France's anti-money laundering regime tightened substantially at the start of 2025. Companies that assumed their existing compliance procedures remained adequate are now exposed to material regulatory risk – and the window for remediation is short.
French anti-money laundering law, aligned with the EU's successive AML directives and administered primarily by the Autorité de contrôle prudentiel et de résolution (ACPR. The Prudential Supervision and Resolution Authority) and Tracfin (the financial intelligence unit), requires all obliged entities to maintain continuous Know Your Customer (KYC) processes, identify beneficial owners, and file suspicious transaction reports. The 2025 updates extend these obligations to additional business categories, raise due diligence thresholds, and impose tighter timelines for beneficial owner registration. Non-compliant entities risk significant administrative sanctions and, in serious cases, criminal referrals under French financial legislation.
This alert summarises the key regulatory developments, identifies which companies are affected, and sets out the immediate steps required to achieve compliance.
What changed and when
France transposed the latest EU AML package through amendments to its financial and commercial legislation, effective from 1 January 2025. The changes affect three principal areas.
First, the scope of obliged entities expanded. Certain categories of high-value goods dealers, virtual asset service providers, and intermediaries previously operating outside the formal AML regime are now fully within it. Any entity that was not an obliged entity before 2025 but now meets the revised criteria must have its compliance programme operational. The grace period for onboarding the new requirements ended on 31 March 2025.
Second, beneficial owner disclosure requirements under French commercial legislation – the Code de commerce – became more demanding. The definition of beneficial owner was tightened, lowering the control threshold at which individuals must be declared. Intermediate holding structures, including those using a société à responsabilité limitée (SARL) or société par actions simplifiée (SAS), must now trace ownership to the ultimate natural person beneficiary with greater precision. Filings with the Registre des bénéficiaires effectifs (beneficial owner register) must be updated within thirty days of any change to the ownership or control structure.
Third, enhanced due diligence requirements now apply to correspondent banking and cross-border credit facility arrangements. French credit institutions conducting correspondent banking relationships with non-EU counterparties must complete refreshed risk assessments and document the rationale for continuing each relationship. Institutions that fail to re-document existing arrangements by 30 June 2025 face supervisory review by the ACPR.
The Cour de cassation (Supreme Court of France) has, in a line of recent decisions, affirmed that individual directors and compliance officers carry personal exposure when an entity's AML deficiencies result in financial crime facilitation. This judicial position reinforces the legislative changes and heightens the personal dimension of non-compliance.
Who is affected and what the thresholds are
The 2025 updates affect a broad range of entities operating in France, including branches and subsidiaries of foreign groups. The principal categories are:
- Credit institutions and payment service providers subject to ACPR supervision
- Virtual asset service providers registered with the Autorité des marchés financiers (AMF, Financial Markets Authority)
- High-value goods dealers whose individual or linked transactions meet or exceed the revised cash transaction threshold
- Notaries, auditors, and certain legal professionals handling real estate or corporate transactions
- Corporate service providers, including registered agents and company formation intermediaries
International companies with a French subsidiary, branch, or permanent establishment are treated as obliged entities in their own right. The compliance obligation sits with the French entity – not only with the parent group. A foreign parent's group-level AML policy does not automatically satisfy French regulatory requirements unless it has been formally adopted and localised.
The bank account opening process in France now requires enhanced KYC documentation for non-resident directors and for entities with complex ownership chains. French banks are applying stricter onboarding standards, and account opening delays of several weeks are common where the beneficial owner declaration is incomplete or inconsistent with the commercial register.
For a detailed analysis of the banking obligations applicable to companies established in France, see our overview of banking and finance law in France.
To receive an expert assessment of your company's AML exposure in France, contact us at info@ferrazwhitmore.com.
Immediate action items for international companies
Five steps require attention before the relevant deadlines pass.
1. Audit your beneficial owner register filing. Confirm that the French beneficial owner register reflects the current, post-threshold ownership structure. If any intermediate holding entity or trust sits in the chain, legal counsel should assess whether re-filing is required. A huissier de justice (court-appointed enforcement officer) acting for a regulatory authority can formally serve notice of a filing deficiency – at which point rectification timelines become mandatory rather than discretionary.
2. Localise your group AML policy. A group-level policy drafted for another jurisdiction does not satisfy French AML obligations. The French entity needs a standalone procedure document referencing the applicable French legislation, naming the local compliance officer, and describing the specific customer categories and risk indicators relevant to its business.
3. Refresh KYC files for existing clients and counterparties. French financial legislation requires periodic review of KYC documentation. Given the new threshold and scope changes, any file last updated before 2024 should be treated as a priority for refresh. Entities in the correspondent banking and capital markets space should apply particular attention here – our analysis of capital markets regulation in France addresses the interaction between AML obligations and securities transaction reporting.
4. Train your compliance team on the 2025 changes. Training records are auditable by the ACPR. Demonstrating that staff responsible for client onboarding and transaction monitoring have received updated instruction is a basic element of a defensible compliance posture.
5. Review correspondent banking and credit facility documentation. Any cross-border credit facility or correspondent banking arrangement involving a non-EU counterparty must be backed by a refreshed risk assessment filed internally by 30 June 2025. Absent this documentation, the arrangement itself becomes a supervisory risk.
Companies facing parallel obligations in other jurisdictions may find it useful to compare the French regime with the approach taken in neighbouring countries. The alert on AML updates in Portugal sets out a comparable analysis for that market.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. As an international law firm with a dedicated France practice, we assist companies in meeting their AML and KYC obligations, establishing compliant corporate structures, and engaging with French regulators including the ACPR and AMF. Our team combines Portuguese civil law expertise with English common law tradition, which is particularly valuable for groups managing compliance across multiple EU jurisdictions simultaneously. We have advised on beneficial owner registration, correspondent banking due diligence, and cross-border credit facility structuring for clients operating in both civil law and common law systems. Engaging a lawyer in France with cross-border regulatory experience is often the most efficient way to close compliance gaps before a supervisory review begins. To discuss your company's AML obligations in France, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.