Released on November 24 by the French Autorité des Marchés Financiers ( ‘French AMF’), Position DOC-2019-14 (‘the Position’), applicable to entities such asset management companies, financial investment advisors.

This Position, which incorporates European Banking Authority (EBA) guidelines on risk factors, sets out factors that firms should take into account when assessing the money laundering and terrorist financing (AML/CFT) risks associated with a business relationship or occasional transaction, and the manner firms should adjust their customer due diligence processes.

The Position includes general guidelines (identifying, assessing and categorising AML/CTF risks) as well as sector-specific ones (e.g., guidelines applicable to asset management companies in connection with their discretionary portfolio management activity and investment advisory services).

The provisions of this Position are reflected in the French AMF General Regulation.