Registre national des gels — asset freezes in France

In France, an asset freeze is not a risk-based control: it is an obligation of result, and the reference list that decides it is the Registre national des gels kept by the Direction générale du Trésor. This guide explains what the register contains, what the Code monétaire et financier (CMF) requires a payment or e-money institution to do when a name matches, the three declarations DG Trésor expects, and how the joint DG Trésor–ACPR guidelines updated on 16 March 2026 treat instant payments, homonyms and circumvention.

1. What the Registre national des gels is

Article R. 562-2 CMF establishes a national register of the persons and entities subject to asset-freezing measures. DG Trésor maintains it, and it covers every freeze in force on French territory, whatever its source: United Nations Security Council designations, EU restrictive-measures regulations and national freezes adopted under articles L. 562-2 and following of the CMF. It also lists vessels.

The register is published at gels-avoirs.dgtresor.gouv.fr. According to DG Trésor’s FAQ, it can be searched by keyword across all fields, filtered, exported as a time-stamped PDF, and consumed in JSON or XML through an API. Each record carries identifiers — names, aliases, dates and places of birth, nationalities, identity and passport numbers, registration numbers and SWIFT codes for entities, IMO numbers for vessels, and crypto-asset addresses where known — together with the legal basis and any EU or UN reference. Aliases judged unreliable are flagged as “alias faible” in the comments field.

2. Four legal sources, one register

The 2026 guidelines describe the layers a screening programme must cover. The register is the one place where all of them appear together.

National freezes are decided by arrêté — jointly by the ministers of the economy and the interior for the terrorism-related regime — and published in the Journal officiel. The guidelines note that addresses are not printed in national arrêtés for confidentiality reasons, which matters when you try to clear a match.

3. The duties on a payment institution

Article L. 562-4 CMF obliges every person covered — including the obliged entities listed in article L. 561-2 — to apply freezes and prohibitions on making funds available sans délai, and to inform the minister for the economy immediately. Article L. 562-4-1 and article R. 562-1, with articles 11 and 12 of the arrêté of 6 January 2021, add the organisational layer: written procedures, adequate staff and systems, training, internal control, and a system to detect operations that circumvent freezes.

The guidelines stress three consequences. First, there is no risk-based approach to freezing itself: a self-declaration from the customer that they are not designated does not discharge the firm. Second, alerts must be handled without delay — an ACPR sanctions decision of 16 May 2023 (no. 2022-04) held that processing times of several days or weeks are incompatible with that standard. Third, the obligation reaches activity carried on under the freedom to provide services or through branches in other EEA countries, and branches in third countries.

The guidelines also tie the French rules to EBA Guidelines 2024/14 and 2024/15 on restrictive measures: payment service providers should assess their exposure to restrictive measures, in writing, and update that assessment whenever needed and at least once a year. The exposure assessment sizes the system; it does not soften the obligation of result.

4. The three declarations to DG Trésor

DG Trésor publishes three forms on its sanctions pages and receives them at the national-list mailbox it lists there. Each has a distinct trigger.

The freeze declaration covers every implementing action: freezing an account, operation or contract; any credit to a frozen account; suspending a transfer to a designated person; refusing to enter a relationship or execute an occasional transaction; and attempted circumvention. You do not ask DG Trésor to confirm a freeze before applying it — you apply it and then declare. A transaction later found to have breached a freeze must also be reported to DG Trésor, without prejudice to informing the ACPR as an incident.

Freeze declarations do not replace TRACFIN. Where transactions executed before the freeze, or linked relationships, fall within article L. 561-15 CMF, a déclaration de soupçon is due as well.

5. Clearing an alert: what to compare

The guidelines define homonymy broadly: identical spelling of name or alias, or different spelling that is phonetically close, typically through transliteration. For a natural person, compare names (usage and birth), aliases, sex, date and place of birth, nationalities, country of residence, address, identity document numbers and profession. For an entity, compare name and trade name, registered office, object and activity, incorporation date and country, register number, phone and website, directors and shareholders.

An alert on a payment flow means the operation is suspended until the alert is fully processed. Where data is missing, the firm must make best efforts: ask the customer, ask the other payment service providers in the chain, and check public sources such as the JORF, the JOUE, Infogreffe, the RCS and the RBE. Payment message data required by Regulation (EU) 2023/1113 is part of the evidence. Everything — the classification, the requests for information and the exchanges with DG Trésor — must be documented.

6. Instant payments: screen the customer base daily

The 2026 update incorporates Regulation (EU) 2024/886 on instant credit transfers in euro. Under article 5d of the SEPA Regulation (Regulation (EU) No 260/2012) as amended, PSPs offering instant credit transfers verify whether their payment service users are subject to EU freezes immediately after any new or amended measure takes effect, and at least once per calendar day. The guidelines apply the same rhythm to the French lists: the customer base is screened immediately after any change to the national or EU lists and at least daily.

Instant credit transfers themselves are not screened against EU lists. The guidelines carve out cross-border instant transfers checked against the French national freeze lists, unless the PSPs concerned each have a system that detects, before execution, cross-border transfers whose payer or payee is designated on those lists.

7. Partial releases and challenges

For national freezes, article L. 562-11 CMF allows partial release authorisations for a natural person’s particular material needs, for an entity’s activity compatible with public order, for decisions preserving the assets, and to execute court decisions in favour of third parties. Requests go to DG Trésor; for the terrorism, interference and drug-trafficking regimes the economy and interior ministers decide jointly. A firm may not release funds on a customer’s say-so: it executes only an authorisation it has received. DG Trésor’s page states that a national freeze can be challenged within two months of notification, administratively or before the Paris administrative court.

Breaching a freeze is a criminal offence: article 459 of the Customs Code for EU measures and article L. 574-3 CMF for national ones, with up to five years’ imprisonment and confiscation, and corporate liability under the Criminal Code. Good-faith decisions taken after a homonymy or circumvention declaration with persistent doubt do not engage the firm’s liability, according to the guidelines.

8. Three worked scenarios

Scenario one — a UN designation on a Friday evening. The Security Council designates an individual; DG Trésor enters the identifiers in the national register that evening. Rule: art. L. 562-3-1 CMF — the freeze applies from the register entry. What the firm does: its list feed ingests the register update the same night and re-screens the customer base; one customer matches on name, date of birth and passport number. Outcome: the account is frozen at once and a déclaration de gel goes to DG Trésor; the firm does not wait for the EU implementing regulation.

Scenario two — an inbound SEPA transfer for a near-match. A credit transfer arrives for a customer whose name transliterates close to a designated person; the date of birth in the file is 1 January of the current year. Rule: guidelines §§162-167. What the analyst does: holds the credit, asks the customer for an identity document and the payer’s PSP for details, and checks public sources. The address and profession do not match but the doubt cannot be removed. Outcome: a déclaration d’homonymie with the evidence; DG Trésor either clears it, confirms it, or leaves the decision to the firm, which records its reasoning and, if suspicion remains, files with TRACFIN.

Scenario three — a relative’s account starts paying the designated person’s bills. After a freeze on a customer, a sibling’s account at the same firm begins paying the designated customer’s rent and school fees. Rule: guidelines §§186-187 and art. R. 562-3 II 2° CMF. What compliance does: reviews related relationships, holds the next payment, and sends a déclaration de suspicion de contournement to DG Trésor and a report to TRACFIN. Outcome: the payments stop unless an authorisation under article L. 562-11 covers them.

9. FAQ

10. What to do, today

• Connect your screening to the register API, or prove your vendor list matches it on the day of each update.
• Write the ten-working-day UN rule into the list-management procedure.
• Prepare the three DG Trésor forms as templates, with owners and a target time for each.
• Set alert-handling targets in hours, not days, and record each clearance decision with its evidence.
• Document your restrictive-measures exposure assessment and review it at least once a year.

Related: EU asset-freeze reporting · Sanctions screening for instant payments · ERMES and the déclaration de soupçon