French regulator fines Banque Delubac €600,000 for anti-money laundering failures
France’s banking watchdog, the ACPR, has fined Banque Delubac & Cie €600,000 and issued a formal reprimand over shortcomings in its anti-money laundering and counter-terrorism financing systems.
The ACPR Sanctions Commission said in a statement that it found the bank’s automated transaction monitoring system ‘did not take into account all the information necessary to detect atypical operations’ by clients, thereby failing to meet due diligence requirements.
The regulator also determined that Delubac ‘did not fully comply with its obligations regarding processing and analysis deadlines for alerts’ and that some client accounts were closed for anti-money laundering reasons ‘without systematically examining the need to conduct enhanced due diligence or submit a declaration to Tracfin’, France’s financial intelligence unit.
The regulator identified additional shortcomings in the bank’s compliance with enhanced and additional due diligence obligations, internal controls, and asset freezing procedures. It stressed that implementing an effective system was an essential requirement and that regulated institutions must ensure their systems actually work, not just implement procedures.
ACPR found the bank failed to conduct required enhanced due diligence reviews and to inform Tracfin of certain transactions ‘without delay’ as required by law.
In determining the penalty amount, the commission considered ‘the seriousness and duration of the breaches’ but also took into account ‘the significant corrective actions recently undertaken by Banque Delubac and the financial position of this institution’, which recorded a loss during the 2024 financial year.
Nicolas Burnichon, Counsel at the law firm of Bennink Dunin-Wasowicz in Paris, said the penalty represents moderate enforcement action in the French context, noting that over the past five years, the ACPR sanctioned between three and 12 financial institutions per year with an average of €1.4 million in fines.
‘However, it is also noted in the decision that the bank invested €3 million since 2020 to adopt and implement efficient financial security mitigation measures, including €800.000 in AML tools development alone,’ he explained. ‘These expenses were taken into consideration by the ACPR in the calculus of the final fine. Overall, the total amount is therefore significant, especially for a small bank.’
The decision will be published in the ACPR register for five years, identifying the bank by name. The ruling was issued on 19 June but announced publicly only last week.
The enforcement action carries broader implications for the French banking sector, Burnichon said.
‘These sanctions being pretty rare, they are always seen as a strong signal sent to other financial institutions and a good reminder of the main issues banks usually face in implementing robust internal compliance frameworks,’ he explained.
Banque Delubac did not respond to an email for comment.
