Country Manual Private Banking
France
out of Bank’s Country of Establishment (Def, RS, BT & RT)
| Source of changes | Answers |
|---|---|
| Law / Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | No |
Regulatory Template, Regulatory Summary and Behaviour Template
Material changes
The documents have been reviewed, and we can confirm that there have been no relevant regulatory developments implying material changes since the last update of this Country Manual.
Non-material changes
With regard to reverse solicitation, the Regulatory Summary now states that French authorities comply with ESMA’s reverse solicitation guidelines in connection with MiCA regulation. The aim is to remind that, also with regard to reverse solicitation in relation to investment services, the AMF may take into consideration ESMA’s MiCA guidelines, which provide for a narrow interpretation of the concept of reverse solicitation.
To reflect the strict approach of the French authorities with regard to reverse solicitation, in particular for contacts taking place on the French territory, investment-related prospecting activities with Qualified prospects are now a grey zone.
In the Behaviour Template, the condition “on an occasional basis” has been added to socialising activities in France, to remind that any kind of activity taking place on the French territory could be considered a relevant element in application of the “bundle of indicators” method. Thus, even for simple socialising activities, it is recommended to avoid a too regular presence in France.
Further non-material developments and amendments have been made throughout all the documents.
Regulatory Summary
This document has now a more user-friendly layout and reflects the changes contained in the RT.
BT Short Comparison
This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “FRANCE” in the Target Country Field.
The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.
For more information, please contact us: info@brpsa.com
Geneva, October 16th, 2025