New Anti-Money Laundering (TRACFIN) Obligations for SME Leaders in 2025-2026: The 5 Costly Traps You Must Avoid to Stay Compliant!

SME leaders, anti-money laundering vigilance is no longer just for banks. With Law No. 2025-532 of June 13, 2025, aimed at getting France out of the grip of drug trafficking, your TRACFIN obligations are significantly strengthened starting in 2026 (progressive measures from January 2025, with decrees still to come). New sectors are now covered (luxury cars, yachts, real estate), mandatory training is introduced, and there is an automatic presumption of money laundering for crypto “mixers/tumblers”. Non-compliance = fines up to €1 million or 10% of turnover (Art. L.561-39 of the Monetary and Financial Code) and asset freezing. For SMEs, this means more suspicious transaction reports (sharp increase expected in 2026) and a higher risk of audits.

Based exclusively on official sources, here are the 5 most expensive pitfalls – and how to anticipate them. (Sources: economie.gouv.fr, legifrance.gouv.fr)

1. Ignoring the extension of regulated sectors SMEs in real estate, luxury vehicle leasing, or property development? New due diligence obligations apply from 2025 (amended Art. L.561-2 CMF). Risk: missing declaration = penalty up to 10% of the suspicious turnover. Solution: Check your status using the official Tracfin guide on economie.gouv.fr and appoint a TRACFIN correspondent before the end of 2025.
2. Forgetting mandatory training The 2025 law requires all regulated entities to complete AML/CFT training (decree forthcoming, Art. L.561-34). No proof = fine + possible suspension of activity. Many SME leaders are still untrained in 2024. Solution: Complete the free Tracfin training modules (available during 2025) and keep certificates. Deadline: certification required before March 2026.
3. Failing to appoint a TRACFIN declarant/correspondent Mandatory for every regulated SME (the manager or a qualified employee, Art. R.561-23 CMF). Without one, no declaration is valid – immediate asset freeze possible in case of suspicion. Solution: Register via the ERMES platform on economie.gouv.fr (automatic update in 2025). Update annually if changes occur.
4. Underestimating suspicious transaction reports for crypto and fraud Automatic presumption for crypto mixers and tax fraud >€10k (Law 2025-532). E-commerce SMEs: significant increase expected in 2025. Delay = Tracfin opposition (up to 5 days). Solution: Use the ERMES portal to report online (required before completing the transaction, Art. L.561-15). Assess using the 16 official fraud indicators on impots.gouv.fr.
5. Lack of vigilance on cash payments New €15,000 ceiling for non-residents (Law 2025-532), with mandatory TRACFIN reporting. Retail SMEs: increased risk of drug-related money laundering expected. Solution: Implement internal controls (DGCCRF-Tracfin guidelines) and train staff using the “AML for SMEs” guide on economie.gouv.fr.

These reforms (transposing EU Directive 2024/1640) protect your company while fighting the estimated €50 billion laundered annually in France. Being TRACFIN-certified in 2026 will become a real competitive advantage with your partners! Is your SME TRACFIN-ready for 2025?

Do not hesitate to contact us at Service on New Grounds for more information.

#TRACFIN #AntiMoneyLaundering #SME #Tax #ComplianceFrance

(Article based on economie.gouv.fr, legifrance.gouv.fr – Updated December 2025)