The PSAN (digital asset service provider) status, established under the Pacte Act, has been replaced by the PSCA (crypto-asset service provider) status, as provided for by the European MiCA regulation. The transition period ended in July 2026: MiCA authorization is required to operate. The obligations…

The Tracfin reporter is the person responsible for submitting suspicious activity reports to the agency. The Tracfin liaison serves as the point of contact with the reporter: he or she receives acknowledgments of receipt and processes the reporter’s requests. Professionals subject to anti-money laundering regulations specifically designate the individuals who perform these two functions at Tracfin and…

For a professional subject to anti-money laundering and counter-terrorism financing regulations (AML-CFT), a regulatory compliance solution encompasses know-your-customer procedures, screening, risk scoring, transaction monitoring, and transaction filtering. It is judged by the evidence it produces during an audit. Each alert,…

The identification of politically exposed persons ( PEP , or “PEPs”) relies on screening clients and their Beneficial Owners at the outset of the business relationship and throughout its duration. The compliance team must be able to independently set the scope, the threshold for name matching, and the handling of alerts, while maintaining…

A customer risk score is transparent when each score can be broken down to determine which factors were considered, with what weighting, based on what data, and on what date. It is auditable if this breakdown, successive versions of the model, and analysts’ decisions are retained and available for review. In AML-CFT, this score…

In transaction monitoring, false positives are reduced by adjusting the scenarios rather than by raising the thresholds across the board. Segment the customer base by risk profile, tailor each scenario to the segment’s expected behavior, prioritize alerts, and track the percentage of alerts that lead to a deeper analysis or to…

Changing data providers PEP and penalties involves three decisions. The first concerns the scope: data alone, the screening engine, or both. The second concerns the criteria: coverage and recency of the lists, false positives, integration, hosting, and support. The third outlines the migration process: transfer of…

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 that measure stems from a decision by the United Nations, the European Union, or France. It…

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…