Centralized exchange in France
Order-book exchange that takes custody of user assets and matches trades between users.
CEX 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 under MiCA via AMF — mandatory full license (replacing former DASP/PSAN registration); minimum capital of EUR 150,000 for exchange/custody operations.
- Mandatory KYC/CDD — collect, verify, and store identity documents (e.g. two forms of ID) for all users; third-party reliance permitted.
- Enhanced Due Diligence (EDD) for PEPs, transactions over EUR 1,000 to self-hosted wallets, and cross-border activities.
- Ongoing transaction monitoring and KYB for corporate clients (beneficial ownership verification).
- ML/FT risk assessment systems required.
- TRACFIN suspicious transaction reporting (STR) obligations under AML/CFT rules applicable to CASPs since December 30, 2024.
- Travel Rule (FATF TFR recast) applies — EUR 0 threshold — mandatory transmission of originator/beneficiary data on all withdrawals and transfers.
- DAC8 reporting (effective January 1, 2026) — CASPs must report user crypto transactions to tax authorities.
- Managers and beneficial owners verified during AMF registration process.
Key Restrictions
- Must obtain full CASP authorization under MiCA via AMF (not just simple registration).
- SHORT transition: existing PSAN/DASP holders had to apply for CASP by June 30, 2025.
- Custody is a licensed MiCA activity — minimum EUR 50,000 capital for custody alone; combined exchange+custody at EUR 150,000 minimum.
- Local entity required — must be incorporated/authorized in France to serve French residents.
- CASP services must comply with MiCA market-conduct rules for orderly trading, transparency, and investor protection.
- French adaptations to MiCA (Order Oct 2024, Decree Feb 2025, Law Apr 2025) integrate local requirements with EU framework.
Key Risks
- Enforcement risk if operating without full CASP authorization after transition deadline (June 30, 2025).
- Regulatory ambiguity during the transition from PACTE DASP regime to MiCA CASP regime — different interpretations may apply.
- Travel Rule compliance imposes operational overhead on all withdrawals (EUR 0 threshold) — must implement technical solutions for data transmission.
- DAC8 tax reporting from January 2026 introduces new data-sharing obligations with tax authorities.
- AMF/ACPR dual supervision (market conduct + prudential) creates overlapping compliance burden.
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.
2024 CMF Update: Adds MiCA-aligned requirements for DASPs.
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.
Travel Rule adopted — threshold: EUR 0 (no threshold under TFR recast)
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a centralized exchange serving French residents must obtain full CASP authorization under MiCA via AMF (EUR 150k minimum capital), maintain a local entity, comply with zero-threshold Travel Rule obligations, and meet comprehensive AML/KYC oversight by AMF/ACPR/TRACFIN.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?