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Crypto ATM / kiosk operator in France

Physical kiosks that exchange cash for crypto (and sometimes vice versa). High-cash AML risk profile.

Conditional AI-Generated · Unreviewed

Crypto ATM is conditionally permitted in France with a local entity, subject to AML obligations and high licensing burden.

Verdict Details

Permitted
conditional
Local entity required
Yes
Licensing burden
High
Last updated
2026-07-13

AML Obligations

  • CASP authorization (MiCA) via AMF — covers custody, exchange, and transfer services; minimum capital of €150,000 for exchange activity applies
  • Mandatory KYC: collect, verify, and store identity documents (two forms of ID required for natural persons)
  • Enhanced Due Diligence (EDD) for high-risk scenarios: PEPs, transactions over €1,000 to self-hosted wallets, and cross-border activities
  • Ongoing transaction monitoring and ML/FT risk assessment systems required
  • KYB for corporate clients including beneficial ownership verification
  • Managers and beneficial owners verified during AMF registration
  • TRACFIN reporting: suspicious transaction reports (STRs) required for AML/CFT
  • FATF Travel Rule compliance under MiCA for transfers of crypto assets
  • DAC8 reporting (effective January 1, 2026): must report user crypto transactions to tax authorities

Key Restrictions

  • Must obtain full CASP authorization from AMF (not mere registration); existing PSAN/DASP regime replaced by MiCA
  • Short transition window — existing PSANs had to apply by June 30, 2025; new entrants must apply under MiCA CASP framework
  • Physical kiosk locations likely trigger ACPR prudential oversight in addition to AMF licensing
  • Minimum capital requirements apply (€125,000–€350,000 for CASP activities; at least €150,000 if exchange services are offered at kiosks)
  • Cash transactions face heightened AML scrutiny — EDD triggered for self-hosted wallet cash-out over €1,000
  • Local entity incorporation required to obtain CASP authorization

Key Risks

  • High-cash AML risk profile of ATM/kiosk operations likely attracts enhanced supervisory attention from both AMF and ACPR
  • Cash transaction reporting thresholds for ATM/kiosk operators not explicitly defined in provided facts — regulatory ambiguity on specific CTR thresholds
  • Short MiCA transition timeline creates risk for operators who delay CASP application
  • Dual supervision (AMF + ACPR) increases compliance burden and potential for conflicting interpretations
  • Reputational and regulatory risk if kiosks are used for self-hosted wallet transactions exceeding €1,000 without proper EDD

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 90% confidence

The AMF is the French competent authority for MiCA CASP authorisation, and France is the second-largest EU home of authorised CASPs (AMF, 6 July 2026). Circle Internet Financial Europe SAS is listed by ESMA as an AMF-authorised CASP from 23 April 2026 and, separately, as an ACPR-supervised e-money institution issuing the EURC and USDC e-money tokens since 1 July 2024.

licensing 92% confidence

The ACPR (Autorité de contrôle prudentiel et de résolution) is the French prudential and AML/CFT supervisor for banks and insurers, applying Monetary and Financial Code articles L. 561-2 ff. and R. 561-1 ff.; under the PACTE regime it gave its AML/CFT opinion on each PSAN before AMF registration.

licensing 20% confidence

MiCA Regulation (EU) (2023) — CASP authorization, comprehensive crypto regulation

licensing 92% confidence

The loi PACTE of 22 May 2019 created the French regime for initial coin offerings and digital-asset service providers (PSAN). The AMF states that this national regime is to disappear under MiCA, and the PSAN transitional period ended on 1 July 2026.

licensing 95% confidence

France applied the full 18-month MiCA transitional period: PSANs registered or licensed under French law could keep serving clients until 1 July 2026. Since 2 July 2026 only crypto-asset service providers (PSCA) authorised under MiCA may provide crypto-asset services in France; the AMF reported 31 French authorisations on 6 July 2026.

licensing 95% confidence

Custody and administration of crypto-assets on behalf of clients is a MiCA Class 2 service requiring minimum capital of €125,000 (Regulation (EU) 2023/1114, Annex IV). In France the AMF authorises CASPs offering it; the ESMA interim register listed 36 AMF-authorised French entries on 14 October 2026.

licensing 95% confidence

Operating a trading platform for crypto-assets is a MiCA Class 3 service requiring minimum capital of €150,000 (Regulation (EU) 2023/1114, Annex IV). In France it requires AMF authorisation as a PSCA, mandatory for all providers since the PSAN transition ended on 1 July 2026.

licensing 90% confidence

The AMF is the French competent authority that authorises and supervises crypto-asset service providers (PSCA) under MiCA, replacing the PSAN registration and licensing regime of the loi PACTE; it also oversees offers of crypto-assets other than asset-referenced and e-money tokens, whose issuers must be authorised by the ACPR.

licensing 92% confidence

The ACPR is the French authority for stablecoin issuers under MiCA: an e-money token issuer must be authorised as a credit institution or electronic money institution and notify the ACPR of its intention to issue and of its white paper. On 14 October 2026 the ESMA register listed 8 French EMT white papers from 6 ACPR-supervised issuers, including Circle Internet Financial Europe SAS, Société Générale – Forge and SALVUS (schuman.io).

licensing 88% confidence

Tracfin, the French financial intelligence unit under the Ministry of the Economy, receives AML/CFT suspicious-transaction declarations; the ACPR and Tracfin have issued joint guidelines on vigilance obligations and on declarations and information to Tracfin.

licensing 92% confidence

France has replaced the PSAN regime with MiCA authorisation: the AMF stated on 6 July 2026 that the transition from the loi PACTE regime ended on 2 July 2026, that France had authorised 31 crypto-asset service providers and that 283 were authorised across the EU. The ESMA interim register listed 36 AMF-authorised French entries on 14 October 2026.

licensing 0% confidence

France's transposition of DAC8 (Council Directive (EU) 2023/2226), including the instrument, its date and the reporting duties of crypto-asset service providers, has no French primary source reachable on 14 October 2026.

licensing 20% confidence

AML/CFT for CASPs (since December 30, 2024): Mandates KYC, transaction monitoring, and sanctions compliance.

aml 90% confidence

The loi PACTE of 22 May 2019 created the French PSAN regime, which required at a minimum an AML/CFT framework; the ACPR gave its AML/CFT opinion on each digital-asset service provider before AMF registration because these providers present high money-laundering risks.

aml 88% confidence

The ACPR lists Directive (EU) 2015/849 as amended by Directive (EU) 2018/843 (the fifth AML directive) among the EU AML/CFT texts in force in France, alongside Monetary and Financial Code articles L. 561-2 ff.; the AMLR (2024/1624) applies from 10 July 2027 and AMLD6 (2024/1640) must be transposed by that date.

aml 92% confidence

MiCA sets CASP minimum capital at €50,000 (Class 1), €125,000 (Class 2, including custody and exchange) or €150,000 (Class 3, trading platforms) under Annex IV of Regulation (EU) 2023/1114. French PSANs had until 1 July 2026 to obtain AMF authorisation, and transfers of crypto-assets follow Regulation (EU) 2023/1113, which the ACPR lists as in force.

aml 20% confidence

EU AML Regulation (AMLR) and Sixth AML Directive (AMLD6): Standardizes KYC as ongoing, risk-based processes across EU, explicitly including CASPs/VASPs; aligns with AMLA for cross-border supervision.

aml 20% confidence

Collect, verify, and store identity documents (e.g., two forms of ID); use third parties permitted.

aml 85% confidence

Under Regulation (EU) 2023/1113, which the ACPR lists among AML/CFT texts in force in France, a CASP handling a transfer exceeding €1,000 to or from a self-hosted address must verify whether that address is owned or controlled by its client; enhanced vigilance for politically exposed persons is covered by ACPR guidelines under Monetary and Financial Code articles L. 561-2 ff.

aml 20% confidence

Ongoing transaction monitoring, KYB for corporate clients (beneficial ownership), and ML/FT risk assessment systems.

aml 90% confidence

Since the PSAN regime ended on 1 July 2026, management and shareholder checks run through AMF authorisation under MiCA: the AMF must refuse a CASP whose management body members lack sufficiently good repute and competence (Art 68(1)) or whose qualifying shareholders are unsuitable (Regulation (EU) 2023/1114, Art 63(10)). Under the former PSAN regime the ACPR gave an AML/CFT opinion before AMF registration.

Verdict Attribution

Source:
AI-Generated · Unreviewed
AI synthesized:
2026-07-13 (deepseek-chat)
Last updated:
2026-07-13
Confidence:
medium

This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.

Conditional — Crypto ATM/kiosk operators can operate in France only with full CASP authorization from AMF, local incorporation, robust AML/KYC programs including EDD for cash transactions over €1,000, and compliance with MiCA capital requirements (minimum €150,000 for exchange services), under dual supervision of AMF and ACPR with TRACFIN for STRs.

Questions this verdict aims to answer

  • What money-transmitter / kiosk-specific license is required?
  • What cash-transaction reporting thresholds apply?
  • What enhanced-KYC obligations attach to cash-in / cash-out?