Decision No. 2025-C-10 of March 17, 2025 Establishing a Consultative Commission on Anti-Money Laundering and Counter-Terrorist Financing

PRUDENTIAL CONTROL AND RESOLUTION AUTHORITY

DECISION OF THE SUPERVISORY COLLEGE

Decision No. 2025-C-10 of March 17, 2025
Establishment of a Consultative Commission
THE COLLEGE IN PLENARY SESSION
Having regard to the Monetary and Financial Code, particularly Articles L. 612-13, L. 612-14-I, and L. 561-36-1; Having regard to the deliberations of the College of March 17, 2025, DECIDES

Article 1: A consultative commission, the Consultative Commission on Anti-Money Laundering and Counter-Terrorist Financing, is hereby established. It is tasked with issuing an opinion, prior to their adoption, on the instructions adopted by the Prudential Control and Resolution Authority (ACPR) concerning persons subject to its supervision in the field of anti-money laundering and counter-terrorist financing (AML/CFT), in accordance with point a) of I of Article L. 561-36-1 of the aforementioned Code.

The instructions determine:
1) The lists, models, frequency, and deadlines for transmitting documents and periodic information that must be submitted to the ACPR under Article L. 612-24, first paragraph, of the aforementioned Code in the AML/CFT field, notably the annual questionnaire.
2) Standard files for applications for approval or authorization of any kind exclusively concerning the AML/CFT field, including notably the list, format, and methods of transmission of information necessary for the ACPR to rule, under Article R. 612-21 of the aforementioned Code, particularly regarding the approval of manual money changers.

The Commission is also consulted on draft guidelines before their adoption or when an update involves a substantial change to existing documents. Guidelines are explanatory guides intended for professions subject to ACPR supervision, containing an analysis of regulations in the AML/CFT field.

The Commission may also be consulted on any other document having an impact in the AML/CFT field.
The Commission is seized by the President of the Prudential Control and Resolution Authority.

Article 2: I - The presidency of the Consultative Commission is exercised by a member of the Supervisory College designated by the Supervisory College, upon proposal by the President of the ACPR. One or two Vice-Presidents possessing complementary experience to that of the President are also designated by the Supervisory College according to the same procedures. The names of the members of the College thus designated are listed in (cf. Annex 1).

II - The following are also members of the Commission:
1) The following professional associations:

• For the insurance sector, as defined in B of I of Article L. 612-2:
  • The Technical Centre of Provident Institutions (CTIP);
  • France Assureurs;
  • The National Independent Federation of Mutuals (FNIM);
  • The National Federation of French Mutuals (FNMF);
  • The Syndicate of Insurance Brokers (CSCA);
  • The Union of Mutual Insurance Organizations (ROAM).
• For the banking sector, as defined in A of I of Article L. 612-2:
  • The Association for the Development of Digital Assets (ADAN);
  • The French Association of Payment and Electronic Money Institutions (AFEPAME);
  • The Association of Financial Companies (ASF);
  • The French Financial Markets Association (AMAFI);
  • The French Banking Federation (FBF);
  • The Banking and Financial Coordination Office (OCBF).

2) Natural persons, designated within persons subject to ACPR supervision, whose names appear on the list in (cf. Annex 2) of this decision for the insurance sector and in (cf. Annex 3) for the banking sector.

3) The Caisse des Dépôts et Consignations. It designates a natural person to represent it.

Article 3: The President establishes, for each meeting of the Commission, the agenda and the list of members to be summoned, after soliciting the opinion of the Vice-President(s).

The President may invite other authorities or bodies competent in the AML/CFT field to the Commission's work. The President may also associate qualified personalities.

The Director of the national competence service TRACFIN, or the representative they designate, is invited to Commission meetings. The President of the AMF, or the representative they designate, is invited to Commission meetings. The President of the CNIL, or the representative they designate, is invited to participate in the Commission's work when subjects falling within their competence are present. The Director General of the Treasury or their representative is invited to Commission meetings.

The President of the Sanctions Commission may designate a member who attends the Commission's work.

When the Commission is consulted on a draft document that specifically concerns a category of persons subject to AML/CFT supervision not represented as such by the members of the Commission, the President invites one or more qualified personalities among the directly concerned persons to participate in the Commission's work.

The General Secretariat of the ACPR ensures the secretariat of the Commission. The secretariat prepares a summary report of the debates at the end of each meeting, accompanied by a record of conclusions, if applicable, which is communicated to the members for approval at the next meeting.

Article 4: For subjects of interest to the entire financial sector, the President of the Consultative Commission and the President of the AMF, or their representative, jointly establish the agenda and the list of representatives of professional associations or entities supervised by the AMF mentioned in point 2° of I of Article L. 561-36, who are to be invited.

The services of the AMF and the General Secretariat of the ACPR jointly prepare the notes to be presented at the meeting. They jointly draft a summary report of the meeting.

Article 5: The President establishes a consultation calendar, which is presented at the first meeting for each consultation. The calendar takes into account both the constraints of the ACPR and the time necessary for the members of the Commission, if applicable, to familiarize themselves with the subject of the consultation and render a relevant opinion, taking into account the impact of the project on persons subject to ACPR supervision.

Article 6: At the end of the consultation, the Commission adopts an opinion which is communicated to the Supervisory College. Only members of the Commission have deliberative votes. The opinion is signed by the President of the Commission.

Article 7: This decision repeals and replaces Decision No. 2024-C-16 of June 10, 2024 of the Supervisory College of the Prudential Control and Resolution Authority regarding the establishment of a consultative commission.

Article 8: This decision will be published in the Official Register of the Prudential Control and Resolution Authority.

The President,
François VILLEROY de GALHAU

Annex 1
President and Vice-Presidents of the Consultative Commission on Anti-Money Laundering and Counter-Terrorist Financing

Mr. Pascal DURAND, member of the College of the Prudential Control and Resolution Authority, President Ms. Marie-Laure BELAVAL, member of the Supervisory College of the Prudential Control and Resolution Authority, Vice-President Mr. Denis ALEXANDRE, member of the Supervisory College of the Prudential Control and Resolution Authority, Vice-President

Annex 2
Members of the Consultative Commission on Anti-Money Laundering Natural persons designated within persons subject to ACPR supervision - Insurance sector

Mr. Vincent FOURCROY
Compliance Director - Pro-BTP

Mr. Hervé FOUILLAND
Compliance Director - SOGECAP

Mr. Jean-Denis MALPELET
Compliance Director - Allianz France

Mr. Philippe PÉLÉGRI
Head of Internal Control and Financial Security Device - Crédit Mutuel Insurance Group

Ms. Laëtitia JACQUET-VAN COPPENOLLE
Public Affairs and Compliance Department - Axa France

Annex 3
Members of the Consultative Commission on Anti-Money Laundering Natural persons designated within persons subject to ACPR supervision - Banking sector

Mr. Djangho BRACHET
Financial Security Director - La Banque Postale

Ms. Magali ARRIVÉ
Compliance Director - Oddo et Cie

Ms. Anne-Catherine COLLEAU
Deputy Director of Group Financial Security - BNP Paribas

Ms. Sophie DUPEUX
Director of Risks and Permanent Control - Boursorama

Ms. Valentine AURIOL
Group Financial Security Director - Crédit Agricole SA

Mr. Michael PICCIOLONI
Chairman of the Board - BNC S.A.

Ms. Julie CHEVALLIER
Financial Security Director - BPCE Group

Mr. Emmanuel VAUTERIN
Legal and Compliance Manager - Mizuho Bank Ltd

Mr. Yoann BRIANT
Group Compliance Director - Coinhouse