France – AMF Guide for Asset Managers

On 18 July, AMF offered guidance for asset managers, UCITS

  • Covers guide to AMF’s expectations regarding compliance at asset manager firms.
  • Guide specifies how various controls within firm are to be operated to control risk.
  • Also addresses how SGPs manage UCITs or AIFs and provide investment services.
  • Updates June. 20 guidance on employees who are seconded within entity group.


  • Self-managed vehicles (UCITS, AIF, etc.) that manages its own portfolio.
  • Investors are reminded that that these legal entities should register with the AMF.
  • And comply with the relevant regulations in terms of reporting.
  • “Scope of the program of operations” presents a concise overview of the activities.
  • Performed by an asset management company; such as order transmission and advice.

E.U. AML Beneficial Ownership Update

Update to address High Risk Countries

On 11 July, the EC issued a letter on the AMLD assessment of high risk third countries.

  • Proposes four stage approach focusing on priority third countries first based on exposure.
  • First stage is develop methodology for assessment, international list to be added to by EC.


Previously reported, on 20 April, the EU Council adopted a position on AML directive, regulation.

Brief highlights of Beneficial Ownership

  • EU States to maintain central registers listing information on beneficial owners and trusts.
  • States may allow public access, can be subject to registration of person, payment of fee.
  • Make accessible without restriction to obliged entity, e.g on bank customer due diligence.
  • To access register, person must demonstrate they have legitimate interest e.g. journalist.
  • Access owner name, month and year of birth, nationality, country of residence, ownership.
  • Central register information on trusts is accessible only to authorities and obliged entities.