Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Measures in France
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Risk Assessment
France has a robust risk assessment process that includes regular reporting from TRACFIN and SIRASCO. However, there are areas for improvement.
Key Findings:
- Regular Reporting: TRACFIN and SIRASCO provide regular reports on risks.
- Common Understanding of Risks: Competent authorities share a common understanding of risks.
- Development Needed: DNFBP supervisory authorities require further development.
- Deeper Assessment Required: Certain sectors (real estate, virtual assets, cash) and threats (corruption) need deeper assessment.
National Policies
France has implemented national policies to combat money laundering and terrorist financing. However, there are areas for improvement.
Key Findings:
- Thematic Action Plans: Thematic action plans are used to implement national policies.
- Prioritization of CFT Issues: France prioritizes CFT issues in its national policies.
- Resource Allocation: Law enforcement policies reflect identified risks, but resource allocation for ML investigations is necessary.
- Supervisory Authorities: Financial sector supervisors consider ML/TF risks, while DNFBP supervisory authorities require further development.
Cooperation and Coordination
Cooperation and coordination are essential in combating money laundering and terrorist financing. France has made progress in this area.
Key Findings:
- COLB: The COLB ensures effective cooperation and coordination at the national level.
- Bilateral Cooperation: Authorities cooperate bilaterally, but cooperation between DNFBP sector supervisors needs improvement.
Financial Intelligence
Financial intelligence is crucial in combating money laundering and terrorist financing. France has made progress in this area.
Key Findings:
- TRACFIN: TRACFIN plays a key role in enriching financial intelligence through various sources of information.
- Exploitation of Information: Not all available information is optimally exploited, with opportunities for further dissemination.
- High-Quality Analyses: High-quality operational analyses are produced by TRACFIN, while strategic analyses (typologies) help improve risk understanding.
Investigation and Prosecution
Investigation and prosecution are critical in combating money laundering and terrorist financing. France has made progress in this area.
Key Findings:
- Identification of ML Cases: France identifies ML cases to a certain extent but actively investigates complex and highly complex cases.
- Prioritization of High-End ML Cases: Authorities favor a “top-down” approach in prioritizing high-end ML cases.
- Consistency with Risk Profile: ML investigations and prosecutions are largely consistent with the identified risk profile, but corruption and human trafficking cases are underreported.
Sanctions
Sanctions imposed on individuals or entities convicted of money laundering or terrorist financing are generally effective, proportionate, and dissuasive.
Key Findings:
- Effectiveness of Sanctions: Sanctions imposed are generally effective.
- Proportionality and Dissuasiveness: Sanctions are proportionate and dissuasive.
Overall, France has made significant progress in implementing AML/CTF measures, but there are areas for improvement, particularly in DNFBP supervisory authorities and resource allocation for ML investigations.