On-shore VASP in France
Locally-incorporated VASP that operates under full local jurisdiction, holding all required licenses and registrations.
On-shore VASP 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
- Mandatory KYC: collect, verify, and store identity documents (e.g., two forms of ID); use of third parties permitted (fr.aml.collect-verify-and-store-identity)
- Enhanced Due Diligence (EDD) for high-risk cases — PEPs, transactions over €1,000 to self-hosted wallets, or cross-border activities (fr.aml.enhanced-due-diligence-edd-for)
- Ongoing transaction monitoring and KYB for corporate clients (beneficial ownership) with ML/FT risk assessment systems (fr.aml.ongoing-transaction-monitoring-kyb-for)
- Managers and beneficial owners verified during AMF registration (fr.aml.managers-and-beneficial-owners-verified)
- FATF Travel Rule compliance with EUR 0 threshold applicable (fr.travel-rule.status)
- Suspicious transaction reports filed with TRACFIN (fr.licensing.tracfin-handles-suspicious-transaction-reports)
- AML/CFT obligations since December 30, 2024 (fr.licensing.amlcft-for-casps-since-december)
- EU AMLR/AMLD6 ongoing risk-based KYC across EU, CASPs/VASPs explicitly included (fr.aml.eu-aml-regulation-amlr-and)
- DAC8 reporting to tax authorities on user crypto transactions effective January 1, 2026 (fr.licensing.dac8-implementation-finance-bill-2025)
Key Restrictions
- Must obtain CASP authorization from AMF under MiCA (fr.licensing.vasp)
- Short transition — existing PSAN/DASP holders had to apply for CASP by June 30, 2025 (fr.licensing.vasp)
- Minimum capital requirements: EUR 150,000 for exchange/trading platforms; EUR 50,000 for custody (fr.licensing.exchange, fr.licensing.custody)
- Application timeline: 3–6 months (AMF is experienced) (fr.licensing.vasp)
- Must comply with French adaptations to MiCA: Order Oct 2024, Decree Feb 2025, Law Apr 2025 (fr.licensing.french-adaptations-to-mica-order)
- Prudential supervision by ACPR; AML/CFT oversight by AMF and ACPR jointly (fr.licensing.regulator-amf, fr.licensing.regulator-acpr)
- 30% flat tax (PFU) on crypto capital gains for individuals (fr.tax)
Key Risks
- Short transition period already lapsed — late entrants face no path under the old DASP regime and must meet full MiCA CASP requirements from the start (fr.licensing.vasp)
- Dual supervision (AMF + ACPR) creates coordination risk and high compliance overhead (fr.licensing.regulator-amf, fr.licensing.regulator-acpr)
- DAC8 reporting obligations starting Jan 2026 add tax-reporting compliance burden (fr.licensing.dac8-implementation-finance-bill-2025)
- No-threshold Travel Rule (EUR 0) means every transfer triggers Travel Rule obligations (fr.travel-rule.status)
- Enforcement precedent from the mature PACTE era — regulators have experience sanctioning non-compliant firms (fr.licensing.pacte-act-act-no-2019-486)
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.
Banque de France (BdF): Monitors stablecoins used as payment means and specific DLT setups; coordinates with AMF/ACPR.
TRACFIN: Handles suspicious transaction reports for AML/CFT.
Ordinance No. 2016-1635 (December 2016): Added crypto platforms to AML obligations under Article L.561-2 of the Monetary and Financial Code (MFC).
Ordinance No. 2017-1674 (effective December 8, 2017): Enabled blockchain registration for unlisted securities.
PACTE Act (Act No. 2019-486, May 22, 2019): Introduced DASP registration with AMF and ICO framework; foundation for current rules.
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)
Evidence fact fr.tax not found (may have been renamed).
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 — an on-shore VASP in France must be locally incorporated and obtain full CASP authorization from AMF under MiCA (3–6 month process, EUR 50k–150k minimum capital, dual AMF/ACPR supervision), with comprehensive AML/CFT obligations including no-threshold Travel Rule and DAC8 tax reporting from 2026.
Questions this verdict aims to answer
- What license(s) are required to operate locally?
- What capital, governance, and reporting obligations apply?
- What is the application process and timeline?