Financial Crime World

France’s National Money Laundering/Terrorist Financing Risk Assessment

Introduction

France is finalizing its first national money laundering/terrorist financing risk assessment (NRA), a comprehensive study coordinated by the Anti-Money Laundering and Terrorist Financing Steering Committee (COLB) with input from various stakeholders, including the private sector.

Risk Assessment and Identification of Risks

The NRA highlights the significant threat of terrorist financing in France, which is considered high by authorities. Preliminary findings indicate that terrorist activities are often facilitated through:

  • Microfinance
  • Associations
  • Networks of funds collectors
  • Non-bank payment service providers
  • Electronic money (e-money)

In addition to terrorist financing risks, the NRA identifies main money laundering threats from:

  • Drug trafficking
  • Large-scale financial fraud
  • Tax and corporate fraud
  • Offenses involving breach of integrity (such as corruption)

Risk-Based Preventive Measures

To address these risks, France has updated its legal framework to transpose the Fourth European Anti-Money Laundering Directive (AMLD). Reporting entities are required to:

  • Identify and assess their money laundering/terrorist financing risks
  • Apply enhanced controls when risks are higher
  • When dealing with Politically Exposed Persons (PEPs), including beneficial owners, ensure that business relationships are approved by a member of the entity’s executive body or an individual authorized by it. Obtain information on the origin of assets and funds.

Transparency of Beneficial Ownership

France has established a central register of beneficial owners (BOs) in accordance with Article 30 of the Fourth European AMLD. The BO register is accessible to:

  • Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) obliged professionals
  • Regulatory authorities
  • Other competent authorities, in line with international standards

Measures are underway to strengthen existing BO registers, including an obligation for BOs to provide all necessary information to companies required to obtain and maintain such information.