Bank Fraud: Towards a National Register of Suspicious Accounts?

On March 31, 2025, the National Assembly passed, in a first reading, a draft law:
https://www.assemblee-nationale.fr/dyn/17/textes/l17t0082_texte-adopte-provisoire.pdf
aimed at strengthening the fight against bank fraud. This initiative follows in particular the ruling of the Court of Cassation on January 15, 2025 (23-15.437):
https://www.courdecassation.fr/decision/6787b9b46ab05acc8d83149d,
which reaffirmed that a bank fulfilling a payment using the IBAN provided by the user meets its obligations.

What does this law propose?

  • The creation of a centralized file of suspicious bank accounts, maintained by payment service providers (PSPs).
  • An obligation for PSPs to report and update this information, under their sole responsibility.

What impact would it have?

  • The liability of PSPs in cases of fraud would remain unchanged (exemption maintained – PSD2, Article L133-21 of the French Monetary and Financial Code).
  • However, a new risk could arise in the event of failure to report fraudulent accounts.

An effective system?

Should this approach, limited to France, complement the “beneficiary verification” service that banks will be required to offer their clients under Regulation (EU) 2024/886:
https://eur-lex.europa.eu/eli/reg/2024/886/oj?locale=fr
which will come into effect on October 9, 2025?

We’ll have to wait and see whether the Senate adopts the proposal and how it will align with European regulations.

Swift
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