Enhanced KYC Obligations: What Brokers Need to Know in 2025
Summary: Since January 2025, the ACPR and MIVILUDES have tightened anti-money laundering and counter-terrorism financing (KYC) regulations. This article deciphers the new enhanced due diligence requirements for brokers and wealth management advisors: lower identity verification thresholds, increased controls for so-called “high-risk” clients.
Regulatory Context: Stricter Rules Expected in 2025
The fight against money laundering and terrorist financing (AML-CFT) remains a priority for French and European authorities. The Autorité de Contrôle Prudentiel et de Résolution (ACPR), in conjunction with MIVILUDES, has revised the regulatory framework for insurance brokers and wealth management advisors (WMAs). Since January 1st 2025, these professionals must apply new enhanced due diligence obligations when establishing and throughout the business relationship.
New Identity Verification Thresholds
One of the main changes concerns the lowering of identity verification thresholds for clients and beneficial owners. From now on, brokers must systematically verify identity as soon as the transaction or deposit reaches 500 euros, compared to 1,000 euros previously. This measure aims to reduce the risk of concealing suspicious transactions through fragmented amounts.
- Identity documents: Valid official ID and proof of address required as soon as the threshold is reached.
- Document verification: Obligation to use enhanced authentication systems (electronic signature, biometric comparison, etc.).
- Archiving: Supporting documents must be kept for at least 5 years after the end of the business relationship.
Identification and Management of High-Risk Clients
Brokers and WMAs must now implement specific procedures for clients presenting a higher risk of money laundering or terrorist financing. The ACPR defines as “high-risk” clients:
- Politically exposed persons (PEPs) or close associates of PEPs.
- Clients domiciled in countries classified as high-risk by the FATF or the European Union.
- Clients with complex legal structures or non-transparent financial activities.
For these clients, obligations are reinforced:
- Enhanced analysis: In-depth examination of the origin of funds and justification of the legitimacy of transactions.
- Periodic checks: Reassessment of the situation and updating of documents at least every 12 months.
- Hierarchical validation: Systematic approval by a compliance officer before any relationship is established or significant transaction is carried out.
New Tools and Procedures to Implement
To meet these requirements, brokers must adapt their organization and tools:
- Enhanced training: Raising awareness among all employees of new risk typologies and warning signs.
- Digitalization: Implementation of digital KYC solutions enabling automatic verification and traceability of controls.
- Internal procedures: Updating procedure manuals and communicating new rules to all staff.
- Reporting: Systematic reporting to TRACFIN in case of suspicion, with monitoring of sensitive cases.
Sanctions and Issues for the Profession
Failure to comply with these new obligations exposes brokers to increased administrative and criminal penalties: fines, withdrawal of license, and even legal proceedings. Beyond the punitive aspect, these measures aim to strengthen trust in the insurance and wealth management sector, protecting clients and the integrity of the market.
Conclusion: Anticipate and Prepare
In light of these regulatory developments, it is essential for brokers and WMAs to anticipate and prepare by adapting their practices now. Increased vigilance and rigorous compliance are becoming vital competitive advantages for operating securely in 2025 and beyond.
