The National Asset Freeze Registry is the list published and maintained by the Directorate General of the Treasury. It lists the individuals, entities, and vessels subject to an asset freeze measure in effect in France, whether resulting from a decision by the United Nations, the European Union, or France. It can be viewed online at gels-avoirs.dgtresor.gouv.fr, can be exported as a time-stamped PDF, and remains accessible via API in JSON and XML formats to feed a screening tool.
Asset freeze measures must be implemented immediately upon taking effect. As soon as a name is entered into the registry, your customer database must be able to be cross-checked against it. The registry is open to the public, but the challenge lies in the organizational efforts required to detect updates, restart the screening process, and keep a record of each check.
National Freeze Registry: Four Access Methods and Their Uses
| How to Access | What it does | When to Use It | Limit to be aware of |
| Online search on the registry's website | Check a name, alias, or vessel, one at a time | One-time check, clarifying an alert | Does not cover an entire customer base or transaction flows |
| Export a time-stamped PDF of the results | Keep a dated copy of the search results | Compilation of the Evidence File | Fixed copy: It does not reflect subsequent updates |
| Registry API in JSON and XML formats | Populate a screening tool with the updated list | Automated Screening of the Customer Base and Operations | Requires integration and verification that each update has been loaded correctly |
| "Flash Freeze Alert" Alert Letter | Be notified of a new measure, a change, or a lifting of restrictions | Initiating a new screening process | Indicates a change, but does not replace the check |
What is the National Freeze Registry, and who maintains it?
The National Asset Freeze Registry lists individuals, legal entities, and vessels subject to an asset freeze measure applicable within French territory. These measures may be imposed by the United Nations, the European Union, or France. The Directorate General of the Treasury publishes and updates this registry in accordance with the provisions of the Monetary and Financial Code.
The registry serves asthe official inventory of measures currently in effect. The accompanying guide specifies the definition and scope of the asset freeze. The purpose of the registry is not to assess the merits of a measure. It indicates that a measure is in effect, which requires the parties concerned to comply with it as soon as it takes effect.
Where can I view the national freeze registry?
The official website gels-avoirs.dgtresor.gouv.fr provides access to the complete registry. There, you can search for a person, entity, or vessel by name, alias, or identifier, and then view the published identifying information, including date of birth, nationality, address, and the reasons for the measure.
Online Search and Time-Stamped Export
Online searches are conducted one case at a time. They are sufficient to resolve any doubts about an alert or to verify a client prior to a one-time transaction. The results can be exported as a time-stamped PDF and retained as evidence of due diligence. This copy captures the status as of a specific date but does not track subsequent updates to the registry.
Exporting to PDF does not replace automated screening of your customer database. To compare an entire portfolio against the registry or filter transaction streams, you must upload the list to a screening tool.
APIs and Structured Formats
The registry is distributed via API in JSON and XML formats, in accordance with the technical specifications published by the Directorate General of the Treasury. Each person, entity, or vessel has a unique identifier, its aliases, its identifying information, and the reference number of the measure that applies to it. The API allows you to load the registry’s up-to-date data into your screening tool, which then compares your customer data against the list.
Does the registry cover all sanctions lists?
The registry lists the asset freeze measures in effect in France. It covers decisions by the United Nations, the European Union, and France, but does not include lists published by other states or restrictive measures other than asset freezes, such as sectoral embargoes or export restrictions.
The registry also does not cover lists of politically exposed persons. These individuals are subject to due diligence requirements regarding “ AML-CFT ” rather than asset freezing. The guide on international financial sanctions outlines the other regimes that must be screened.
If your business exposes you to lists from other jurisdictions, you must determine which ones to consider in addition to the national registry, with an appropriate traceability requirement. A screening tool must be able to import data from multiple sources and keep a record of each check.
How can I keep track of registry updates?
The Treasury Department issues an email newsletter, “Freeze Alert,” which reports on new freezing measures, changes to them, and their lifting. This alert should serve as a trigger for a new screening of your customer database and, if necessary, your ongoing transactions. To subscribe, visit the page dedicated to economic sanctions.
The registry is updated regularly, with no set schedule. The alert letter does not replace the audit. It notifies you that a change has occurred, but you must download the updated list and run the screening process again. Establish an internal division of responsibilities to determine who receives the letter, initiates the audit, keeps a record of it, and handles the alerts.
When should customer and operational data be reconciled against the ledger?
For financial institutions, audits must be conducted at three specific times:
- before entering into a business relationship or carrying out a one-time transaction;
- whenever the registry is updated, for the existing customer base;
- before the operations are completed.
Freezing measures must be enforced immediately upon their entry into force. It is therefore prohibited to carry out any transaction that would violate a freezing measure or a prohibition on making funds available, even if the person in question was already a client before the measure took effect.
When Starting a Relationship
Before opening an account, signing a contract, or carrying out an initial transaction for a new customer, you must verify the customer’s identity against the registry. This verification is part of the process for implementing asset freeze measures and must be documented. The documentation must specify the version of the registry used, the date of the verification, the result obtained, and the decision made.
If a match is found, compare the identifying information published in the registry with that in your customer file. A shared name alone is not sufficient to reach a conclusion. The date of birth, nationality, aliases, and address can help resolve any doubts. Document the decision and its rationale before proceeding.
Every time the registry is updated
As soon as a new measure takes effect or identification details are updated in the registry, you must screen your customer database immediately. The “Freeze Alert” letter notifies you of this change. You then upload the updated list to your tool, rerun the screening, address the alerts, and keep a record of each step.
A customer who was not a target yesterday may be one today. The absence of an alert at the time a customer relationship is established does not, therefore, preclude the need for ongoing monitoring. According to the joint guidelines issued by the Directorate General of the Treasury and the ACPR, the customer database must be screened without delay when new measures take effect or when published identification criteria are modified.
Before performing an operation
Before a transaction is settled, you must verify that the individuals and entities involved in the transaction are not subject to any applicable asset freeze. Depending on the nature of the transaction and the available data, the screening may include the originator, the beneficiary, and any intermediaries. A screening tool connected to up-to-date lists filters transactions and issues an alert before the transaction is completed.
If an alert is triggered during an operation, suspend the operation while you analyze it and, if a match is confirmed, follow the procedure for when a customer is subject to an asset freeze. Do not assume that a customer who was screened when the relationship began is no longer on the registry. Only an up-to-date screening can confirm this.
How can we automate the monitoring of the national freeze registry?
A screening tool can load data from the registry via its API, compare your customer data to the list using approximate name matching, and then rank alerts based on their likelihood of a match. Depending on its features and configuration, the engine can handle transliterations, reversed first and last names, aliases, and spelling variations.
AP Scan, which screens against asset freeze and sanctions lists, compares your customer database and transactions against the national asset freeze registry, international sanctions lists, and politically exposed persons (PEP) databases. List updates and portfolio re-screening are automated, while all actions remain traceable to meet audit requirements. Payment flow screening with AP Filter completes the system by verifying transactions before they are executed.
What records should you keep in case of an audit?
An auditor may request the following:
- the version of the list used and the date it was uploaded;
- the screened area;
- each alert, along with the decision made, the person who made it, and the rationale;
- the asset freeze measures implemented and the reports filed.
Without this information, you cannot prove that you have fulfilled your obligations. Keep a record of every entry in the log, every screening performed, every alert addressed, and every decision made.
A time-stamped PDF export of the log, a screenshot of the tool at the time of the audit, or a dated event log can help document your due diligence. Traceability also applies to cases in which no alerts were triggered. You must be able to demonstrate that the audit actually took place.
From updating the registry to verifying compliance
| Step | What's Going On | What You Need to Be Able to Show |
| Registry Update | A measure is added, modified, or lifted | The date on which the institution became aware of this |
| Loading into the tool | The updated list replaces the previous one | The version used and the date it was uploaded |
| Screening | The affected customer base and operations are confronted with the list | The screened area and the result obtained |
| Handling the Alert | An analyst confirms or rules out the match | The Decision, Its Author, and Its Rationale |
| Suites | If the match is confirmed, the freeze procedure applies | The measures taken and the statements made |
Verify that the list loaded into your tool includes the latest measures published by the Directorate General of the Treasury. Subscribe to the “Flash Info Gel” newsletter if you haven’t already, then determine internally who will receive the alert, trigger the new screening, and keep a record of it. Before selecting a tool, review the ten criteria for choosing a screening tool.
FAQ
Is the national freeze registry public?
Yes. The Treasury Department publishes the national asset freeze registry on a dedicated website, where anyone can search for a person, entity, or vessel. The results can be exported as a time-stamped PDF and retained as proof of due diligence. The registry is also accessible via API, allowing it to be integrated into an internal tool or screening solution.
Does the national freeze registry include U.S. sanctions?
No. The registry lists the sanctions currently in effect on French territory that have been imposed by the UN, the European Union, or France. Lists published by other countries, including the United States, are not included. If your business activities expose you to these sanctions, you must determine which ones to take into account in addition to the registry, with appropriate traceability requirements.
How often is the national freeze registry updated?
The Treasury Department states that the registry is updated regularly, with no set schedule. To ensure you don’t miss any changes, subscribe to its “Flash Info Gel” newsletter, which alerts you to new measures, modifications, and liftings, and then verify that your screening tool loads the updated list as soon as it is published. Keep a record of the date of each update, as an auditor may request this information.
What should you do if a customer has the same name as someone listed in the registry?
A match based on the name alone is not sufficient to reach a conclusion. Compare the identifying information published in the registry—such as date of birth, nationality, or aliases—with that in your customer file, and then document the decision and the rationale behind it. If any doubt remains, follow your alert-handling procedure before proceeding with any transaction.
Can a screening tool be connected to the national freeze registry?
Yes. The registry is distributed via API in structured formats that screening tools can import. Each person, entity, or vessel has a unique identifier, which is useful for tracking a designation as updates are made. Automation does not eliminate the need to verify that each new list has been successfully imported and that the screening process has been rerun across the entire portfolio.
