Head of International Corporate Law and Fintech Practice
Expert in fintech, crypto, and international corporate law with over 20 years of experience. Specializes in crypto licensing (VASP/CASP), iGaming business support, and international structuring, asset protection, and OSINT analytics for risk assessment and due diligence.
Confirmation of the origin of money in France
In 2025, France is strengthening control over large cash flows: according to TRACFIN, in 2024, the French financial intelligence service received more than 211,000 reports of suspicious transactions – an increase of more than 13% compared to the previous year. This means that banks and payment providers are controlling the origin of funds more strictly than ever.
The Prikhodko & Partners team regularly accompanies clients – individuals and entrepreneurs – in France when verifying the sources of funds. Here are practical answers to the questions you need to know and how to prepare.
What can be the confirmation of the origin of funds of an individual?
The most common and acceptable documents required by banks, notaries or financial platforms in France are:
- Bank statements (showing the receipt and storage of funds).
- Contracts and certificates of work performed – employment contracts, subcontracts, contracts for the sale of goods/services.
- Payment documents – SWIFT, SEPA payments, payment orders, invoices and receipts.
- Documents on the sale of assets – a contract for the sale of real estate, cars, corporate rights with confirmation of the transfer.
- Tax returns and tax certificates from the country of origin (for example, a Ukrainian tax certificate).
- Documents on inheritance or donation – certificates, notarial deeds.
- Official certificates of disbursement (attestation de disponibilité des fonds) – some French notaries request handwritten confirmations or bank certificates.
We advise our clients to form a chain of evidence: the clearer the chain (contract → invoice → payment), the faster the verification will be completed.
What is needed for this is the requirements of local legislation (key provisions)
French financial monitoring rules are enshrined in the Code monétaire et financier, in particular in the sections regulating customer verification obligations (see articles L561-1 and L561-2 on the scope of entities obliged to carry out CDD – customer due diligence). Supervisory and sanctioning tools are enshrined in the articles of the liability section (in particular article L574-1 on administrative sanctions). In addition to national legislation, financial institutions in France apply the guidelines and instructions of regulators (ACPR, AMF) on reporting to TRACFIN and conducting due diligence. In 2025, the ACPR published clarified guidelines on the obligation to report to TRACFIN and interaction with payment services, which affects the requirements for confirming the origin of funds.
Basic requirements for the origin of funds of an individual
Banks and financial institutions in France are guided by a risk-based approach (RBA). The main requirements are:
- Evidence – the presence of primary documents confirming the source.
- The integrity of the chain of funds movement – from the original payer to the client’s account.
- Transparency of the purpose of the transaction – a clear explanation of what the funds are used for.
- The presence of tax evidence – confirmation of tax payment or legality of origin (if it is a salary or business income).
- Compliance with sanctions lists and the absence of suspicious patterns – repeated receipts from risky jurisdictions raise additional questions.
The procedure for confirming the origin of funds and deadlines
Typical workflow:
- Request from the bank / notary – an official list of required documents.
- Collection and submission of documents – the client provides scans / apostilled copies, translations.
- Initial due diligence (CDD) — 1–5 business days (depending on complexity).
- Extended due diligence (EDD) — if the client is classified as high-risk, additional inquiries (sources of funds, beneficiaries, contracts) — up to 10–30 days or more.
- Bank/notary decision — acceptance, rejection, or additional conditions (e.g., escrow or accompanying instructions).
TRACFIN requires institutions to immediately report suspicious transactions; if a bank detects a discrepancy, it may temporarily freeze the account until the circumstances are clarified. In practice, the full resolution of complex cases can take from several weeks to several months.
How much does a source of funds relevance analysis cost?
Estimated market rates in 2025 (for individuals):
- Basic verification (package of documents, short report) — € 300–€ 800.
- In-depth due diligence with international verification (managers, counterparties, verification of the origin of funds from several countries) — € 1,200–€ 6,000.
- Full legal and tax audit with preparation of official reports for the bank/notary — from € 4,000, depending on the complexity and volume.
We offer both individual services and package solutions: preparation of an AML package + support for negotiations with the bank from € 300 in standard cases and individual tariffs for comprehensive verifications.
Main difficulties in confirming the origin of money of an individual
- Incomplete or untranslated documents — banks require an apostille/translation in French or English.
- Time discrepancy — gaps between the date of the contract and the receipt of funds raise questions.
- Form of income (cash, crypto) — cash and cryptocurrency transactions require additional confirmations.
- Complex corporate structures (offshores, trusts) complicate verification of ultimate beneficiaries.
- Sanction risks — transactions through certain jurisdictions or counterparties increase the likelihood of an in-depth review.
What is the interaction with the EU and Ukraine?
France coordinates activities with other EU countries through financial intelligence exchange mechanisms and applies the EU AML Directives; coordination will be strengthened in preparation for the launch of the AMLA at the EU level. Therefore, documents issued by Ukrainian authorities (tax certificates, notarial acts) can be accepted subject to proper legalization (apostille) and translation. FATF and European instruments also define inspection standards, which unifies approaches between France and Ukraine.
How do we help with confirming the origin of money for an individual?
The law firm “Prikhodko and Partners” provides comprehensive support:
- Preliminary audit and checklist of documents – we determine which documents your bank or notary will need.
- Preparation of legalization and translations – apostilles, notarial certifications, professional translations into French.
- Building a chain of evidence – preparation of contracts, payment orders, accounting extracts, tax certificates.
- Preparation of legal explanations and memoranda for banks or TRACFIN, if necessary.
- Representation in negotiations with the bank/notary: we communicate with officials, minimize the risk of blocking.
- Legal and tax consulting on the optimal structure of the transfer of funds (especially when it comes to purchasing real estate or investments).
In 2025, we successfully supported over 30 cases of proof of origin of funds for private investors in the EU — from apartment purchases to transfers for business investments. This allowed our clients to avoid delays, fines, and reduce the risks of long-term account blocking.
Confirming the origin of funds in France is a matter of preparation, transparency and quick response. A clearly formed package of documents, apostilled certificates and professional legal explanations significantly increase the chances of successful verification. If there is a need to prepare and form the origin of funds – we will be happy to help with international expertise, practical experience and effective solutions for your specific case.
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