French sanctions body fines a domiciliation provider: none of the 15 client files inspected held a proof of address
On 1 July 2026, France's National Sanctions Commission (CNS) sanctioned a small domiciliation company in the Alpes-Maritimes, four years after an inspection by the DGCCRF, the French consumer-protection and fraud authority: a 12-month suspended ban and €30,000 in fines in total. Almost everything the decision faults can be read in the client files.
Decision no. 2024-07, published by the CNS, concerns a non-trading company in Antibes, licensed since 2018, with no employees, that provided a registered address to about fifteen businesses. The DGCCRF inspection took place on 2 February 2022; the Commission upholds six findings, none contested at the hearing. The internal procedure fitted on one page, with no risk classification. Of 15 files, 5 held no document showing that the directors' identity had been verified and 3 none for the beneficial owners; none contained a proof of address, "a key element of knowing the client" according to the decision; 2 had not been updated after a transfer of the business. Two relationships, property structures with several intermediaries, should have triggered enhanced due diligence and a suspicious-activity report. The penalty: a 12-month suspended ban from domiciliation work for the company and its two co-managers, a €6,000 fine for the company and €12,000 for each of them.
For a network of several branches, the lesson is first a practical one: what gets inspected is the file, and a file empties quietly. An ID document expires, a proof of address was never requested, a director changes and the record does not follow. The decision also notes that at the hearing, in June 2026, the anti-money-laundering training certificate covered only one of the two co-managers. Tracking which documents were received, their dates and what is missing, client by client and branch by branch, is repetitive work a tool can prepare. Assessing a risk, stepping up due diligence or filing a report remains the job of a responsible person.
For AppH
- In our domiciliation module, every new client starts with five documents marked "missing" (company registration extract, director's ID, proof of address, bank details, articles of association), and the file stays "incomplete" while one is missing. Expiry dates are recorded and the tool flags what is about to expire.
- The tool can prepare a reminder to the client about a missing or expired document; it is sent only once the branch approves it. The file keeps a dated record of each document, which is what an inspection asks you to be able to show.
Against / the honest limit
- AppH verifies no identity, assesses no money-laundering risk, decides on no enhanced due diligence and files no report to Tracfin: the tool keeps things in order and sends reminders, a responsible person at the branch judges and decides.
- A complete file is not enough: the most serious findings in the decision concern the analysis of two high-risk relationships, which only a trained person can carry out. No software replaces the risk classification or the training required of managers.
Four years between inspection and sanction: today's files will be judged as they stand today. A domiciliation network gains from seeing the state of every file at all times, document by document and branch by branch. Our rule does not change: the tool keeps the file up to date and points out what is missing, the responsible person decides.
Reviewed by a human at AppH