As part of a wide update of legislation in France to crack down on drug trafficking Loi n° 2025-532 du 13 juin 2025 was published in the Official Journal on 14 June 2025
This law expands the scope of anti-money-laundering (AML) obligations by adding several professions to the list of regulated entities under Article L.561-2. Newly covered are real estate traders and developers (“marchands de biens” and “promoteurs immobiliers”), as well as high-value goods dealers including automobile sellers, yacht brokers (businesses selling or leasing pleasure vessels), and private aircraft dealers (each above a value threshold to be defined by decree), as well as football clubs. These sectors join the existing list of persons subject to AML duties in France. Specific applicable value thresholds for sales and leasing/charter have yet to be published.
Compliance Timeline (Yacht Brokers & Real Estate Developers): Yacht brokers and real estate promoters/developers will be required to comply with the new AML obligations once the Article L.561-2 modifications come into force. Thanks to the law’s transitional provision, there is a delayed enforcement period for these professions. The government will set the exact start date by decree, but it must be no later than 10 July 2027. Until that date, yacht brokerage firms and real estate developers are not yet legally bound by the new requirements of Article L.561-2. In practice, this gives these sectors time to prepare for compliance. (There are no additional transitional exemptions specific to these professions beyond this deferred commencement. The only longer delay in the law applies to the football clubs category. These new obligations will enable France to meet similar new EU requirements.
New EU AML Obligations for Yacht Brokers (Effective 2027) - In 2024, the European Union adopted a comprehensive “AML Package” to overhaul its anti-money laundering framework. This package includes a new AML Regulation that will apply directly across all member states from July 10, 2027. It also includes the 6th AML Directive (Directive (EU) 2024/1640), which EU countries must transpose into national law by the same date. Together, these measures aim to harmonize AML/CFT rules EU-wide, closing gaps caused by past national divergences. Crucially, the new rules expand the scope of “obliged entities” – sectors subject to AML obligations – to cover certain high-value luxury industries that were not comprehensively covered before. This expansion explicitly includes yacht brokers and dealers, as traders of luxury watercraft, bringing them under the EU’s AML/CFT regime for the first time on a uniform basis.
Importantly, new rules single out high-value transactions in this sector: brokers involved in selling high-end yachts will have customer identification and reporting obligations triggered when a vessel’s sale price exceeds certain thresholds. For example, any sale of a watercraft for €7.5 million or more (when the vessel is for private/non-commercial use) must be reported to the national Financial Intelligence Unit (FIU) under a newly introduced threshold-based reporting system. (Sales of luxury motor vehicles above €250,000 and aircraft above €7.5 million are similarly reportable.) In short, yacht brokers across all EU states will be fully subject to AML laws – a significant change for an industry where such obligations may have been less uniform previously.
It is notable that the French obligations also cover yacht charters, whereas the EU legislation is currently restricted to sales. Until the EU legislation is in place each country is free to add additional obligations, outside the scope of the EU ones.
These French business will need to comply with the AML framework in addition to international sanctions obligations, applying a strict risk-based approach. This means undertaking a business risk assessment, putting in place procedures, and adjusting due diligence according to the client’s profile and transaction risk: simplified checks for low-risk individuals, standard measures for typical corporate clients, and enhanced due diligence (including independent wealth verification and senior management approval) for high-risk cases such as PEPs or complex structures. Businesses must put in place processes and train staff to conduct ongoing transaction monitoring, regular sanctions screening, maintain detailed records, and promptly file suspicious transaction reports when red flags arise.
It is time to start preparing!
The new French Law also includes a provision making formal approved training obligatory.
For assistance with the new obligations please contact us: consulting@rosemont.mc