Annual Report Highlights France’s Financial Crime Enforcement and International Cooperation

Skadden Publication / White Collar Defense and Investigations

Emmanuel Marsigny Louis Guesdon Margot Sève Guilhem Le Gars Gregory Vianesi

Ten years after its establishment, France’s National Financial Prosecutor’s Office (Parquet National Financier or PNF) has released its 2024 annual report (Report),1 showcasing a year of consolidation and innovation in the fight against complex financial crime.

In the Report, the PNF, whose jurisdiction extends not only to French companies but also to those operating in France, highlights its significant efforts to strengthen international cooperation, with approximately one-third of its cases requiring international legal assistance. Notably, the PNF has enhanced collaboration with the United Arab Emirates, appointing a French liaison magistrate in Abu Dhabi.

Looking ahead, the PNF’s mandate could potentially expand to include the enforcement of economic sanctions, implementing the upcoming EU directive criminalizing violations of economic sanctions rules.

Key Points

With a slight dip in ongoing cases to 766 from 781 in the previous year, the PNF maintained its focus on high-stakes financial crimes, with tax fraud (46.9%) and corruption-related offenses (46.6%) accounting for nearly 94% of its caseload. The office has utilized its investigative resources, including partnerships with specialized agencies, such as the Central Office for the Fight Against Corruption and Financial and Tax Offenses (OCLCIFF), to address these complex cases.

In 2024, the PNF secured 97 convictions, recovering €203.9 million for the French Treasury. The Report raises concerns, however, about an increasing acquittal rate and notes that the underlying causes are being analyzed.

The Report notes a reduction in the number of French Deferred Prosecution Agreements (Judicial Public Interest Agreements or CJIPs) finalized in 2024 (two) compared to the previous year (six). The PNF says it still considers CJIPs an important tool in addressing financial crimes as part of its enforcement strategy, but is selective in their application.

Strengthening International Cooperation in Criminal Matters

The Report notes that international cooperation has been a cornerstone of the PNF’s approach, and the PNF significantly intensified its international cooperation efforts in 2024, reflecting the increasingly global nature of financial crime. The Report highlights that the PNF requires international legal assistance for various investigative actions, such as obtaining bank records, interviewing witnesses or suspects, and seizing criminal assets. The report also states that the PNF employs advanced cooperation tools, including Eurojust (the European Union Agency for Criminal Justice Cooperation) coordination meetings and joint investigation teams.2

The PNF also receives a growing number of legal assistance requests. In 2024, the PNF processed 112 requests, continuing a trend that has seen over 100 annual requests each year since 2021. These solicitations have originated from 77 countries, with Algeria, Poland, and Belgium leading in terms of request volume, but the PNF also received several requests from Switzerland and the United States.

The PNF’s expanding role in cross-border financial crime investigations is further underscored by its efforts to strengthen cooperation with strategic partners. A notable example is the recent focus on enhancing collaboration with the United Arab Emirates (UAE). In addition to the appointment the French liaison magistrate in Abu Dhabi, in November 2024, the PNF’s chief prosecutor participated in a high-level visit to the UAE, engaging with key judicial figures to discuss ongoing assistance requests and streamline processes for executing French requests. The UAE, identified in the Report as a “tax-privileged or financially opaque country,” is ranked 13th in the PNF’s list of countries to which it has most frequently made requests for international criminal assistance, with 17 requests to date.

The strengthening of the PNF’s cooperation with its international counterparts is highly relevant for French companies since, pursuant to the June 2, 2020, Circular of the French Ministry of Justice (Circular), the Ministry expects the PNF to open “mirror investigations” when receiving incoming international cooperation requests related to international corruption involving French companies or companies operating in France.3 The Circular also encourages the PNF to assess the opening of parallel investigations when informed by the Strategic Information and Economic Security Service (SISSE) about foreign proceedings against French companies.4

Toward an Expansion of the PNF’s Mandate To Cover Economic Sanctions?

Looking ahead, the Report notes that the PNF faces several challenges, including an increasingly complex legal landscape and a busy court schedule in 2025.

The Report concludes with the open question of expanding the scope of the PNF’s action to enhance the effectiveness of financial crime enforcement. In particular, as the PNF has previously stated, its mandate could be expanded to the violation of economic sanctions rules, and/or include issues of “presumed” money laundering (présomption de blanchiment). Giving PNF responsibility for economic sanctions enforcement could be part of the implementation into French law of the EU Directive on the criminalization of economic sanctions rules, which is due before May 2025.

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1 Parquet National Financier, Synthèse 2024.

2 The reports notes that several joint investigation teams are currently operational with countries such as Germany, Norway, Ukraine, Estonia, Belgium, Switzerland, Moldova, and the United Kingdom.

3 Circular 2020 F 0028 FAl on criminal policy in the fight against international corruption, §2.2.

4 §1.2 of the Circular.

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