An ACPR audit is not something you handle on the day the request arrives. It requires advance preparation—in your procedures, your supporting documentation, your governance, and your ability to justify every decision made regarding AML-CFT compliance. For you, the challenge lies not only in having a system in place. It hinges above all on your ability to demonstrate its effectiveness. In 2025, theACPR introduced new AML-CFT questionnaires to support its risk-based supervision. In April 2026, it also updated its guidelines on asset freezing, in collaboration with the Directorate General of the Treasury.
At AP Solutions IO, we approach this topic from a strictly operational perspective. You must be able to justify your KYC and KYB processes, the lifting of a sanctions-related alert, or an escalation to TRACFIN, a review of the transaction monitoring system or even a weighting applied in risk assessment. This requirement calls for a process that is clear, traceable, and auditable. It is precisely at this level that a RegTech based on a logic of transparency comes into its own.
What is the ACPR? Mandate, scope, and relationship with the Banque de France
ThePrudentialPrudential Control and Resolution Authority is an administrative authority attached to the Bank of France. It supervises the banking and insurance sectors in France. Its scope of action is not limited to prudential supervision. It also covers consumer protection, the anti-money laundering and counter-terrorist financing, the authorization of relevant entities, and resolution tasks.
For a compliance officer, the useful definition is simple: theACPR is the authority that can come to verify the actual soundness of your organization. It examines the quality of your framework, the associated governance, how you classify risks, the robustness of controls, and the quality of remedial actions. It also works in conjunction with other institutional actors, notably TRACFIN at the national level, and operates within a European and international framework for supervision regarding AML-CFT.
It is often at this stage that operational stress begins to surface. Your teams havetools, procedures, and tracking tables, and sometimes multiple filtering engines and data sources. Yet, when it comes time for an audit, the same question arises: Can you prove why a particular business relationship was classified as high risk, why a specific alert was dismissed, and why a particular enhanced measure was selected? When the answer still depends on manual reprocessing, the risk becomes immediate.
AML-CFT Controls AML-CFT Frequency, Scope, and Key Considerations
TheACPR conducts document-based inspections and on-site inspections. The AML-CFT questionnaires inform its risk assessment. On-site inspections, meanwhile, are part of an annual inspection schedule, with a joint report at the end of the inspection and follow-up actions scaled according to the findings.
In fact, theACPR does not limit itself to your internal documents. It verifies how your organization actually operates. The quality of a system is assessed based on very concrete factors:
- relevance of the risk classification ;
- quality of customer insight ;
- effectiveness of constant vigilance ;
- consistency of consistency of ;
- robustness of the international sanctions ;
- risk management related to politically exposed persons (PEP) ;
- how internal control ;
- team building and decision-making transparency.
The freezing of assets requires particular vigilance. The guidelines updated in April 2026 reiterate that these measures must be applied as soon as they take effect and that they constitute a performance-based obligation. They should therefore not be treated as a mere extension of therisk-based approach.
For a regulated institution, this distinction is critical, as it directly affects enforcement procedures, processing times, internal controls, and the documentation of actions taken.
We design our devices to meet these high standards. With AP Scan, AP Scoring, AP Monitoring and AP Filter, we help you build a compliance environment capable of producing a clear decision. Our SaaS, designed for full integration via API and hosted in France, allows you to link data, rules, and evidence within a single audit trail.
ACPR Sanctions: History, Amounts, and Publication
The ACPR sanctions are not merely an abstract risk. Since 2024, several decisions have underscored thelevel of compliance expected regarding the fundamentals of AML-CFT. In 2024 and 2025, the Sanctions Commission issued reprimands accompanied by fines of 1 million euros, 600,000 euros and 250,000 euros. The violations identified concerned fundamental issues: an insufficiently discriminating risk profile, and failures in ongoing monitoring, inadequate monitoring of operations, and weaknesses in internal control.
The message to regulated institutions is clear. TheACPR does not merely penalize the absence of procedures. It penalizes the discrepancy between the stated framework and its operational implementation. When the scoring does not properly distinguish between cases, if alerts are not prioritized in a way that is actionable, if decision-making processes are not formalized or documented, or if the audit trail does not allow for the identification of responsibilities, the system becomes vulnerable. The risk of disciplinary action then increases rapidly.
The procedure itself is structured. The Supervisory Board initiates disciplinary proceedings and refers the matter to the Sanctions Commission. The Commission investigates the case, summons the parties, holds a hearing, and imposes a sanction, if appropriate. Decisions are published in the Authority’s official register. The law also provides, in certain cases, for publication in an anonymous form.
Possible sanctions range from warnings and reprimands to the partial or total revocation of authorization, along with, depending on the circumstances, bans on conducting business or measures targeting executives.
For you, the true cost goes beyond the fine itself. It includes the cost of remediation, the mobilization of teams, a review of your systems, the pressure placed on governance, and the reputational impact resulting from the publication of the decision. That is why we advocate for a demonstrable prevention strategy, supported by explainable augmented intelligence, rather than an accumulation of tools that are opaque or difficult to audit.
Compliance Checklist: 10 Points to Check Before an Audit
Before an ACPR inspection, we recommend that you check at least the following items:
- your AML-CFT risk mapping must be up to date, validated, and linked to operational criteria;
- your files KYC and KYB must be sufficiently complete, with prioritized remediation;
- your scoring must explain the source used, the date of the update, the weighting applied, and the impact on the business relationship;
- your transaction monitoring system must be based on reviewed, versioned, and justified scenarios;
- your system for sanctions filtering and PEP must retain evidence of implementation, review, and internal reporting;
- your asset asset freeze must be capable of being executed immediately and must be fully documented;
- your reports and analyses intended for TRACFIN must be categorized, archived, and linked to the decisions made;
- your governance must clearly define the responsibilities among business units, compliance, ongoing monitoring, and management;
- Your control plan and internal reports must allow you to track issues, corrections, and resolution times;
- Your system must maintain a complete audit trail of alerts, human reviews, and final decisions.
This checklist is immediate value. It helps you prepare for an audit. It also allows you to reduce false positives, prioritize alerts more effectively, and make your processing workflows clearer. At AP Solutions IO, we structure this work around more than 90 configurable criteria and an open, multilingual, no-code. Depending on the use case, this approach can reduce 98% of false positives. The decision remains in human hands, and the evidence becomes fully actionable.
Prepare for ACPR compliance with AP Solutions IO
We have developed AP Solutions IO to address the pressure facing compliance departments, CCOs, RSCI, MLROs, KYC and group legal departments. You must go beyond a theoretical framework. You must demonstrate compliance to the regulator, with a clear decision-making chain, actionable traceability, and technology that you can explain.
Our position is clear: we provide you with French RegTech, hosted locally, designed for both large enterprises and ME. Its Glass Box aligns with your auditability requirements and your compliance obligations regarding AML-CFT , and your governance efforts related to the European Artificial Intelligence Regulation (AI Act).
For more information, please also visit our page on compliance, and our article on AML-CFT, and our breakdown of TRACFIN and our compliance glossary.
Contact us to evaluate your system ACPR, improve the reliability of your controls, and upgrade your compliance architecture within a documented, traceable, and audit-ready framework.
FAQ
Can the ACPR impose sanctions without issuing a warning?
A ACPR sanction is not the result of an instantaneous decision. It is issued as part of a structured disciplinary procedure: review of documents or on-site inspection, initiation of proceedings by the Board, notification of charges, adversarial investigation, hearing, and then a decision by the Sanctions Commission. However, you have no control over either the timeline of the review or the standard of proof applied to your evidence.
What is the difference between the ACPR and the AMF?
TheACPR primarily supervises the banking and insurance sectors, with responsibilities in prudential supervision, customer protection, AML-CFT and resolution. TheAMF regulates the financial market, protects savings invested in financial products, ensures investor disclosure, and oversees the proper functioning of the markets. The two authorities also cooperate within the framework of the joint ACPR-AMF unit
