AMF (Autorité des Marchés Financiers — France)

The Autorité des Marchés Financiers (AMF) is France’s securities and financial markets regulator, established by the Financial Security Law of August 1, 2003, which merged the Commission des Opérations de Bourse (COB), the Conseil des Marchés Financiers (CMF), and the Conseil de Discipline de la Gestion Financière (CDGF). The AMF regulates French financial markets, investment products, and market participants, and it serves as France’s designated national competent authority under MiCA. The AMF’s precocious development of a voluntary crypto registration regime — the PSAN framework — gave France one of the more developed supervisory track records in European crypto regulation before MiCA’s full application.

The PSAN Regime: Origins and Structure

France introduced its Prestataires de Services sur Actifs Numériques (PSAN) regime through the PACTE Law (Plan d’Action pour la Croissance et la Transformation des Entreprises) of May 22, 2019. The PACTE Law amended the Monetary and Financial Code to create a regulatory framework for crypto asset service providers, defining the scope of regulated services, establishing registration and licensing procedures, and assigning supervisory responsibility to the AMF.

The PSAN regime was originally structured on two tiers. The first tier — optional full licensing — required applicants to demonstrate comprehensive compliance with operational, governance, cybersecurity, and capital requirements, and in return conferred a French regulatory endorsement that firms could use as a marketing asset. The second tier — mandatory basic registration — initially applied only to a subset of the highest-risk activities (custody and operation of trading platforms involving fiat currency exchange), requiring AML compliance demonstration but not the full operational standards of the optional licence.

Beginning in 2024, France strengthened the mandatory registration requirements and expanded their scope, progressively requiring a wider range of crypto asset service providers to register with the AMF and demonstrate compliance with enhanced AML standards. This evolution reflected both France’s response to FATF requirements and the policy environment created by the pending MiCA transition, which made the PSAN regime a bridge to the EU-wide authorization framework.

Major Registrations

Several major global crypto firms obtained PSAN registration or optional licensing from the AMF during the regime’s operational period. Binance France, Coinbase France (operating as Coinbase SAS), and Crypto.com were among the notable registrants. Binance’s French registration attracted particular attention because Binance.com, the global platform, simultaneously faced regulatory challenges in multiple other jurisdictions including the UK and Germany, making the French PSAN registration one of the few major jurisdiction authorizations the group held at the time.

These registrations gave the AMF supervisory experience with large-scale crypto exchange operations that informed the agency’s approach to MiCA implementation. The AMF published detailed observations from its PSAN supervisory activities, including findings on AML deficiencies, custody arrangements, and consumer communications, creating a public record of supervisory expectations that benefited the broader industry.

Transition to MiCA CASP Licensing

With MiCA entering full application in December 2024, the PSAN regime is being phased out and replaced by the MiCA CASP (Crypto-Asset Service Provider) authorization framework. PSAN-registered firms are subject to a transition period during which they may continue operating under their existing registration while completing the full MiCA authorization process with the AMF as France’s NCA.

The AMF has moved actively to prepare for its NCA role, establishing a dedicated crypto team, publishing MiCA authorization guidance for applicants, and engaging with ESMA’s supervisory convergence process. France has been one of the most active member states in ESMA’s Level 2 technical standards development process, with AMF representatives contributing to multiple working groups and the AMF submitting detailed responses to ESMA consultations.

AMF’s Policy Positions in EU Regulatory Development

The AMF has been notable for the assertiveness of its policy positions in European digital asset regulatory development. The agency has advocated for ESMA to take a robust approach to CASP supervision and for stringent application of MiCA’s asset-referenced token reserve and redemption requirements. The AMF has also engaged actively on DeFi regulatory questions, publishing discussion papers and participating in ESMA’s work on potential future DeFi regulation.

France’s geographic proximity to ESMA’s Paris headquarters and the AMF’s strong institutional relationship with ESMA have positioned French supervisory perspectives prominently in EU-level regulatory debates. The AMF has on several occasions diverged from what it perceived as overly permissive supervisory approaches by other member state NCAs, advocating for consistent and high-standard application of MiCA requirements as a matter of European financial market integrity and investor protection.