Subsection 8: Obligations in the event of a low risk of money laundering or terrorist financing

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Article R561-14-1-1

French Monetary and Financial CodeIn force

Updated 5 Nov 2023

I. - Electronic money issuers referred to in 1°, 1° ter and 1° quater of Article L. 561-2 may defer verification of the identity of their customer and, where applicable, of the customer's beneficial owner, where the following conditions are met:

1° There is no suspicion of money laundering or terrorist financing ;

2° The customer may not hold another instrument of the same type from the same issuer;

3° The electronic money instrument may only be loaded by a means of payment issued by a person mentioned in 1° to 1°c of Article L. 561-2 whose holder has been identified and had his identity verified in accordance with the provisions of Articles R. 561-5 and R. 561-5-2, or by a transfer of funds from an instrument governed by this Article and issued by the same issuer;

4° The electronic money instrument may only be used by natural persons and for the following purposes:

a) Issuing funds transfers to a person holding an electronic money instrument issued by the same issuer;

b) Receiving transfers of funds issued by another person holding an electronic money instrument issued by the same issuer;

c) Purchase consumer goods or services from identified persons whose identity has been verified by the issuer in accordance with the conditions set out in articles R. 561-5 to R. 561-5-2, or make donations to identified non-profit organisations whose identity has been verified in accordance with the same conditions;

d) Issue fund transfers to a deposit account or payment account opened with a person mentioned in 1° to 1°c of Article L. 561-2 who is established in a Member State of the European Union or in a State party to the Agreement on the European Economic Area;

5° The contract concluded between the issuer and the holder of the electronic money instrument indicates that this instrument is governed by Article R. 561-14-1-1.

II. - The verification referred to in I shall be carried out no later than twelve months after the date of issue of the electronic money instrument. However, it shall be carried out immediately, before the expiry of this period, if one of the following conditions is met:

1° The monetary value loaded onto the electronic money instrument or the payments made exceed €150 over a period of thirty days;

2° The cumulative amount of all the deposits exceeds €1,000;

3° The electronic money instrument is used to make a payment transaction for the purchase of consumer goods or services for which the unit amount exceeds €50, initiated over the Internet or by means of a remote communication device;

4° The fund transfers referred to in d of 4° of I exceed €50 per transaction or a cumulative amount of €150.

Mariela Petrova

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Working with a corporate lawyer in France — Q&A

Any time a strategic decision changes how the company is owned, governed or contractually bound — incorporation, fundraising, M&A, restructuring, shareholder agreements, or major commercial contracts. Earlier engagement always costs less than later remediation.

A notary (notaire) is a public officer who authenticates specific deeds (mainly real-estate transfers and certain family-law acts). A corporate lawyer (avocat) advises on strategy, negotiates and drafts company documents, and represents you in disputes. The two roles complement rather than overlap.

Yes — most of our clients are foreign suppliers, investors or holding entities. We bridge the gap between French law and your home jurisdiction's expectations and deliver everything bilingually.

The SAS (Société par Actions Simplifiée) is the default choice for most international structures: flexible governance, single shareholder allowed, no minimum capital, and works cleanly with foreign holding entities. We assess SARL, SA, SCI on the merits when the situation calls for it.

Yes — communications with a French avocat are protected by the secret professionnel (Article 66-5 of the Law of 31 December 1971). This protection is broader than the common-law attorney-client privilege and applies to written and oral exchanges.

We work on fixed fees for clearly scoped engagements (incorporation, contract drafting, audits) and on monthly retainers for ongoing advisory. Hourly billing is the exception, not the default. You always know the cost before work starts.

Typical timeline is 2–3 weeks from KYC kick-off to RCS registration, assuming standard documentation. Holding-company structures, foreign-shareholder identification or in-kind contributions can extend this — we flag the gating items at the first meeting.

Absolutely. We routinely coordinate with your in-house counsel, expert-comptable or notaire — pragmatic collaboration is the norm, not the exception. We send them everything they need to do their part without duplicating work.

Mariela Petrova

Mariela Petrova

Avocate au Barreau de Paris

Toque #C2396

15+ Years In Corporate Practice

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Communications protected by professional secrecy — secret professionnel de l'avocat, Article 66-5 of the Law of 31 December 1971.

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