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Centralized exchange in France

Order-book exchange that takes custody of user assets and matches trades between users.

Conditional AI-Generated · Unreviewed

CEX 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 under MiCA via AMF — mandatory full license (replacing former DASP/PSAN registration); minimum capital of EUR 150,000 for exchange/custody operations.
  • Mandatory KYC/CDD — collect, verify, and store identity documents (e.g. two forms of ID) for all users; third-party reliance permitted.
  • Enhanced Due Diligence (EDD) for PEPs, transactions over EUR 1,000 to self-hosted wallets, and cross-border activities.
  • Ongoing transaction monitoring and KYB for corporate clients (beneficial ownership verification).
  • ML/FT risk assessment systems required.
  • TRACFIN suspicious transaction reporting (STR) obligations under AML/CFT rules applicable to CASPs since December 30, 2024.
  • Travel Rule (FATF TFR recast) applies — EUR 0 threshold — mandatory transmission of originator/beneficiary data on all withdrawals and transfers.
  • DAC8 reporting (effective January 1, 2026) — CASPs must report user crypto transactions to tax authorities.
  • Managers and beneficial owners verified during AMF registration process.

Key Restrictions

  • Must obtain full CASP authorization under MiCA via AMF (not just simple registration).
  • SHORT transition: existing PSAN/DASP holders had to apply for CASP by June 30, 2025.
  • Custody is a licensed MiCA activity — minimum EUR 50,000 capital for custody alone; combined exchange+custody at EUR 150,000 minimum.
  • Local entity required — must be incorporated/authorized in France to serve French residents.
  • CASP services must comply with MiCA market-conduct rules for orderly trading, transparency, and investor protection.
  • French adaptations to MiCA (Order Oct 2024, Decree Feb 2025, Law Apr 2025) integrate local requirements with EU framework.

Key Risks

  • Enforcement risk if operating without full CASP authorization after transition deadline (June 30, 2025).
  • Regulatory ambiguity during the transition from PACTE DASP regime to MiCA CASP regime — different interpretations may apply.
  • Travel Rule compliance imposes operational overhead on all withdrawals (EUR 0 threshold) — must implement technical solutions for data transmission.
  • DAC8 tax reporting from January 2026 introduces new data-sharing obligations with tax authorities.
  • AMF/ACPR dual supervision (market conduct + prudential) creates overlapping compliance burden.

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

2024 CMF Update: Adds MiCA-aligned requirements for DASPs.

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.

travel-rule 95% confidence

France applies the EU Transfer of Funds Regulation (EU) 2023/1113 from 30 December 2024, which the ACPR lists among the AML/CFT texts in force; transfers of crypto-assets must carry originator and beneficiary information regardless of amount, with no minimum threshold.

Verdict Attribution

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

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

Conditional — a centralized exchange serving French residents must obtain full CASP authorization under MiCA via AMF (EUR 150k minimum capital), maintain a local entity, comply with zero-threshold Travel Rule obligations, and meet comprehensive AML/KYC oversight by AMF/ACPR/TRACFIN.

Questions this verdict aims to answer

  • What exchange / VASP license applies?
  • What custody segregation rules apply to user assets?
  • What market-conduct and listing rules apply?
  • What travel-rule obligations apply on withdrawals?