Regulatory

A fintech wished to provide crypto-asset services in France without holding any status. We qualified each of its services, set the strategy for the application, drafted the programme of operations and the procedures, including the AML/CFT framework, and structured its organisation. We assisted it in all its exchanges with the AMF and the ACPR until it obtained its authorisation as a crypto-asset service provider.

A project whose token was already in circulation sought its admission to trading on a platform. We qualified the token under MiCA, drafted the white paper and assisted the issuer in its exchanges with the AMF. The token was admitted to trading on a secure footing.

A fintech wanted to offer an integrated service in fiat currency and crypto-assets. We ran in parallel its applications for CASP authorisation with the AMF and for payment institution authorisation with the ACPR, aligning the MiCA and PSD2 requirements on own funds, governance and internal control. The fintech obtained both authorisations and operates under dual status.

A business offered crypto-asset staking and lending services to retail and corporate clients. We analysed the risk of the model being requalified as an investment service or a collective investment scheme and proposed a compliant structure. We monitored for it the review of MiCA and the consultations of the European Securities and Markets Authority (ESMA) and the AMF, and assisted it in its exchanges with the regulators.

An international exchange was on the AMF blacklist. We assisted it in its relations with the AMF and other national regulators to design and implement an orderly exit from the French market. This plan led to its removal from the blacklist.

A crypto-asset service provider authorised in another Member State wished to serve the French market. We assisted it with the notification of its passport and the launch of its services in France. The passport does not settle everything: we brought its activities into line with the MiCA rules applicable in France, AML/CFT rules and consumer law, dealt with the tax questions raised by a possible establishment and its structure, and negotiated its contracts with local partners, in particular on marketing.

The publisher of a Web3 game with monetisable digital objects had to enter the JONUM regime. We analysed its business, handled the whole declaration process and assisted the publisher before the ANJ, before and after the declaration, to adapt its game to the regime. The project became compliant and secured its operations.

They advise and represent businesses that provide crypto-asset services or payment services, or that issue tokens: qualification of the business, choice of status, authorisation application, ongoing compliance and relations with the AMF, the ACPR, the Banque de France and the ANJ. The lawyer is professionally liable for the advice, and exchanges with the client are protected by legal professional privilege.

Yes. We advise providers and groups established in other Member States and in third countries, both on entering the French market and on obtaining an authorisation in the European Union. We work in English and French and coordinate, where needed, with counsel in other jurisdictions.

Yes. Since the end of the transitional period on 1 July 2026, a provider serving clients in France must be authorised as a CASP by the AMF, or be authorised in another Member State and passport its services into France. Reverse solicitation, at the exclusive initiative of the client, remains a narrow exception. We handle these CASP authorisation applications.

The AMF authorises CASPs and receives the white papers of most tokens. The ACPR authorises payment and e-money institutions, supervises stablecoin issuers, gives an opinion on CASP applications and supervises their AML/CFT framework. The same project often falls under both authorities, for example under dual CASP and payment institution status.

Providers registered as PSANs that have not obtained MiCA authorisation can no longer provide their services in France. The AMF recommended that they prepare an orderly wind-down plan by 30 March 2026 at the latest. We assist these providers in winding down their business.

A CASP authorised in another Member State can do so under the MiCA passport, after notification to its home authority. A third-country provider must in principle set up an authorised entity in the European Union. Advertising aimed at the French public without authorisation exposes a provider to the AMF blacklist. We assist these foreign providers with access to the French market.

It depends on the qualification. Fungible tokens fall in principle under MiCA, genuinely unique NFTs are excluded, and only genuinely decentralised services fall outside the Regulation. A game with monetisable digital objects falls under the French JONUM regime and requires a declaration to the ANJ. We qualify these crypto and Web3 projects before launch.

Respond quickly, with counsel, and make no commitment you have not checked: the first exchanges shape what follows. Being on the blacklist is not final. Removal requires ceasing any offer to the French public and demonstrating this to the AMF. We handle these removals from the blacklist.