France: FATF's Latest Recommendations

FATF's 2022 mutual evaluation rated France one of its better-performing members: 19 of the 40 Recommendations compliant, 18 largely compliant, and three of eleven immediate outcomes highly effective. The two weak spots were preventive measures and supervision, both rated only moderately effective, driven by the non-financial sector.

Key takeaways

• France's technical compliance improved sharply between evaluations, from 5 compliant ratings in 2011 to 19 in 2022, with the one non-compliant rating (Recommendation 24, on non-financial businesses and professions) lifted to largely compliant.
• The two moderate effectiveness ratings both concern the private-sector control layer rather than law enforcement, so FATF's recommendations land on obliged entities and their supervisors, not on prosecutors.
• Suspicious transaction reports to TRACFIN grew more than sixfold between 2012 and 2021, peaking at 161,000, while only 12 of the 1,227 money-laundering convictions handed down in 2020 involved a legal person.
• France applies a EUR 1,000 cash payment ceiling, well below the EUR 10,000 EU-wide ceiling arriving with the 2024 AML package, and brings estate agents and traders into scope only above EUR 10,000.
• ACPR fines for AML and asset-freezing failures since 2024 range from EUR 250,000 to EUR 2.5 million, and the recurring grievances are risk classification, suspicious-transaction reporting and freeze screening.

What did FATF's 2022 mutual evaluation actually rate France on?

Two separate scorecards, and conflating them is where most commentary on this report goes wrong. Technical compliance rates whether the law and institutional framework match each of the 40 Recommendations. Effectiveness rates outcomes against eleven immediate outcomes, from risk understanding through to targeted financial sanctions.

France was assessed between 2020 and 2022, ten years after its previous evaluation, with the report published in May 2022 (FATF). On technical compliance it moved from 5 compliant, 23 largely compliant, 9 partially compliant and 1 non-compliant in 2011 to 19 compliant, 18 largely compliant and 3 partially compliant.

On effectiveness, three immediate outcomes were rated high, six substantial and two moderate, per the Cour des comptes review of the French AML regime. Read the two scorecards together and the pattern is clear: France's statute book is in good order, and the residual risk is in execution by supervised firms.

How do France's ratings compare with other large FATF members?

Comparison matters here because absolute ratings mean little without a peer baseline. A "moderate" is common; a "high" is rare. France's three high ratings put it near the top of recent assessments of major economies, which is the substance behind FATF's language about a robust and sophisticated framework.

The following comparison is drawn from the Cour des comptes analysis of the same FATF evaluation round.

Germany, assessed in the same year with a comparable financial sector, took seven moderate ratings. The United States collected the only low rating in the group, on beneficial ownership identification. Nothing in FATF's assessment history put France at risk of the grey list, although a 2018 mission preparing the evaluation did flag increased monitoring as a live risk if reforms stalled.

Which two areas did FATF rate only moderately effective?

Preventive measures and supervision. Both sit in the private-sector control layer, and both were dragged down by the same thing: designated non-financial businesses and professions.

FATF found risk-based AML supervision immature outside banking and insurance, with the ACPR the explicit exception for having built a robust methodology. Real estate drew specific criticism as a sector carrying significant risk without supervision to match. On the sectoral risk assessments that are supposed to drive that supervision, FATF welcomed the involvement of obliged professions but criticised uneven quality and thin granularity for notaries, estate agents, company formation agents and accountants.

The evaluators concluded that significant resources still had to be deployed to assess and mitigate risk properly in the non-financial sector and to develop risk-based supervisory strategies. Beneficial ownership was the other named gap: identification efforts were rated notable, but verification of the register needed strengthening through better feedback from authorities and obliged entities on discrepancies found. Our note on FATF mutual evaluations and what they mean for financial institutions sets out how these ratings translate into supervisory pressure.

Who supervises and sanctions AML compliance in France?

France splits AML supervision by sector rather than running a single supervisor, and the split explains the ratings above. The ACPR supervises banking and insurance, carries out off-site and on-site inspections, and also gives an opinion on crypto-asset providers before the AMF authorises them (ACPR).

Coordination runs through the Conseil d'orientation de la lutte contre le blanchiment de capitaux et du financement du terrorisme (COLB), which brings together 16 State services, 15 supervisory and sanctioning authorities and two independent authorities. Sanctioning power for the non-financial professions sits with the Commission nationale des sanctions, on referral from the relevant supervisor.

That referral pipeline is where the moderate supervision rating becomes concrete. Since its creation in 2014, the Commission had never received a case concerning precious stones and metals dealers, art and antiquities dealers, or sports agents; the first luxury goods case reached it on 24 October 2022, referred by the DGCCRF. Inside the financial sector the picture is different: the ACPR's own Sanctions Committee is a standing adjudicator whose rulings are appealable to the Conseil d'Etat (ACPR).

What does TRACFIN do with the reports it receives?

TRACFIN is France's financial intelligence unit and sits under the authority of the Ministry for the Economy, Finance and Industrial and Digital Sovereignty, a point worth correcting in any internal policy still citing the Ministry of Economy, Finance and Recovery. FATF rated its role central and credited its outreach to obliged entities.

Volume is the operational story. Suspicious transaction reports grew more than sixfold between 2012 and 2021, peaking at 161,000, with payment institutions the second largest contributor at 68,500 in 2021 and the non-financial sector rising from under 2,000 to over 7,000. Systematic reporting on funds transmission climbed from 2,538,092 filings in 2014 to 3,644,093 in 2021.

The Cour des comptes was blunt that rising volume is not the same as rising effectiveness: report quality remains uneven, and the combined inflow makes triage harder. For a compliance team, that is an argument for tuning transaction monitoring thresholds against typologies rather than filing defensively.

Why do French money-laundering convictions lag the underlying offences?

Because the offence is under-charged, not because the law is narrow. France criminalised self-laundering, introduced a laundering presumption in 2013 that relieves prosecutors of proving the predicate offence in defined circumstances, and made laundering an autonomous offence in 2012 so it survives limitation of the predicate.

The numbers show the gap anyway. Against 105,099 convictions in 2020 for the predicate offences identified in the national risk assessment, excluding laundering itself, only 12 of 1,227 money-laundering convictions that year involved a legal person, down from 38 of 1,543 in 2019. Money-laundering charges were dropped far less often than the predicates (8% in 2020 against 58% for tax, social security and customs fraud), which suggests the constraint is upstream, at charging.

FATF also identified a shortage of specialised investigators as a limit on enforcement, lengthening complex investigations. Confiscation is the counterweight and a genuine strength, driven by AGRASC, the agency managing seized and confiscated assets, created in 2010.

Which French thresholds differ from the EU baseline?

France runs tighter cash rules than the EU floor and applies entry thresholds that decide whether a non-financial business is in scope at all. Both matter when configuring onboarding rules for a French entity inside a group programme.

Scope itself is unstable. Article L.561-2 of the Code monétaire et financier, which lists obliged entities, was amended 26 times between 1 January 2009 and 26 February 2022. Separately, France operates a national asset-freezing regime under Articles L.562-1 and following, where the economy and interior ministers freeze funds jointly for renewable six-month periods, published in the Journal Officiel (Direction générale du Trésor). Those designations sit in the registre national des gels and must be screened alongside EU and UN lists, which is why PEP and sanctions screening for a French entity cannot rely on EU consolidated data alone.

What has changed since the evaluation?

Three things, and all of them bear on the gaps FATF named. Public access to beneficial ownership registers was struck down by the Court of Justice of the European Union on 22 November 2022 in joined cases C-37/20 and C-601/20, so the register FATF wanted better verified is now accessible on a legitimate-interest basis rather than to anyone (CJEU).

Virtual assets moved from a French regime to a European one. MiCA applied to crypto-asset service providers from 30 December 2024, and the transitional period for providers registered under the Pacte law ran to 1 July 2026. France has authorised 31 providers of the 283 authorised across the EU, making it the second most common location for authorised providers (AMF).

The EU AML package is the larger shift, replacing directive-based national variation with directly applicable rules from 2027 (European Commission), while AMLA in Frankfurt begins direct supervision of selected significant cross-border institutions from 2028 (AMLA). See our explainers on the 6th EU Anti-Money Laundering Directive and preventing misuse of legal persons.

What are French supervisors actually penalising?

ACPR decisions are the best available read on what a French examiner tests, because each published decision names the grievances upheld. The recent AML and asset-freezing decisions are consistent: risk classification under Article L.561-4-1 of the Code monétaire et financier, suspicious-transaction reporting, and freeze screening under the ministerial order of 6 January 2021.

Two patterns are worth acting on. Penalties are modest by US standards but always published by name, in the recent decisions for five years, so the reputational cost dominates the financial one. Asset freezing also appears as a standalone grievance rather than folded into AML, which means freeze screening needs its own evidence trail.

The full register sits in the ACPR's recueil des sanctions. For the regulator-level snapshot see our France coverage page, the glossary of AML terms and further jurisdictions and regulation analysis.