An extract from French and EU sanctions and PEP lists establishes, at a fixed point in time, whether a named individual or entity appears on any controlled list. This is a factual retrieval, not a legal opinion. The result either confirms a listing, confirms absence of a listing, or identifies a match requiring further disambiguation. Control over a company — who directs it, who owns it, who can bind it — is only meaningful if the persons exercising that control are not subject to asset freezes or transaction restrictions. That is the function this extract serves.
What it showsWhether a named person or entity appears on EU consolidated sanctions lists, French national lists (GAFI/TRACFIN-adjacent designations), and PEP classification databases as of the extraction date. Primary sourceEU Financial Sanctions Files (European Commission, DG FISMA) · verified 2026-09-10 Secondary sourceFrench national sanctions list maintained by the Direction générale du Trésor · verified 2026-09-10 Access conditionThe EU consolidated list is publicly downloadable without registration. The French national list is published on the Trésor website. What is paid for is the structured cross-referencing, disambiguation, and documented retrieval path. What it does not showInformal designations, pending designation procedures, or listings on non-EU third-country lists not incorporated into the EU framework.This register is public and free of charge. What is paid for is the removed path: registration, national identifier, language, electronic signature, declaration of legitimate interest — and, in this case, structured cross-referencing across multiple list sources with documented disambiguation and a timestamped retrieval record.
Source: EU Financial Sanctions Files (DG FISMA) · Direction générale du Trésor · extracted 2026-09-10
What a sanctions and PEP extract covers in France
France operates within the EU sanctions framework. The primary instrument is the EU consolidated list of financial sanctions, maintained by the European Commission under Council Regulation (EC) No 2580/2001 and subsequent regulations. This list is updated without fixed schedule; updates occur when the Council adopts a new designation decision.
Alongside the EU list, the Direction générale du Trésor publishes French national designations. These cover individuals and entities designated under French autonomous measures, including those arising from FATF mutual evaluation commitments. The two lists are not identical. An entity absent from the EU list may appear on the French national list, and vice versa.
PEP classification in France follows the definition in the Fourth and Fifth Anti-Money Laundering Directives, transposed into French law under the Code monétaire et financier. PEP status is not published in a single official register. It is derived from public function databases, official gazettes, and parliamentary records. A PEP extract is therefore a structured analytical output, not a direct registry download.
The extract produced under this service covers:
- EU consolidated financial sanctions list (all designation categories)
- French national sanctions list (Direction générale du Trésor)
- PEP classification based on public function records and official gazette entries
- Adverse media flags at Extended tier (see scope table below)
Source: European Commission DG FISMA — EU Financial Sanctions Files · extracted 2026-09-10
The structure of the French sanctions framework
The EU consolidated list is the operative instrument for most cross-border transactions. It is published as a structured XML file and updated on an irregular basis. The file contains full name, date of birth where known, aliases, and the legal basis for designation.
French national designations are published in the Journal officiel de la République française and on the Trésor website. They are not always mirrored in the EU list. For a counterparty operating primarily in France, checking only the EU list is insufficient.
OFAC, UN, and other third-country lists are not part of the French domestic framework. They are included at Extended tier as a separate layer, clearly labelled as non-French, non-EU sources.
| List | Operator | Update frequency | Included at |
|---|---|---|---|
| EU consolidated financial sanctions | European Commission, DG FISMA | Irregular, upon Council decision | Signal, Standard, Extended |
| French national designations | Direction générale du Trésor | Irregular, upon ministerial order | Signal, Standard, Extended |
| PEP classification (FR public functions) | Derived from JO, parliamentary records | Continuous | Standard, Extended |
| UN Security Council consolidated list | UN 1267/1988/2253 Committee | Irregular | Extended |
| OFAC SDN and other US lists | US Treasury | Irregular | Extended |
| Adverse media screening | Open sources, structured | At time of extraction | Extended |
Source: Direction générale du Trésor · extracted 2026-09-10
The limit of what the sources allow
The EU consolidated list and the French national list are static at the moment of extraction. A designation adopted the day after extraction will not appear in the result. This is not a monitoring service; it is a point-in-time retrieval.
PEP classification depends on the completeness of public function records. An individual who held a qualifying public function but whose appointment was not published in the Journal officiel — or was published under a name variant — may not be identified. The extract states the sources checked and the name variants searched. It does not certify the absence of a PEP connection beyond those sources.
The French national list is published in French. Name transliteration from Arabic, Cyrillic, or Chinese scripts introduces ambiguity. The extract documents the transliteration standard applied and flags cases where a match is uncertain.
Pending designation procedures are not public. An individual or entity under active investigation for designation does not appear on any list until the designation is formally adopted. The extract cannot establish what is not yet published.
Sanctions evasion through nominee structures is outside the scope of this extract. The extract checks named individuals and entities. If the beneficial owner is concealed behind a nominee, the extract will show the nominee as unlisted — which is accurate but incomplete. That gap is addressed by a separate ownership structure report, not by this extract.
The ceiling of what the sources allow is stated before payment. No result is guaranteed beyond what the listed sources contain at the time of retrieval.
Where the sources disagree
The EU list and the French national list are maintained independently. Discrepancies arise in three patterns:
Name variants. The EU list may use a different transliteration than the French national list. Both entries may refer to the same individual. The extract documents both entries and flags the match as probable or confirmed.
Designation scope. An individual may be designated on the French list for reasons that do not meet the threshold for EU-level designation. The extract records the basis for each listing separately.
Removal timing. Delisting from the EU list and delisting from the French national list are separate administrative acts. An individual removed from the EU list may remain on the French list for a period. The extract records the status on each list independently.
Source: EU Financial Sanctions Files · Direction générale du Trésor · extracted 2026-09-10
Scope and fixed price
| Tier | Price | What is included | What is NOT included |
|---|---|---|---|
| Signal | €440 | EU consolidated sanctions list check; French national list (Trésor) check; name variant search (standard Latin script); timestamped retrieval record; PDF output | PEP classification; UN and OFAC lists; adverse media; non-Latin script transliteration review |
| Standard | €890 | All Signal items; PEP classification from French public function records and JO; non-Latin script transliteration review; match disambiguation report | UN and OFAC lists; adverse media screening |
| Extended | €1,800 | All Standard items; UN Security Council consolidated list; OFAC SDN and other US lists; adverse media screening (structured, open sources); summary memo on findings | Legal qualification of findings; monitoring after delivery date |
Timeline: Signal — 2 business days. Standard — 3 business days. Extended — 5 business days. Timelines run from confirmation of subject details.
FAQ
Does a clean result on the EU list mean the counterparty is not sanctioned? Not necessarily. The French national list and third-country lists (UN, OFAC) are separate instruments. A clean EU list result covers only EU-level designations. Standard and Extended tiers check additional lists.
How current is the extract? The extract reflects the state of each list at the time of retrieval, documented in the timestamped record. Lists are not monitored after delivery. If ongoing monitoring is required, that is a separate engagement.
What if the subject's name appears in multiple scripts? Signal tier covers standard Latin script. Standard and Extended tiers include non-Latin script transliteration review. The extract documents the transliteration standard applied and flags uncertain matches.
Is PEP status published in an official French register? No. PEP classification is derived from public function records, the Journal officiel, and parliamentary databases. There is no single official PEP register in France. The extract documents the sources checked.
Can the extract be used for AML compliance purposes? The extract is a factual compilation from official sources. Whether it satisfies a specific AML compliance requirement depends on the applicable regulatory framework and the policies of the institution concerned. That determination is outside the scope of this service.
What is the difference between Signal and Standard for a French counterparty? Signal covers the two primary lists — EU consolidated and French national. Standard adds PEP classification, which is material for any counterparty who holds or has held a qualifying public function in France or another jurisdiction.
Sources
- EU Financial Sanctions Files — European Commission, DG FISMA — https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/overview_en — extracted 2026-09-10
- French national sanctions list — Direction générale du Trésor — https://www.tresor.economie.gouv.fr/services-aux-entreprises/sanctions-economiques — extracted 2026-09-10
- Journal officiel de la République française — Légifrance — https://www.legifrance.gouv.fr — extracted 2026-09-10
- UN Security Council consolidated list — https://www.un.org/securitycouncil/content/un-sc-consolidated-list — extracted 2026-09-10
- OFAC Specially Designated Nationals list — US Department of the Treasury — https://ofac.treasury.gov/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists — extracted 2026-09-10
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Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. VLO Law Firm assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.
Author: Elena Moretti — Partner, Continental Europe, VLO Law Firm
