France's financial intelligence unit, TRACFIN, has released its comprehensive threat assessment for 2024-2025, providing invaluable intelligence for compliance professionals. The report highlights emerging money laundering typologies and offers guidance for regulated entities operating in or with connections to France.

Real Estate Sector Focus

TRACFIN identifies real estate as a persistent high-risk sector for money laundering. The report details schemes involving shell companies, complex corporate structures, and the use of foreign entities to obscure beneficial ownership. Real estate agents and notaries are urged to enhance their vigilance on unusual transaction patterns.

Crypto-Asset Risks

The threat report dedicates significant attention to virtual assets. Key concerns include: use of unregulated exchanges, peer-to-peer transactions bypassing traditional controls, mixing services obscuring transaction trails, and conversion to stablecoins as a layering technique.

Professional Services Gatekeepers

Lawyers, accountants, and corporate service providers face heightened scrutiny. TRACFIN notes that these gatekeepers are often unknowingly involved in creating structures used for money laundering. The report emphasizes the importance of understanding the economic rationale behind complex arrangements.

Letterbox Companies Strategy

A notable development is TRACFIN's enhanced focus on 'sociétés boîtes aux lettres' (letterbox companies). The FIU has developed new analytical techniques to identify shell companies with no real economic substance used purely for fund transfers.

Red Flags to Watch

The report provides updated typologies including: rapid succession of company formations, discrepancies between declared activity and actual transactions, use of nominees or power of attorney arrangements, and transactions with jurisdictions lacking transparency.

Implications for Compliance

Regulated professionals should update their risk assessments to incorporate TRACFIN's findings. This is particularly relevant for entities with French clients or operations. The threat report serves as an essential reference for developing targeted monitoring scenarios.