Crypto ATM / kiosk operator in France
Physical kiosks that exchange cash for crypto (and sometimes vice versa). High-cash AML risk profile.
Crypto ATM is conditionally permitted in France with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- CASP authorization (MiCA) via AMF — covers custody, exchange, and transfer services; minimum capital of €150,000 for exchange activity applies
- Mandatory KYC: collect, verify, and store identity documents (two forms of ID required for natural persons)
- Enhanced Due Diligence (EDD) for high-risk scenarios: PEPs, transactions over €1,000 to self-hosted wallets, and cross-border activities
- Ongoing transaction monitoring and ML/FT risk assessment systems required
- KYB for corporate clients including beneficial ownership verification
- Managers and beneficial owners verified during AMF registration
- TRACFIN reporting: suspicious transaction reports (STRs) required for AML/CFT
- FATF Travel Rule compliance under MiCA for transfers of crypto assets
- DAC8 reporting (effective January 1, 2026): must report user crypto transactions to tax authorities
Key Restrictions
- Must obtain full CASP authorization from AMF (not mere registration); existing PSAN/DASP regime replaced by MiCA
- Short transition window — existing PSANs had to apply by June 30, 2025; new entrants must apply under MiCA CASP framework
- Physical kiosk locations likely trigger ACPR prudential oversight in addition to AMF licensing
- Minimum capital requirements apply (€125,000–€350,000 for CASP activities; at least €150,000 if exchange services are offered at kiosks)
- Cash transactions face heightened AML scrutiny — EDD triggered for self-hosted wallet cash-out over €1,000
- Local entity incorporation required to obtain CASP authorization
Key Risks
- High-cash AML risk profile of ATM/kiosk operations likely attracts enhanced supervisory attention from both AMF and ACPR
- Cash transaction reporting thresholds for ATM/kiosk operators not explicitly defined in provided facts — regulatory ambiguity on specific CTR thresholds
- Short MiCA transition timeline creates risk for operators who delay CASP application
- Dual supervision (AMF + ACPR) increases compliance burden and potential for conflicting interpretations
- Reputational and regulatory risk if kiosks are used for self-hosted wallet transactions exceeding €1,000 without proper EDD
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
AMF — CASP authorization — most experienced EU NCA for crypto. Circle chose France for EU MiCA authorization.
MiCA Regulation (EU) (2023) — CASP authorization, comprehensive crypto regulation
PACTE Law (Loi PACTE) (2019) — Prior PSAN/DASP regime — EU's most mature pre-MiCA framework, replaced by MiCA
VASP: CASP authorization under MiCA via AMF. SHORT 6-month transition (existing PSANs had to apply by June 30, 2025). 3-6 months (AMF is experienced). France positioning as EU crypto hub.
CUSTODY: CASP authorization — custody is a licensed MiCA activity (EUR 50,000 minimum capital)
EXCHANGE: CASP authorization — EUR 150,000 minimum capital for trading platforms
Autorité des Marchés Financiers (AMF): Primary authority for registering/licensing Crypto-Asset Service Providers (CASPs, formerly Digital Asset Service Providers or DASPs), supervising crypto offerings (except stablecoins), and enforcing investor protection, AML, and financial regulations.
Autorité de Contrôle Prudentiel et de Résolution (ACPR): Oversees prudential supervision, AML compliance (with AMF), stablecoin issuers (e.g., authorizing Circle France, Schuman Financial, Société Générale Forge), and certain DLT infrastructures.
TRACFIN: Handles suspicious transaction reports for AML/CFT.
French adaptations to MiCA: Order (October 15, 2024), Decree (February 21, 2025), Law (April 30, 2025); replaced DASP regime with CASP licensing, integrated electronic money tokens (EMTs), and aligned with EU standards. Over 100 DASPs registered previously.
DAC8 implementation (Finance Bill 2025, effective January 1, 2026): Requires CASPs and tied providers to report user crypto transactions to tax authorities.
AML/CFT for CASPs (since December 30, 2024): Mandates KYC, transaction monitoring, and sanctions compliance.
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.
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.
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.
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.
Collect, verify, and store identity documents (e.g., two forms of ID); use third parties permitted.
Enhanced Due Diligence (EDD): For high-risk cases like PEPs, transactions over €1,000 to self-hosted wallets, or cross-border activities.
Ongoing transaction monitoring, KYB for corporate clients (beneficial ownership), and ML/FT risk assessment systems.
Managers and beneficial owners verified during AMF registration.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — Crypto ATM/kiosk operators can operate in France only with full CASP authorization from AMF, local incorporation, robust AML/KYC programs including EDD for cash transactions over €1,000, and compliance with MiCA capital requirements (minimum €150,000 for exchange services), under dual supervision of AMF and ACPR with TRACFIN for STRs.
Questions this verdict aims to answer
- What money-transmitter / kiosk-specific license is required?
- What cash-transaction reporting thresholds apply?
- What enhanced-KYC obligations attach to cash-in / cash-out?