On 29th October, the IMF published this Technical Note which summarises the findings of a targeted review of France’s AML/CFT framework with respect to measures to prevent and combat terrorist financing, risk-based supervision of banks, real estate agents, company service providers and lawyers, measures to tackle cross-border crimes, and fintech.  It provides a factual update on the key measures taken by the authorities since France’s previous assessment against the FATF standard during 2010-2011.  However, it is stressed that the Technical Note is not, in any way, an evaluation or assessment of France’s AML/CFT system.  France is scheduled to undergo a comprehensive assessment against the prevailing standard during 2020–2021 by FATF.

The Note says that, since the last review, France has made significant progress in aligning its AML/CFT framework with the revised FATF standard and the EU AML Directives.  Its first national money laundering and terrorist financing risks assessment is being finalised.  The French legal framework has been updated to transpose the 4th and 5th EU AML Laundering Directives, including risk-based preventive measures and PEP and transparency of beneficial ownership. France has also taken steps to strengthen the AML/CFT measures in its overseas territories.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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