Crypto Law Profile

France Ordinance No. 2024-937 on AML/CFT Crypto Transfers

French ordinance adapting AML/CFT rules for crypto-asset transfers under EU TFR II, extending obligations to CASPs, self-hosted-address risk controls, supervision allocation, and overseas adaptations.

France Effective Decree Dec 30, 2024

At a glance

Jurisdiction France; national ordinance adapting French AML/CFT law for crypto-asset transfers.
Status In force; main date Dec. 30, 2024, final transition provisions July 1, 2026.
Core focus Extends AML/CFT coverage to CASPs and crypto-asset transfer risk controls.
Regulators AMF and ACPR supervision roles remain allocated by service type during the transition.

Overview

France’s Ordinance No. 2024-937 of October 15, 2024 strengthens AML/CFT obligations for crypto-asset transfers by amending the Code monétaire et financier and aligning French law with the EU Transfer of Funds Regulation framework for crypto-assets. The ordinance is in force: most provisions applied from December 30, 2024, and the remaining transition-related provisions applied from July 1, 2026.

The measure sits alongside France’s wider MiCA implementation work. Its focus is narrower than market authorization: it targets anti-money laundering and counter-terrorist financing obligations for crypto-asset service providers, including controls for transfers involving self-hosted addresses, supervision by French authorities, and overseas adaptations.

Key provisions of France Ordinance No. 2024-937

Expanded AML/CFT perimeter for crypto-asset service providers

The ordinance updates French AML/CFT terminology from digital asset service provider concepts toward MiCA-aligned crypto-asset service provider categories. It amends Article L. 561-2 of the Code monétaire et financier to cover CASPs authorized under Article 59 of MiCA, including certain branches established in France, and to bring additional provider categories into France’s AML/CFT perimeter.

The official explanatory report states that Article 2 adapts provider terminology to MiCA and subjects CASPs that provide only crypto-asset advice to AML/CFT obligations. It also allows specific application provisions for the Caisse des dépôts et consignations when providing crypto-asset services.

Self-hosted address risk assessment

A central change is the creation of Article L. 561-10-4. This provision requires covered CASPs to identify and assess money laundering and terrorist-financing risk linked to crypto-asset transfers made to or from a self-hosted address, as that term is used in Regulation (EU) 2023/1113. CASPs must put in place internal organization, policies, procedures, and controls for complementary due-diligence measures, with further conditions to be set by decree of the Conseil d’État.

Crypto correspondence and enhanced due diligence

The ordinance extends enhanced due-diligence concepts used for financial institutions to crypto-asset services. Article 5 amends Article L. 561-10-3 so that rules for relationships with non-EU financial institutions can also address crypto-asset operations and transfers. The explanatory report describes this as requiring complementary due-diligence measures when CASPs provide crypto-asset correspondence services to client financial institutions established outside the European Union.

Regulators and affected entities

Ordinance No. 2024-937 preserves the division of AML/CFT supervision between the Autorité des marchés financiers and the Autorité de contrôle prudentiel et de résolution. The official report says Articles 8 and 9 maintain this allocation during the transitional period ending July 1, 2026, covering both MiCA-authorized CASPs and French-registered or authorized digital asset service providers operating under transitional arrangements.

The AMF later published Position DOC-2024-08 to incorporate the European Banking Authority’s Travel Rule Guidelines for certain crypto-asset transfers. The AMF said the guidelines apply from December 30, 2024, and that it applies them in supervising CASPs under its jurisdiction, including transitional DASPs covered by MiCA’s French transition period.

Status and timeline

DateEvent
October 15, 2024Ordinance adopted and signed.
October 17, 2024Published in the Journal officiel de la République française.
December 30, 2024Main provisions entered into force.
January 8, 2025Ratification bill for Ordinances 2024-936 and 2024-937 deposited in the Senate.
July 1, 2026Remaining article 2 and article 9 provisions entered into force.

As of July 6, 2026, the ordinance should be treated as an in-force French legal instrument for CryptoSlate reference purposes. Editors should continue to track the separate ratification bill and any Conseil d’État decree implementing Article L. 561-10-4.

Relationship to EU Travel Rule implementation

The French measure is designed to operate with Regulation (EU) 2023/1113, often referred to as the EU Transfer of Funds Regulation or Travel Rule framework. The EBA’s related guidelines specify steps for payment service providers, intermediary payment service providers, CASPs, and intermediary CASPs to detect missing or incomplete information accompanying transfers and to manage deficient transfers consistently across the EU.

Key provisions

CASP AML/CFT perimeter

Updates art. L. 561-2 terminology and brings additional CASP categories, including advice-only CASPs, within France’s AML/CFT scope.

AML/CFT Dec 30, 2024 Source

Self-hosted address controls

Creates art. L. 561-10-4 requiring CASPs to assess ML/TF risk for transfers to or from self-hosted addresses and apply complementary controls.

Self-custody Dec 30, 2024 Source

Crypto correspondence due diligence

Extends enhanced due-diligence rules to crypto-asset correspondence services involving non-EU financial institutions.

AML/CFT Dec 30, 2024 Source

AMF and ACPR supervision split

Maintains allocation of AML/CFT supervision between AMF and ACPR for MiCA-authorized CASPs and transitional French DASPs.

Licensing & Registration Dec 30, 2024 Source

Overseas adaptations

Adapts relevant Code monétaire et financier provisions for French overseas territories, including references to art. L. 561-10-4.

AML/CFT Dec 30, 2024 Source

Timeline

  1. Ordinance adopted

    Ordinance No. 2024-937 was signed after Council of State and Council of Ministers review.

    Enacted Source
  2. Official Journal publication

    Text n°19 published in JORF n°0247 with NOR ECOT2415928R.

    Enacted Source
  3. Main provisions in force

    General application date aligned with EU TFR II and the amended AML Directive timing.

    In force Source
  4. Ratification bill deposited

    Bill n°231 to ratify ordinances 2024-936 and 2024-937 was deposited in the Senate.

    Introduced Source
  5. Final phase-in date

    Remaining article 2 and article 9 transition provisions scheduled for July 1, 2026 became operative.

    In force Source

Who it affects

Actors

Autorité de contrôle prudentiel et de résolution (ACPR), Autorité des marchés financiers (AMF), European Banking Authority (EBA), French Ministry of Economy and Finance

Asset classes

Crypto assets

Official sources

Editorial note

Non-U.S. legal instrument mapped to In force. Main provisions applied Dec. 30, 2024; remaining transition provisions applied July 1, 2026. Ratification bill n°231 was deposited Jan. 8, 2025; no final ratifying law was confirmed in checked sources.

Editor note: AMF page appears to cite “ordinance 2024-397”; Légifrance confirms the relevant identifier is Ordonnance n° 2024-937.