France: Implemented AMF doctrine on PSANs to clarify the transitional provisions towards "enhanced registration"

On 19 July 2023, the Financial Markets Authority (AMF) of France updated its doctrine concerning the registration regime for digital assets services providers (PSAN), implementing the provisions outlined in the Bill containing provisions to incorporate European Union law in the areas of economy, health, work, transport and agriculture (DDADUE Law). The DDADUE Law includes registration and operational licence requirements which come into force on 1 January 2024. The AMF updated its doctrine to clarify the transitional provisions related to the "enhanced registration" regime established by DDADUE Law. According to the updated doctrine, PSANs that completed their registration application filing before 1 July 2023 and were considered complete by the AMF will undergo the previous registration procedure. The entities that haven't submitted a complete registration dossier before 1 July 2023 must update and complete their dossier to comply with the "enhanced registration" provisions. Additionally, if an already registered PSAN applies for an extension to offer a new service from 1 July 2023 onwards, it will be subject to the "enhanced registration" requirements for all services provided, including those for which it was previously single registered. Under the "enhanced registration," the entities have to prove compliance with the requirements on anti-money laundering, internal controls, cybersecurity, conflicts of interest, governance standards, reporting to regulators, and rules on the segregation of funds.