Centralized exchange in France
Order-book exchange that takes custody of user assets and matches trades between users.
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).
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.
2024 CMF Update: Adds MiCA-aligned requirements for DASPs.
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.
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?