Tougher regulations, stiffer penalties, maximum vigilance. Reporting suspicions is becoming a major lever in the fight against money laundering. But in practice? Errors persist. And they are costly.
MiCA, DORA, AML-CFT... In 2025, regulations are changing dimension. For you, professionals subject to AML-CFT, the Tracfin declaration is no longer a simple administrative reflex: it is a structuring act, which engages the responsibility of the company.
And given the complexity of procedures, traceability requirements and regulators' expectations... it's hard to improvise! That's where digital solutions come in, capable of structuring, historizing and automating every step of the process. AP Solutions IO is one of the players rethinking compliance in the digital age, to avoid errors before they become mistakes.
Legal framework: what every professional needs to know
Reporting suspicions is not a matter of personal intuition. It is a strict obligation, governed by AML-CFT regulations. As soon as you have serious doubts about a transaction or a customer, you are obliged to act, without delay.
This requirement concerns a wide range of players:
- Financial institutions
- Digital asset service providers (DASPs)
- Regulated legal professions (notaries, lawyers, court-appointed agents or administrators)
- Real estate players (real estate agents/intermediaries, property managers)
- Gaming operators (casino, online gaming, betting and games of chance)
- Accounting professions (chartered accountants, statutory auditors)
Unless duly justified, the report must be submitted before the suspicious transaction is carried out. In all cases, it must be substantiated by precise facts, supported by concrete evidence, and transmitted via theERMES platform.
This secure portal is the only official channel recognized by Tracfin. It allows you to generate, sign and time-stamp each declaration, with specific forms according to your profession. Any omission or delay exposes you to the risk of sanction during an inspection by one or more of the following bodies: ACPR, AMF, DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes), or other regulators specific to your activity.
The solutions offered by AP Solutions IO facilitate this procedure by automating the collection, analysis and documentation of suspicions, in full compliance with legal obligations.
The 5 most common mistakes to avoid
Do you manage compliance? Then these common mistakes can ruin your system. Let's find out how to avoid them!
1. Late declaration
As soon as a suspicion arises (dubious behavior, unusual flow, obvious inconsistency), the report must be sent without delay. There's no need to wait for a complete file: the report must precede the suspicious transaction, unless justified otherwise.
Many make the mistake of wanting to check everything before acting. The result: out-of-time reporting and possible sanctions by the ACPR and/or AMF.
A partial but reasoned response is always better than a prolonged silence. Anticipation is proof of vigilance. Adopt this reflex now to avoid any risk in the event of an inspection.
2. Incomplete declaration
A report without customer identity, without a clear analysis of the suspicion, or without supporting documents, can be simply dismissed. However, in the event of an audit, the inadmissibility of a report directly exposes you.
Omissions are often due to misuse of the form. Each profession (notaries, PSANs, insurers, etc.) has its own templates.
Use them systematically. They guide data entry, structure analysis and remind you of mandatory elements.
By filling in each field, you'll ensure that your approach is easy to understand... and that the authorities recognize your vigilance!
3. No update
A Tracfin declaration is never static. Any new element, however minor, must be transmitted immediately. Withholding information exposes you to sanctions, perceived as wilful default. Ongoing transparency is a legal obligation, not an option.
4. Incorrect qualification of suspicion
A credible suspicion is based on concrete evidence. Confusing intuition with verifiable facts often leads to rejection of the report. Distinguish between the subjective and the objective, and base each report on precise, quantified and verifiable data.
5. Lack of internal traceability
Without a register or documented procedure, it's difficult to justify your decisions to the various regulators and supervisors. Every action must be recorded, formalized and archived. Solutions such as those offered by AP Solutions IO can automate this traceability, without weighing down your processes or mobilizing your teams unnecessarily.
Reporting entities, PSAN: best practices to adopt
Avoiding errors is no longer enough: to remain compliant, players subject to AML-CFT obligations, as well as PSANs, need to structure, train... and automate intelligently.
Clear internal procedures
Formalizing reporting processes is essential. Who triggers an alert? How is it analyzed? Who decides whether an alert should be forwarded to Tracfin? Each step must be described, recorded and shared. Without precise documentation, it becomes difficult to justify one's choices in the event of an audit.
Ongoing, targeted training
Well-trained employees are more likely to spot anomalies, fill in declarations correctly and better understand the nuance between subjective and objective suspicion. In 2025, training can no longer be a one-off event: it must be part of a regular cycle, updated in line with regulatory developments.
A RegTech solution for automation and reliability
The tools developed by AP Solutions IO integrate directly into your workflows. Their objective? To help you gain in rigor, time and security.
- Centralize alerts: weak signals captured automatically, scoring tailored to your sector
- Document suspicions: every action is logged - from alert to decision
- Generate ready-to-send Tracfin reports: conform to expected format, exportable directly to ERMES
This technological integration reduces human error, improves traceability and secures your compliance, without adding to your day-to-day operations.
Anticipate, equip, secure
Tracfin reporting is not just a regulatory obligation. It is a strategic component of the AML-CFT system. Poorly managed, it can undermine your compliance. But structured, equipped and properly integrated, it becomes a lever of control, a marker of rigor.
Faced with a growing arsenal of European regulations, PSANs and regulated players have no choice but to industrialize their practices. Centralize alerts, document suspicions, trace every decision.
This is precisely where the solutions developed by AP Solutions IO come in. They don't just digitize obligations: they translate them into concrete actions, adapted to each sector and fully integrated into business workflows.
Do you need to strengthen your reporting process without complicating your operations?
Discover AP Solutions IO solutions and move from reactive management to controlled, scalable, solid compliance!
