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

As part of its 2026 supervisory priorities and its Impact 2027 strategic orientations, the Autorité des Marchés Financiers (AMF) is publishing a summary of the main lessons learned from its inspections involving a component looking at Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) and the Automatic Exchange of Information for tax purposes (AEI), which gave rise to follow-up action between 1 January 2022 and 31 December 2025.

AML/CFT poses a major challenge for the integrity of the financial markets and the prevention of financial crime. The market participants regulated by the AMF, in particular asset management companies and financial investment advisors, have a key role to play in this regard by detecting and preventing the risks of money laundering, terrorist financing and, more broadly, financial fraud.

This summary is based on an analysis of 46 inspections which gave rise to follow-up, whether repressive or otherwise, during the period under review. These inspections resulted in 16 sanction decisions, 16 administrative settlement agreements and 16 follow-up letters requesting remedial measures. Some of the inspections led to more than one type of follow-up. These 'standard' inspections complement the AMF's ongoing supervision of AML/CFT matters.

This publication forms part of an educational and preventive approach aimed at raising awareness among supervised market participants of the importance of their AML/CFT and AEI obligations. It also comes at a time when the European supervisory framework is being strengthened, marked by the creation, in June 2024, of the European Anti-Money Laundering and Countering the Financing of Terrorism Authority (AMLA), whose remit includes supervising (directly and indirectly) the financial sector in terms of AML/CFT, as well as contributing to the definition of the European regulatory framework in this area.

The main shortcomings identified by the AMF's inspection teams include the following:

• the existence of AML/CFT procedures that are incomplete, insufficiently precise or not adapted to the activities carried out;
• risk maps that are insufficiently personalised, incomplete or that do not provide an operational link between the risks identified and the vigilance measures implemented;
• gaps in the supervision of delegates, distributors, service providers and other third parties involved in know your customer due diligence;
• shortcomings in the collection, storage, updating and traceability of information relating to clients, their beneficial owners, the origin of funds or politically exposed person status;
• failures in the implementation of the due diligence applicable to investment and divestment transactions involving fund assets;
• breaches of TRACFIN or AMF reporting obligations;
• a lack of regular and appropriate training for employees on AML/CFT obligations;
• internal control systems that are insufficiently formalised or whose effectiveness has not been demonstrated;
• shortcomings in the way in which AEI obligations are taken into account.

The summary also highlights the importance of reporting work in the effectiveness of the AML/CFT systems. Obliged entities must be able to identify atypical transactions, carry out the necessary analyses and, where circumstances so warrant it, make the appropriate suspicious transaction reports to TRACFIN.

The AMF will continue its supervisory and inspection work to ensure that the applicable AML/CFT and AEI obligations are effectively implemented, and to consider repressive action in line with a risk-based approach. It will also continue to contribute to European work in this area, particularly as part of the gradual set-up of the AMLA.

Find out more

• Summary of the findings of the Autorité des Marchés Financiers anti-money laundering and combating the financing of terrorism inspections (AML/CFT) that gave rise to follow-up action between 1 January 2022 and 31 December 2025