Inside France’s Battle Against Financial Crime: TRACFIN Uncovers 17 Sophisticated Money Laundering Techniques

Criminals are constantly adapting, and TRACFIN’s latest AML/CFT Threat Assessment for 2023–2024 lays bare the seventeen distinct methods currently being used to launder illicit funds in France and internationally. With case studies spanning sectors from real estate and gambling to crypto-assets and the art market, the report is a wake-up call to compliance professionals who must stay ahead of evolving financial crime risks. This in-depth look from TRACFIN—a key French intelligence agency—delivers tactical insights into how illicit money moves through legitimate systems, and how public-private collaboration remains key to fighting financial crime.

TRACFIN’s approach centers on typologies derived from real-world cases, allowing investigators and compliance teams to link predicate offences, laundering mechanisms, and economic sectors. This classification system, according to the agency, helps benchmark control systems and “spot emerging trends” with greater precision.

A notable concern involves accounting manipulation, where criminal actors hide dirty money behind doctored financial statements. One case highlighted by TRACFIN involved a publicly listed company issuing a €20 million share premium for what amounted to non-functional software, supported by manipulated ledgers and “parallel flows of funds and falsified records.” The purpose: reduce tax obligations and disguise illicit revenue. The report flags classic warning signs—such as high-value invoices for suspicious business dealings, disproportionate payrolls, and circular transactions among unconnected companies.

Another sector under scrutiny is the art market, long considered a haven for opaque, high-value deals. TRACFIN reports how construction and food service firms—unrelated to art—collaborated to buy expensive artworks at auction. Payments often came through foreign intermediaries with no apparent links to the companies’ operations, and many buyers requested invoice alterations to conceal beneficial ownership. TRACFIN stresses that reporting entities must “verify the relationship between buyers, payment sources, and the declared business activities.”

The realm of digital currencies and DeFi is also a growing battlefield. One method identified is the notorious “rug pull” scam, where fraudsters hype a new token online, attract investor funds, and then drain liquidity, leaving worthless tokens in their wake. TRACFIN points to “promotion of blockchain projects,” the use of “blacklisted crypto-assets,” and “sudden NFT price spikes” as red flags. The report also sheds light on crypto's dark applications, including payments tied to child exploitation and cross-border criminal finance.

In more traditional channels, real estate remains a go-to tool for launderers. Cases include properties sold below market value to associates, followed by rapid resales at inflated prices. One tactic uses foreign shell companies to purchase assets, effectively bypassing financial scrutiny. Similarly, high-end goods like art, watches, and jewelry are bought using cash or proxy accounts—allowing criminals to embed illegal funds into the economy. According to TRACFIN, “transactions involving individuals under asset freezes” are an increasingly common pattern.

Gambling and betting operations are also frequently abused. In multiple cases, criminals deposited cash abroad and moved it through gambling venues—sometimes with inside help—to simulate legitimate winnings. Tactics ranged from purchasing winning tickets to orchestrating unrealistic betting returns. TRACFIN warns of “unexplained payments between unrelated parties” and gambling wins that don’t match a person’s known income or lifestyle.

Criminals are not resting on old tricks. TRACFIN identifies shell companies and offshore trusts as growing tools of obfuscation. A typical example: a French resident utilized multiple offshore shell entities and a trust in a grey-listed FATF country to mask ties to a consultancy firm. Money flowed through neobanks and standard bank accounts in various jurisdictions, making origin tracing complex. Warning indicators here include transfers to weak AML jurisdictions and ownership links absent from public registries.

Public finances aren’t safe either. Fraudulent claims on government aid—particularly in construction subsidies and overseas investment incentives—are on the rise. In one example, shell companies and fake invoices were used to drain public funds under the guise of green building initiatives. TRACFIN flags such red flags as “unregistered subcontractors,” “lack of physical investment,” and diversion of funds to unrelated accounts.

Even social media platforms are being turned into financial conduits. According to TRACFIN, extremist groups are receiving “virtual gifts” via streaming platforms, with influencers unknowingly acting as intermediaries. Because these financial features operate within closed systems, law enforcement faces difficulties in identifying the real beneficiaries. Gaming and content-subscription platforms pose similar risks when supporting anonymous payments.

Crowdfunding has also been weaponized. Fundraising accounts created for humanitarian or social purposes are later found to have diverted donations to high-risk destinations or criminal activity. TRACFIN identifies shifts in account behavior, “clusters of small donations,” and links to geopolitically exposed regions as telltale signs.

Corruption within government procurement processes is yet another threat vector. Officials have been caught awarding lucrative public contracts to entities in which they held secret stakes. Methods included engineered short deadlines and fictitious subcontracting arrangements. TRACFIN urges vigilance around “unusually favorable contracts,” “rapid payments for undelivered services,” and “complex bidder relationships.”

The report’s most actionable contribution lies in its list of red flags, which reporting entities are urged to incorporate into their internal controls. Among these indicators: excessive numbers of accounts or cards tied to a single name (especially via neobanks), large unexplained cash deposits, inconsistent economic logic between transacting entities, use of companies in tax havens, and transactions involving PEPs or persons with negative media coverage. Rapid asset resales and odd cross-border flows—particularly with sanctioned or watchlisted nations—are also key warning signs.

Among TRACFIN’s highlighted case studies is the Girardin Tax Incentive Scam. French mainland investors were lured into a fake overseas development scheme with promises of tax breaks. No properties were built. Forged invoices and shell companies completed the illusion, siphoning millions in public money.

Another case involved a French national accessing child exploitation content via numerous small crypto payments routed through various VASPs. Despite the seemingly innocuous amounts, TRACFIN flagged the behavior due to the recipient’s profile and the fragmented structure of incoming transfers.

Real estate again proved central to another complex laundering scheme. A solo-owned property company sold discounted assets to affiliates, then flipped them to external shell companies—including foreign buyers—at inflated prices. This dual-layered structure helped circumvent asset freezes and obscure illicit origins.

TRACFIN emphasizes that its mission is both investigative and preventative. “By sharing anonymized case studies and warning signs,” the agency says, it helps enhance national detection capabilities. Compliance professionals are encouraged to refine transaction monitoring tools, invest in staff training, and “foster a culture of compliance that keeps pace with emerging risks.”

TRACFIN’s annual Forum continues to serve as a touchpoint between the financial sector and government, promoting “regular feedback and dialogue” essential to effective AML/CFT efforts.

As the agency states, “Regular consultation of TRACFIN’s guidance and active participation in AML/CFT knowledge sharing will be critical for financial institutions and non-financial actors alike.” It is only by internalizing such intelligence and fostering robust partnerships across sectors that France—and by extension, the global financial community—can protect itself against the continuously morphing threat of money laundering and financial crime.

By fLEXI tEAM