly from 10 July 2027. This regulation aims to harmonize AML procedures across the EU and introduces a more full overhaul of AML procedures, requiring firms to update their KYC dossiers and adopt a standardized approach.

ACPR's Guidance and Expectations

The ACPR has issued Lignes Directrices and Principes d'application sectoriels for LCB-FT, providing detailed guidance on AML/CFT obligations. These guidelines emphasize the importance of a risk-based approach, customer due diligence, and suspicious transaction reporting. Institutions are expected to implement documented AML/CFT systems, including ongoing monitoring and reporting of suspicious activities.

Customer Due Diligence and KYC

French CDD obligations follow the familiar EU template. Identification of natural persons requires verified data on full name, place and date of birth, nationality, and a residential address. For legal entities, verification typically rests on commercial register excerpts, articles of association, and beneficial-ownership records.

Beneficial-ownership thresholds follow the 25 % standard. Where no natural person can be identified above that threshold, the senior managing official is recorded as the “notional” beneficial owner. PEP screening is required for clients, beneficial owners, and counterparties.

Sanctions Screening

Sanctions implementation in France rests on EU regulations directly applicable in Member States, supplemented by national laws and regulations. Enforcement responsibility is shared among the ACPR, AMF, and the Ministry of Economy Directorate General of Treasury. Institutions are expected to screen against EU, UN, and national sanctions lists.

SAR/STR Reporting

Suspicious Activity Reports must be filed with TRACFIN, the FIU. In 2024, TRACFIN received 215,410 information reports and transmitted 4,000 notes to partners, with a total of 59 consolidated alerts issued on 12,079 entities. The Code monétaire et financier and TRACFIN guidelines provide detailed requirements for SAR/STR reporting.

Risk-Based Approach

The ACPR emphasizes the importance of a risk-based approach in AML/CFT compliance. Institutions are required to implement a risk-management system proportionate to their nature and size, anchored in a documented institution-wide risk assessment.

Crypto-Assets: MiCAR and PACTE Law

France's crypto-asset framework is built on the PACTE law and the upcoming MiCAR licensing requirements. Crypto-asset providers must register with the AMF and comply with AML/CFT obligations.

Recent Enforcement

Recent enforcement actions demonstrate the regulators' focus on AML/CFT compliance. The €600,000 fine against Banque Delubac et Cie in June 2025 highlights the consequences of AML/CTF deficiencies.

Practical Compliance Checklist for French Institutions

Common Pitfalls

Institutions must be aware of common pitfalls, including SAR latency and fragmented governance. The ACPR expects “without undue delay” to be a real-time standard, not a weekly one. Documented escalation processes and clear coordination across business lines are essential.

How RegMantle Helps

RegMantle generates jurisdiction-specific AML/CFT documentation for French institutions, citing the Code monétaire et financier and applicable EU regulations directly in the text. Generated documents include the institution-wide risk assessment, AML/CFT policy manual, KYC/CDD procedures aligned with ACPR guidelines, sanctions screening policy referencing the EU Consolidated Financial Sanctions List, SAR/STR procedures keyed to Code monétaire et financier Article L. 561-15 and TRACFIN guidelines, and the staff training programme required under Code monétaire et financier Article L. 561-6. All outputs are exportable as branded DOCX files ready for board approval and regulator inspection.