In November 2022, the Court of Justice of the European Union ruled that letting anyone search a company's beneficial ownership data indiscriminately breached the right to privacy. The case, brought by a Luxembourg-registered company called Sovim, forced France to lock down a register it had spent years building into one of Europe's most open.
Rebuilding a workable access regime has taken almost four years, a new law and a decree signed in April 2026. Judicial authorities, banks, notaries and anyone able to show a 'legitimate interest' in combating money laundering may now apply, with the France's National Institute of Industrial Property (INPI) required from 10 November 2026 to decide within 12 days. France has just finished relearning how difficult it is to define, defend and administer beneficial ownership transparency in practice.
That experience is about to become directly relevant to every obliged entity in France, for reasons that have nothing to do with France's own register.
Judging in others what France has just judged in itself
Under Article 20(3) of the EU's new Anti Money Laundering Regulation, the EU Anti Money Laundering Authority (AMLA) must issue guidelines on the risk factors obliged entities should weigh when assessing customers and transactions. From July 2027, those guidelines will require firms to treat financial secrecy as a formal component of geographic risk assessment, not an informal judgement call. Annex III of the Regulation defines financial secrecy through features that will sound familiar in Paris - restrictions on the exchange of information, weak oversight of legal entities, strict banking or corporate secrecy laws and the absence of beneficial ownership transparency.
For years, French obliged entities have leaned on FATF and EU high-risk lists to classify geographic risk: a jurisdiction is either flagged or it is not. AMLA's guidance moves past that. Instead, geographic risk will be built by combining transaction value with the level of financial secrecy in both the originating and destination jurisdiction, drawing on structured, comparable datasets such as the Basel AML Index rather than static classifications. It is both a more granular approach and a more demanding one. Firms will need to show not just that they screened a country, but that they can defend, with evidence, how opaque it actually is.
Why this lands harder in France than the guidance itself suggests
France is not a bystander to this shift. In its 2025 annual report Tracfin, France's financial intelligence unit, recorded 278,484 suspicious activity disclosures, up 32% on the previous year with banks alone up 45% and crypto asset service providers nearly doubling their filings. More than 8,000 shell companies were flagged, four in five of them subsequently struck off the register. France’s Economy Minister Roland Lescure has pointed to Tracfin's growing capacity to “link dispersed financial operations to reveal networks, beneficial owners and concealed strategies” as central to that effort. That volume is itself evidence of how much ownership obscurity still moves through the French financial system.
France's largest banking groups also carry some of Europe's deepest cross-border exposure to the kind of secrecy characteristics Annex III describes - correspondent relationships across the CFA franc zone in West and Central Africa, long-standing private banking ties to Monaco and networks built up over decades in jurisdictions where legal ownership has historically been difficult to verify. Geographic risk models built solely on FATF lists have never fully captured that exposure. AMLA's framework is designed to capture it.
Looking ahead: 2027 and beyond
For compliance professionals in France, the practical task over the next 18 months is to move geographic risk assessment away from a static list-based control and towards a documented, data-driven methodology that can withstand supervisory challenge. That means mapping correspondent and client relationships against jurisdiction-level secrecy indicators, not just sanctions and high-risk designations, building the model AMLA envisages, which combines transaction value with secrecy scoring. This must happen before it becomes mandatory and ensuring boards can explain, in specific and evidenced terms, why a given jurisdiction was scored as it was.
France's own beneficial ownership saga offers a preview of what is coming, at a smaller scale and on a longer timeline than firms will now be given. Building a transparency regime that is workable, proportionate and legally defensible took Paris the better part of four years. Obliged entities have until July 2027.
For those advancing through ICA's French-language Certificate in Anti Money Laundering and Specialist Certificate in Combating the Financing of Terrorism, that timeline is no longer a distant regulatory milestone. It is the shape of the job from 2027 onwards.