AML/CFT: What are the obligations for professionals in the watchmaking and jewelry industry?

Starting from August 1, 2026, Many professionals in the watchmaking, jewelry, and goldsmithing sectors will be directly subject to the obligations of fight against money laundering and the financing of terrorism (AML/CFT). This regulation no longer only concerns large cash payments: it requires knowing your customers, assessing risks, keeping supporting documents, and, in case of suspicion, reporting to TRACFIN. Here is an overview.

The essentials in 30 seconds

• Applicable to August 1, 2026 (law of June 25, 2026).
• Concerned: HBJO professionals who, as regular or main, sell goods over €10,000.
• The threshold is regardless of the payment method (including card or bank transfer).
• The key is: knowing the customer, analyzing the risks, keeping the evidence, and reporting to Tracfin in case of suspicion.

Who is affected from August 1st, 2026?

The law of June 25, 2026 subjects professionals who practice, on a regular basis or as a primary occupation, The sale of goods worth more than €10,000 in watchmaking, jewelry, or goldsmithing. Two conditions must be met:

1. you market regularly or mainly HBJO goods worth more than €10,000; ;
2. the asset involved in the transaction itself has a value over €10,000.

THE The method of payment has no impact The rule also applies to payments made by bank card or bank transfer. It will come into effect on August 1, 2026, the first day of the second month following the publication of the law.

What does "regular" activity mean?

The text does not fix no minimum number of sales. Therefore, there is no rule that automatically excludes one or two sales per year. The frequency of sales, their repetition, their importance to the business, and the brand's positioning will be assessed on a case-by-case basis. A boutique that typically sells watches or jewelry worth over €10,000 should seriously consider whether it falls within this category.

Existing cases of liability

Some HBJO professionals were already affected before August 1, 2026, in particular traders accepting payment in cash or electronic money above the regulatory threshold, and those who habitually and primarily trade in precious metals or precious stones (transactions of at least €10,000).

Starting from the July 10, 2027, The European AML/CFT regulation will directly extend its scope to individuals who regularly or primarily trade in precious metals, precious stones, or high-value goods. Watches, jewelry, and silverware valued at over €10,000 are specifically included. This development will particularly target jewelers who regularly engage in... gold buyback, even as a non-primary occupation.

Major obligations, in brief

Once subject to these obligations, you must implement several due diligence requirements: assess the risks of your business, identify and verify the customer, identify the beneficial owner, understand the operation, increase vigilance in risky situations, and verify the asset freeze measures. Details can be found in our dedicated guide: AML/CFT: Due Diligence Obligations in Detail.

Reporting a suspicious activity to TRACFIN

In the presence of serious doubt about the origin of the funds or the nature of a transaction, a declaration to TRACFIN It is mandatory, including for attempts and without a minimum amount. When to declare, on which indices and how (ERMES platform): see AML/CFT: Reporting suspicious activity to TRACFIN.

Organizing one's compliance

AML/CFT also requires internal organization: distributing roles, training teams, and retaining supporting documents. five years, And, if you wish, you can use software (not mandatory). The practical point: AML/CFT: Organizing your compliance.

Note: AML/CFT is not the cash limit

The €10,000 threshold that triggers AML/CFT regulations does not mean that a customer can pay €10,000 in cash. For a customer who is a tax resident of France (or acting in a professional capacity), cash payments remain limited to 1 000 € ; a non-resident consumer for tax purposes may, under certain conditions, pay up to 15 000 € in cash. These are two separate regulations that must be respected simultaneously.

What should we do right now?

1. Determine if you regularly sell goods worth more than €10,000.
2. Create and formalize your risk mapping.
3. Write your internal procedures.
4. Organize the identification of clients and beneficial owners.
5. Implement PPE controls and asset freezes.
6. Designate the people responsible for alerts and exchanges with TRACFIN.
7. Register the declarant on ERMES.
8. To train managers and salespeople.
9. Plan for secure storage of supporting documents during five years.
10. Integrate these controls into the sales process without degrading the customer experience.

AML/CFT compliance is therefore not just about asking for an identity document: you must be able to demonstrate that you know your risks, that you analyze unusual situations and that you keep proof of the measures taken.

This article is for informational purposes only and does not replace applicable laws or professional advice. The AML/CFT framework is technical and constantly evolving: verify your situation with official sources (Monetary and Financial Code, French Customs and Indirect Tax Authority (DGDDI), French Financial Intelligence Unit (Tracfin)) or a professional before deciding on your specific measures.