Professionals involved in the trading of precious metals, gemstones, or other goods falling within the scope of Regulation AML-CFT are subject to the obligations set forth in the Monetary and Financial Code. For occasional transactions, certain due diligence measures are triggered once the applicable regulatory thresholds are met, assessed, where applicable, on a cumulative basis…

For an online gaming operator, the obligations set forth at AML-CFT apply from the moment a relationship is established and continue throughout its duration: identification and verification of the player’s identity, monitoring of transactions, screening for sanctions and asset freezing measures, and identification of politically exposed persons (PEP). Compliance with AML-CFT , however, faces challenges…

A wealth management firm has neither a compliance department nor a dedicated compliance unit. Yet it is subject to the same substantive obligations as organizations a hundred times its size. The question, therefore, is not whether the framework applies, but how to scale it so that it fits within the firm’s actual operations…

Are real estate agents subject to anti- AML-CFT obligations? Yes. Real estate agents and property managers have been among the professionals subject to these obligations since Ordinance No. 2009-104 of January 30, 2009. They must identify their clients, collect the information necessary to understand the business relationship, and, when circumstances warrant, conduct more thorough due diligence…

In insurance distribution, the broker manages the initial contact, identifies the policyholder, and collects the necessary documents. The insurer holds the policy and assumes the risk, as well as, if applicable, the suspicious activity report. Between the two, the duty of care AML-CFT is never the sole responsibility of a single party. Each party is accountable to the regulator for its own due diligence. Their division of responsibilities must…

Notaries are among the professionals subject to the national asset freeze regime. The verification process covers the parties to the deed, their representatives, and the legal Beneficial Owners of legal entities. It must be completed at the time the file is opened, during the full identification process, and before the deed is executed. If any discrepancies are detected, a review is required in order to…

A compliance officer generally knows what the regulations AML-CFT require of them. They are less likely to know who will conduct the audit, the scope of the audit, and the level of detail involved. The answer depends on the entity’s status: the same compliance framework is reviewed by the ACPR at an insur , by the AMF at an asset management firm, and so on.

Choosing a sanctions screening solution isn’t just a matter of verifying that a vendor has lists and a matching engine. You need to understand what data is being used, how matches are detected, how many alerts will need to be analyzed, and what evidence can be produced several months later. Compliance teams must also…

Knowing your customer, verifying a business, evaluating a supplier, monitoring transactions: these processes are similar, but they do not address the same needs or, depending on the situation, the same regulatory requirements. KYC, or Know Your Customer, refers to understanding the customer. KYB, or Know Your Business, commonly refers to the processes of understanding and…

Choosing a compliance solution isn't just about the performance of its engine. It also depends on how the solution integrates with the existing information system, the location of the data, the operational workload, and the ability to scale the architecture over time. Three terms often come up when…

The announcement of an audit shifts priorities. The focus is no longer on immediately seeking the ideal long-term solution, but on determining what actually works, what can be demonstrated, and what shortcomings in the system need to be corrected. This is particularly relevant for organizations supervised by the ACPR, the French Prudential Supervision and Resolution Authority, which…

Certified public accountants are among the professionals subject to obligations regarding AML-CFT, and the fight against money laundering and terrorist financing. In a firm, however, these obligations often must be managed without a team dedicated exclusively to compliance. The question is therefore a very practical one: how can a proportionate compliance framework be established…