The PSAN (digital asset service provider) status, established under the Pacte Act, has been replaced by the PSCA (crypto-asset service provider) status, as provided for by the European MiCA regulation.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: a MiCA license is required to operate. AML-CFT ’s obligations remain in effect: customer due diligence, transaction monitoring, asset freezing, and reporting suspicious activity to Tracfin.
Table of Contents:
- PSAN and PSCA: What Do These Two Statuses Mean?
- What has become of PSAN status since the end of the transition period?
- What requirements AML-CFT apply to a PSCA under MiCA?
- What does the travel rule require regarding crypto-asset transfers?
- Crypto-assets and Tracfin: When Should You Report a Suspicion?
- Who oversees the operations AML-CFT of a crypto-asset service provider?
- How should you prepare your AML-CFT device for an inspection?
- FAQ
The PSAN acronym remains the most sought-after, but it refers to a status that is no longer in effect. For a crypto-asset service provider, registration falls under the previous regulatory framework. Going forward, the challenge is to maintain—under European authorization— AML-CFT s capable of withstanding an audit, particularly with regard to due diligence, monitoring, and reporting.
PSAN and PSCA: What Do These Two Statuses Mean?
The acronym PSAN referred to a digital asset service provider, a legal status created by the Pacte Act. The PSCA, or crypto-asset service provider, is the legal status established by the European MiCA Regulation (Regulation (EU) 2023/1114 of May 31, 2023). The transition from one regulatory framework to the other is in line with European harmonization.
| Point of comparison | PSAN (French system) | PSCA (MiCA Regulation) |
| Meaning of the acronym | Digital Asset Service Provider | Crypto-asset service provider |
| Original text | Pacte Act (Act No. 2019-486 of May 22, 2019) | Regulation (EU) 2023/1114 of May 31, 2023 |
| Access to the Activity | Registration or certification, depending on the department | PSCA Certification |
| Scope | France | European Union |
| Current Situation | Plan terminated as of June 30, 2026 | Required Status to Provide Services Related to Crypto-Assets |
| AML-CFT | Taxable Service Provider | Taxable service provider; Regulation (EU) 2023/1113 of May 31, 2023, on transfers |
What has become of PSAN status since the end of the transition period?
The MiCA Regulation has applied to service providers since December 30, 2024. France had established a transition period: entities registered or authorized under the Pacte Act were allowed to continue their operations until June 30, 2026.
In its press release dated July 6, 2026,the French Financial Markets Authority (AMF) confirmed that this period had ended.Market participants without PSCA authorization must wind down their operations in an orderly manner. The PSAN regime is now a thing of the past.
What “ AML-CFT ” obligations apply to a PSCA under MiCA?
A PSCA is a professional subject to anti-money laundering and counter-terrorism financing regulations. The anticipated “ AML-CFT ” framework is based on six obligations:
| Obligation | What She's Asking For | Assignment to Prepare |
| Risk Classification | Assess the risk associated with customers, services, channels, and countries | Current classification, dated |
| Customer Identification | Know the customer and its beneficial owner | Complete Client File |
| Screening of sanctions and PEP | Compare clients and beneficiaries against the lists | Screening History, Reasoned Decisions |
| Transaction Monitoring | Detect unusual transactions | Current scenarios, alerts handled |
| Report of a Suspicion | Report Suspicious Transactions to Tracfin | Escalation Procedure, Designation of the Reporter |
| Internal control | Check the device and keep the parts | Results of the inspections, audit trail |
Understand the customer and assess the risk
Before opening an account, the service provider identifies the customer, verifies their identity, determines their beneficial owner, and classifies their risk level. This classification is based on the nature of the customer, the service requested, the channel, and the countries involved. A high-risk customer is subject to enhanced due diligence measures. The classification must be updated whenever the customer’s situation changes and in accordance with the frequency specified in your procedures.
Asset Freezes and Restrictive Measures
Screening involves cross-referencing each customer and beneficial owner against international asset freeze and sanctions lists. Any alert must be addressed immediately: analyze the information, compare it against the criteria, justify your decision, and maintain a record of it. In the event of a confirmed match, immediately freeze the assets and report the action to the Directorate General of the Treasury. AP Scan automates the screening process and maintains an audit trail for each alert.
What does the travel rule require regarding crypto-asset transfers?
Regulation (EU) 2023/1113 of May 31, 2023, extends the “travel rule” to crypto-assets: every transfer must be accompanied by information on the originator and the recipient. The service provider executing the transfer must transmit this information to the recipient’s service provider. The required information includes, in particular, the name of the originator and the recipient, as well as their address on the distributed ledger or their crypto-asset account number.
When the recipient uses a self-hosted email address, the sending service provider verifies that the address belongs to the customer and retains proof of this verification. A transfer with missing information is handled according to the established procedure: suspension, request for information, or rejection.
Crypto-assets and Tracfin: When Should You Report a Suspicion?
The transaction monitoring helps detect atypical transactions: unusual amounts, high-risk destinations, splitting of transactions, or transactions without justification. Each alert must be analyzed in light of the customer’s file. If the analysis raises suspicion of money laundering or terrorist financing, the service provider must report the transaction to Tracfin.
Suspicion does not require certainty. It is sufficient that objective evidence leads to the conclusion that the transaction may be linked to a crime. The report is submitted by the designated reporter via the Ermes portal as soon as possible. AP Monitoring continuously monitors transactions, prioritizes alerts, and links each transaction to the customer’s profile.
Who oversees a crypto-asset provider’s “ AML-CFT ” system?
In its press release dated July 6, 2026, the French Financial Markets Authority (AMF) states that it oversees compliance by PSCA entities with their professional obligations. Oversight of the “ AML-CFT ” program falls under the jurisdiction of the authorities responsible for combating money laundering and terrorist financing.
In practice, the auditor verifies that the service provider has categorized its risks, identifies and screens its customers, monitors transactions, reports suspicious activity, and retains evidence. Prepare your system by compiling all the elements that make up the audit trail. To identify the competent authority, check which agency oversees your system AML-CFT based on your profession.
How should you prepare your AML-CFT device for an inspection?
The transition from PSAN to PSCA status does not exempt you from any obligations AML-CFT. Follow these steps:
- Review your risk classification and verify that it includes the services provided under the PSCA certification;
- Update your written procedures, replace all references to the PSAN program with the PSCA status, and date each version;
- Test your screening tool on a sample of customers;
- Monitor transaction oversight by reviewing current scenarios;
- Train teams on travel policies, self-hosted addresses, and the criteria for reporting suspected cases ;
- Gather the evidence, including the audit trail for the screenings, the record of reports, and the names of the reporter and the Tracfin liaison.
Start by reviewing your procedures and replacing any references to the PSAN program.
FAQ
What is the difference between a PSAN and a PSCA?
The PSAN, a digital asset service provider, was a French legal status created by the Pacte Act. The PSCA, a crypto-asset service provider, is the legal status established by the European MiCA Regulation, which applies throughout the European Union. The latter replaced the former following a transition period that ended on June 30, 2026. Both are subject to anti-money laundering and counter-terrorism financing regulations.
Can a PSAN-registered service provider still operate without PSCA certification?
No. The transition period ended on June 30, 2026: authorization under the MiCA Regulation is now required to provide crypto-asset services. The AMF has indicated that it is monitoring the orderly cessation of operations by entities that have not obtained such authorization. Check a service provider’s status on the lists published by the authority before doing business with them.
Is a blockchain analysis tool enough to know your customer?
No. Analyzing transactions on the blockchain provides information about transaction flows and addresses, but not about the customer’s identity, the source of their funds, or their risk profile. It complements due diligence measures without replacing identification, identity verification, sanctions and “ PEP ” screening, or risk classification. Link the two systems so that a transaction alert can be analyzed in light of the customer’s file.
Is a PSCA required to designate a reporting officer and a Tracfin liaison?
Yes, just like other professionals subject to the “ AML-CFT.” The reporting officer submits suspicious activity reports, while the liaison officer serves as the point of contact with Tracfin and handles its requests. Both are designated by name to Tracfin and the supervisory authority, but the same person may hold both positions. Update the designation whenever there is a change in the person holding the position.
Does the asset freeze also apply to crypto-assets?
Yes. A crypto-asset service provider implements asset freezing measures and other restrictive measures, just like other regulated professionals. In practice, screen customers and their Beneficial Owners when establishing a business relationship, and then whenever the lists are updated. Also monitor transfers and document how each alert is handled.
