The Autorité des Marchés Financiers publishes a summary of its anti-money laundering and combating the financing of terrorism inspections

What Changed

• - The AMF has formalised and publicly communicated its enforcement findings and expectations on AML/CFT and AEI, turning past inspection outcomes into forward‑looking supervisory benchmarks for 2026 and beyond.
• AML/CFT frameworks must move from generic and incomplete documentation to precise, activity‑specific procedures that clearly reflect the firm’s business model, products, distribution channels and client typologies.
• AML/CFT risk mapping must be personalised, complete, and demonstrably linked to the level and type of customer due diligence and ongoing monitoring applied; purely theoretical or non‑operational risk maps are treated as deficiencies.
• Firms must implement robust oversight and documented supervision of delegates, distributors, service providers and other third parties involved in KYC or onboarding, rather than relying on unverified third‑party processes.
• Client, beneficial owner and source‑of‑funds information must be systematically collected, stored, updated and traceable, including clear identification and ongoing review of politically exposed persons (PEPs).
• Due diligence must be applied not only at client onboarding but also to investment and divestment transactions involving fund assets, with documented analyses of unusual or higher‑risk transactions.

Suggested Considerations

• Review and comprehensively update AML/CFT written policies and procedures to ensure they are complete, precise and clearly adapted to the firm’s specific activities, products, distribution channels and client profiles.
• Redesign AML/CFT risk mapping to be firm‑specific, cover all relevant money laundering and terrorist financing risks, and explicitly link identified risks to the intensity of customer due diligence and transaction monitoring measures applied.
• Implement a formalised framework for the oversight of delegates, distributors, service providers and other third parties performing KYC or onboarding tasks, including documented due diligence, contractual obligations, and periodic testing of their AML/CFT controls.
• Conduct a gap analysis of client and beneficial owner data collection, storage and updating processes to ensure full traceability of KYC information, including clear documentation of PEP identification and periodic review.
• Enhance due diligence procedures for investment and divestment operations involving fund assets, including documented risk assessments and escalation paths for unusual or higher‑risk transactions.
• Review and strengthen suspicious activity reporting processes to TRACFIN and required notifications to the AMF, ensuring that atypical transactions are detected by monitoring systems, analysed by qualified staff and, where appropriate, reported within required timelines.

Key Dates

Who is Affected