Contents of your Astrée press review:

• ACPR launches a new survey on brokers' LCB-FT obligations.
• The AMF Ombudsman publishes his 2024 report.
• Again, the ACPR has issued a formal notice to a broker to correct shortcomings in the supervision of its distribution network.
• The AMF sanctions an issuer and its shareholders.
• The Senate unanimously adopted a bill to guarantee an insurance solution for all local authorities.
• Climate change and insurance: a report by the French High Commission for Strategy and Planning calls for an overhaul of solidarity in the face of natural risks.
• Tracking pixels: CNIL launches a public consultation.
• All-time record number of suspicious transaction reports in Tracfin's new activity report. 

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ACPR launches a new survey on brokers' LCB-FT obligations

June 10, 2025

In 2025, the Autorité de contrôle prudentiel et de résolution ("ACPR") is launching a new survey of brokers subject to LCB-FT obligations, following those of 2020 and 2022.

The questionnaire, updated to reflect regulatory changes, will be available online from June 10 to July 10, 2025. It aims to collect data on brokers' activity and verify their compliance with LCB-FT obligations. This concerns insurance and banking brokers registered with ORIAS before December 31, 2024.

This investigation is part of the drive to strengthen Europe's fight against money laundering, notably with the creation of the AMLA.

The form is available here.

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The AMF Ombudsman publishes his 2024 report

June 11, 2025

The 2024 report by the Ombudsman of the Autorité des marchés financiers ("AMF") ("AMF") Ombudsman, Marielle Cohen-Branche, takes place in a special context: a real estate crisis, a team transfer, and the imminent end of her term of office.

The number of cases referred to the Ombudsman rose significantly (+15%), largely due to a surge in disputes concerning real estate crowdfunding and real estate investment trusts (SCPI).
While PEAs and employee savings schemes remain the most frequent grounds for complaint, crypto-assets are generating a growing lack of understanding among investors as to the protection afforded to them. Despite a decline in the number of opinions issued (-16%), the Ombudsman's proposals continue to be followed in 94% of cases. The report also highlights the progress made in terms of online referrals, which are now in the majority. Finally, mediation is proving to be a real lever for alerting and improving practices, in the service of fairer finance.

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ACPR issues a formal notice to a broker to correct shortcomings in the supervision of its distribution network

June 6, 2025

The Autorité de contrôle prudentiel et de résolution ("ACPR") has issued a issued a formal notice an insurance broker to remedy major shortcomings in the supervision of its distribution network. The ACPR's inspection revealed shortcomings in the monitoring of distribution partners, as well as in the quality control of sales, particularly those made remotely by telephone canvassing, via platforms operating outside the European Economic Area.

These shortcomings, which are detrimental to policyholders (mainly pensioners), raise concerns in terms of customer protection. The ACPR stresses the importance for all professionals of ensuring that product distribution is in line with governance arrangements.

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AMF sanctions an issuer and its shareholders

June 10, 2025

On June 10, 2025, the Enforcement Committee of the Autorité des marchés financiers ("AMF") issued, a decision1.72 million in sanctions against a listed issuer in the ready-to-wear sector and several of its former majority shareholders.

The issuer was fined 20,000 euros for failing to preserve the confidentiality of insider information, since its annual press release could be consulted in advance.

However, the main breaches concerned historical shareholdings. Two companies, controlled by the same individual, were sanctioned for failing to declare the crossing of thresholds and failing to declare their intention to do so, as part of a share transfer scheme implemented between 2016 and 2021.

A misleading press release denying the existence of capital and control links between these entities was also considered as market manipulation.

The financial penalties are as follows:

• 1 million euros against the individual controlling the companies;
• 400,000 euros for the first structure involved;
• 300,000 euros for a second structure;
• 20,000 for a third company.

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The Senate unanimously adopts a bill to guarantee an insurance solution for all local authorities

June 11, 2025

This text follows on from a parliamentary report denouncing the difficulties of access to insurance in the face of rising risks and premiums.
It includes the creation of a rates observatory, the extension of the Insurance Ombudsman's remit, and the obligation to include riot cover in "property damage" contracts.
Several adjustments have been made, including clarification of legal concepts and an increase in the risk management fund to 1.5 billion euros.
The proposal was transmitted to the National Assembly on June 12, 2025.

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Climate change and insurance: a report by the French High Commission for Strategy and Planning calls for an overhaul of solidarity in the face of natural risks.

June 12, 2025

Faced with the intensification of extreme climatic events, the French High Commission for Strategy and Planning publishes a report calling for an overhaul of France's climate risk mutualization system. It warns of the limitations of the current model, based on the "Cat Nat" scheme and home insurance, which does not cover all risks (such as coastline recession), remains unevenly distributed across the country, and struggles to integrate the growing challenges of prevention.

The average cost of weather-related claims, now estimated at between 4 and 4.5 billion euros a year, is set to rise even further. Against this backdrop, the authors of the report propose three scenarios for reform, ranging from a stronger regulatory role for the State to full socialization of risks, with a universal system financed by climate-related contributions.

The challenge is to guarantee the insurability of exposed territories, while rethinking collective solidarity in the face of increasingly frequent disasters.

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Tracking pixels: CNIL launches a public consultation

June 12, 2025

CNIL opens a public consultation on the use of tracking pixels, invisible devices integrated into e-mails to track recipients' activity.

While the use of these tools is not new, their widespread adoption raises major issues of confidentiality in what is perceived as a personal space. The draft recommendation aims to clarify the rules applicable to these tools, in addition to those relating to cookies, and is addressed to all public and private players concerned. Contributions are invited by July 24, 2025, in particular to assess the legal, technical and economic impact of possible regulation.

With this initiative, CNIL aims to reconcile data protection with an understanding of the underlying business models.

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All-time record number of suspicious transaction reports in Tracfin's new activity report

June 12, 2025

In its 2024 reportTracfin reports that it received 215,410 reports, including 211,165 suspicious transaction reports, a record 13.2% higher than in 2023.
The financial sector remains the main contributor, while emerging players such as NSPs are reporting a spectacular increase in reports. The non-financial sector is also growing, albeit unevenly by profession. Two new categories, including digital gaming companies, have joined the anti-money laundering scheme.

In 2025, Tracfin's operational priorities are threefold: to receive better quality suspicious transaction reports, to work more closely on disciplinary matters in collaboration with the supervisory authorities, and to support reporters in the new procedures for entering and sending suspicious transaction reports.

It is mainly professions in the financial sector that report suspicious transactions (93.1%), and in particular banks and credit institutions (57.2%).
Some professions, such as lawyers (15 suspicious transaction reports), are clearly lagging behind.

In the insurance sector, there has been a marked increase, with 13,003 suspicious transaction reports (+13.6% on 2023).
Insurance companies account for 11,172 reports, compared with 557 for insurance intermediaries.

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Have a great week!