Crypto ATM / kiosk operator in France
Physical kiosks that exchange cash for crypto (and sometimes vice versa). High-cash AML risk profile.
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).
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.
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.
MiCA Regulation (EU) (2023) — CASP authorization, comprehensive crypto regulation
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.
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.
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.
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.
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.
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).
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.
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.
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.
AML/CFT for CASPs (since December 30, 2024): Mandates KYC, transaction monitoring, and sanctions compliance.
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.
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.
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.
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.
Collect, verify, and store identity documents (e.g., two forms of ID); use third parties permitted.
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.
Ongoing transaction monitoring, KYB for corporate clients (beneficial ownership), and ML/FT risk assessment systems.
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?