France -- AML/CFT Compliance Regulatory Overview

Cryptocurrency and virtual asset service providers (VASPs), known as Digital Asset Service Providers (DASPs or PSANs) in France, must register with the Autorité des Marchés Financiers (AMF) and comply with AML/CFT obligations derived from the PACTE Law (2019), the EU's Fifth AML Directive (implemented January 2020), MiCA Regulation, EU AMLR, and AMLD6. These requirements encompass customer due diligence (CDD), suspicious transaction reporting, and record-keeping, with oversight primarily by the AMF and ACPR, and reporting to TRACFIN.[1][2][3][4][6][8]

Key AML/CFT Legislation

• PACTE Law (Loi PACTE, 2019): Introduced mandatory registration for DASPs (e.g., crypto exchanges, custodians, wallet services, crypto-to-crypto platforms) and imposed AML standards.[1][6]
• EU Fifth AML Directive (5AMLD): Implemented in France in January 2020, requiring AML/CFT policies, CDD, and registration for all crypto firms serving French clients.[3]
• Markets in Crypto-Assets Regulation (MiCA): Enhances transparency, security, and AML for crypto providers; DASPs must transition to CASP licensing with minimum capital (€125,000–€350,000) and FATF Travel Rule compliance.[1][2][4][7]
• EU AML Regulation (AMLR) and Sixth AML Directive (AMLD6): Standardizes KYC as ongoing, risk-based processes across EU, explicitly including CASPs/VASPs; aligns with AMLA for cross-border supervision.[4][5]
• 2024 CMF Update: Adds MiCA-aligned requirements for DASPs.[4]

Customer Due Diligence (CDD/KYC) Requirements

DASPs must implement risk-based CDD for all clients, regardless of transaction amount, prohibiting anonymous accounts or transactions:

• Collect, verify, and store identity documents (e.g., two forms of ID); use third parties permitted.[2][3]
• Enhanced Due Diligence (EDD): For high-risk cases like PEPs, transactions over €1,000 to self-hosted wallets, or cross-border activities.[2][4]
• Ongoing transaction monitoring, KYB for corporate clients (beneficial ownership), and ML/FT risk assessment systems.[3][4][5][6]
• Managers and beneficial owners verified during AMF registration.[3][6]

Suspicious Transaction Reporting

DASPs must report suspicious activities to TRACFIN (Traitement du renseignement et action contre les circuits financiers clandestins), France's financial intelligence unit, via SARs; includes monitoring for fraud, ML/FT, and asset freezes.[4][9]

Record-Keeping Obligations

Maintain records of CDD, transactions, and monitoring for at least 5 years (standard EU AML period, aligned under AMLR/MiCA); supports audits by AMF, ACPR, or TRACFIN.[2][5]

Oversight Authorities

Non-compliance risks fines, sanctions, or deregistration; crypto-to-crypto and trading platforms follow simplified registration but full AML obligations.[1][3][6] As of 2026, MiCA and AMLR fully harmonize these with EU standards.[2][5][7]