Suspicious activity report (SAR / TRACFIN)
A legal obligation on all professionals subject to AML/CTF regulation, including IOBSP brokers, to report to TRACFIN (the financial intelligence unit of the French Ministry of Economy) any transaction or situation suggesting illicit origin of funds or terrorist financing. The report is confidential and the client must not be informed of it. Failure to comply is a criminal offence.
Key points
Frequently asked questions
In what situations must a broker file a suspicious activity report?
A report must be filed as soon as reasonable grounds exist to suspect that the client's funds have an illicit origin, or that the transaction could contribute to terrorist financing. Typical red flags include a down payment without coherent supporting evidence, transfers from high-risk countries, or a project plainly inconsistent with the declared assets.
Why is it forbidden to inform the client that a suspicious activity report has been filed?
The confidentiality of the report is a legal requirement designed to prevent the suspect from concealing evidence, transferring funds, or disappearing before TRACFIN can act. Disclosing the existence of a report is itself a separate criminal offence, regardless of the merits of the suspicion.
What is the difference between a suspicious activity report and an internal alert note?
An internal alert note is a risk management tool internal to the broker's organisation (compliance team, manager) and carries no legal weight as such. A suspicious activity report is a formal act transmitted to TRACFIN via its secure Ermes portal; it triggers a legal processing obligation and shields the reporting broker from defamation liability.
In practice
A borrower presents an €80,000 cash deposit made to their account the week before file submission, with no evidence of its origin; the broker suspends processing and transmits a suspicious activity report to TRACFIN before taking any banking steps.
Official sources
- Article L561-15 CMF (report to TRACFIN) · Légifrance
- TRACFIN — Financial intelligence unit · Ministère de l'Économie
- Article L519-1 of the Monetary and Financial Code · Légifrance