Editor’s Note
This article outlines the role of France’s COLB, the national steering committee for anti-money laundering and counter-terrorist financing (AML/CFT). The committee, serviced by the Treasury, is central to coordinating the country’s risk assessment and response in this critical area of financial security.
The Directorate General of the Treasury (DG Trésor) provides the secretariat for the COLB, the coordinating body for the national system to combat money laundering and the financing of terrorism (AML/CFT). It is notably responsible for conducting the national risk analysis in the fight against money laundering and terrorist financing.
The mandate of the COLB, as defined in Article D. 561-51 of the Monetary and Financial Code, is:
– To ensure the coordination of state services and supervisory authorities involved in the fight against money laundering and terrorist financing and to strengthen information exchange between actors in the preventive and repressive aspects.
– To promote consultation with the various professions subject to customer due diligence obligations.
– To propose improvements to the national system for combating money laundering and terrorist financing aimed at feeding an inter-ministerial action plan, to monitor its implementation, and to assess its effectiveness.
– To establish and regularly update a national risk analysis aimed at identifying, understanding, and assessing the risks of money laundering and terrorist financing to which France is exposed and to propose mitigation measures for these risks.
– To consolidate relevant statistics to illustrate the effectiveness of the French system, with a view to their publication within an annual report.
The COLB is chaired by a qualified individual jointly appointed, for a renewable three-year term, by the Minister of the Economy and the Minister of the Budget, after consultation with the Minister of the Interior and the Keeper of the Seals, Minister of Justice.
This body has been successively chaired by: Philippe Jurgensen (creation-June 2013), Bruno Parent (December 2013-June 2014), Jérôme Fournel (October 2015-May 2017), Pierre-Mathieu Duhamel (June 2018-March 2019) and Didier Banquy (since May 2019).
The Directorate General of the Treasury provides its secretariat (Secfin 1 office).
The President of the COLB plays a decisive role in steering this work, ensuring, with the support of the secretariat provided by the DG Trésor, effective coordination among the multitude of stakeholders, whether other ministries or private sector professionals.
To ensure effective mobilization of its members, the COLB meets monthly in plenary session. Restricted format meetings may also be organized.
The COLB brings together all competent authorities in AML/CFT, from the preventive aspect (AML/CFT regulator, AML/CFT supervisory and sanctioning authorities, and self-regulatory bodies) to the repressive aspect (intelligence, investigations and prosecutions, confiscations), including the financial intelligence unit (Tracfin). The detailed list of the thirty members is available in the Monetary and Financial Code (Article D561-53).
The national risk analysis constitutes the cornerstone of the system to combat money laundering and terrorist financing.
The work aims to cross-reference money laundering threats, i.e., the main sources of illicit income, with vulnerabilities that can be exploited by criminals. Nine working groups have been established: four related to threats (criminal threats; tax and social fraud; corruption; terrorist financing), three related to vulnerabilities (related to the identification of the beneficial owner; financial actors and products; non-financial professions), and two related to factors aggravating vulnerabilities (economic activity sectors; geographical sectors). They involved representatives from numerous ministries and the private sector. Questionnaires were also sent to supervisory and sanctioning authorities and to professionals subject to AML/CFT obligations, to assess the level of vigilance among professionals and the quality of the countermeasures implemented.