New Tracfin-DGCCRF brochure on business domiciliation: the KYC document list in black and white — and what no tool should decide instead of the filer
Tracfin and the DGCCRF published a guidance brochure for domiciliation professionals in May 2026, detailing the documents to collect before entering a business relationship (order of 2 September 2009) and recalling the National Sanctions Commission's record: 19 decisions in 2023, fines from €500 to €50,000. The central message fits in one sentence: the domiciliation provider remains the sole judge of a suspicious-activity report — no tool can substitute for that decision.
The guide gathers into seven fact sheets what the DGCCRF and Tracfin concretely expect from a domiciliation provider, subject since 2009 to anti-money-laundering rules (art. L. 561-2 15° of the Monetary and Financial Code): risk classification, verifying the client's and beneficial owner's identity before signing, vigilance matched to risk profile, five-year document retention. It also details the documents listed by the 2 September 2009 order — ID document, company registration extract under three months old, bylaws, proof of address — that every branch must collect before signing a contract.
What the guide stresses repeatedly is that the decision to file a suspicious-activity report with Tracfin belongs exclusively to the human professional, never to a tool or automated procedure — the Sanctions Commission has already fined domiciliation providers who relied too heavily on an intermediary without their own analysis (19 decisions in 2023, from a simple warning to a €50,000 fine). That's exactly the line AppH builds into its own design: the front-desk assistant can help gather and list the documents expected at check-in, never verify an identity or assess a suspicion.
For AppH
- The front-desk assistant can walk the client through which documents to bring (ID, registration extract under 3 months, proof of address) as soon as the appointment is booked, cutting back-and-forth before signing.
- The assembled file stays reviewable and timestamped for the branch's compliance officer, who keeps full control over the decision to enter the relationship or file a report.
Against / the honest limit
- AppH does not verify or certify any ID document or beneficial owner: that identification work remains, as the Monetary and Financial Code requires, the domiciliation provider's own responsibility.
- The Tracfin-DGCCRF guide is a reference for the whole profession, not an audit of AppH specifically — we don't yet have a measured figure for how much back-and-forth a pilot actually cuts, only qualitative observation from the first client.
What interests us about this document is what it refuses to delegate: the Sanctions Commission fined domiciliation providers who let an intermediary decide for them. That's exactly the line we draw — an assistant that prepares the file, never an algorithm that judges a suspicion.
Reviewed by a human at AppH