AMF Mediator Report 2025: Crypto AML Disputes Jump 38%
France's financial markets regulator has released data that every firm handling digital assets in the country should take seriously. The AMF mediator's 2025 annual report, presented by Rémi Bouchez at a press conference on 10 September 2026, shows a record 3,010 cases received last year, a 37% increase on 2024. Within that surge, crypto-related complaints rose 38% year on year, and the pattern of those complaints points directly at AML and counter-terrorism financing controls as the primary friction point between intermediaries and their clients.
A Record Year for the AMF Mediation Service
The headline numbers are striking. The mediation service received 3,010 files in 2025, up from 2,204 in 2024. Cases resolved and closed reached 2,772, a 41% increase on the 1,969 closed the previous year. The mediator issued 888 proposed solutions, and 92% of those proposals, whether favourable or unfavourable to the complainant, were accepted by both parties.
Early 2026 momentum continues
The trend has not slowed. In the first half of 2026 alone, 1,865 files were registered, 31% more than in the same period of 2025. Over that same half-year, 1,525 cases were resolved and closed, up 14% year on year, and 422 proposed solutions were issued, 58% of them favourable to the complainant. The throughput figures suggest the mediation service has significantly scaled its operational capacity, but the underlying demand keeps rising.
Where Crypto Sits in the Overall Picture
Digital asset disputes are not the largest category in the 2025 report, but their growth rate stands out. The AMF mediator received around 38% more crypto-related files in 2025 than in 2024. The important nuance is jurisdictional competence: only about a third of those files, roughly 30 cases in 2025, actually fell within the mediator's remit. By the end of June 2026, 61 crypto-related files had already been handled.
Why most crypto complaints are turned away
The majority of crypto files that the mediator declines to take on fall into two buckets. Approximately 54% involve facts that may constitute fraud or outright scams, matters for criminal enforcement rather than regulatory mediation. A further 28% relate to disputes that fall under a different mediator's competence. That leaves a relatively narrow slice, but it is a revealing one.
The AML account restriction problem
Among the cases the mediator does accept, account access restrictions applied under AML and counter-terrorism financing (CFT) regulation are the defining theme. French digital asset intermediaries, operating under obligations derived from the EU AML framework and national transpositions, are blocking or limiting client accounts as part of their monitoring and due diligence processes. Clients who feel those restrictions are unjustified or poorly explained are turning to the mediator in growing numbers.
This is the enforcement dynamic that firms need to understand. It is not that regulators are directly sanctioning more firms for AML breaches in this dataset. It is that the downstream effect of AML compliance, restricting client access, is generating a rising volume of formal disputes. The gap between the compliance action and the client's understanding of it is where the friction lives. Understanding how AML sanctions screening obligations affect crypto transfers is therefore directly relevant to reducing exposure to this kind of complaint.
The Broader Dispute Landscape: Context for Crypto Professionals
The crypto figures do not exist in isolation. The report shows that the equity savings plan (PEA, or plan d'épargne en actions) generated the highest volume of disputes by a wide margin, with 462 cases closed in 2025, nearly 150% more than the 185 closed in 2024. Nearly three-quarters of those PEA disputes relate to transfer difficulties, often involving European intermediaries operating in France under freedom-of-services rules. The arrival of new entrants into the PEA ecosystem has triggered a surge in transfer requests and, correspondingly, a surge in complaints when those transfers stall.
Real estate and crowdfunding disputes accelerate
Two other categories matter for contextual awareness. SCPI (real estate investment vehicle) disputes rose 41% to 199 cases in 2025 from 141 in 2024, driven by delayed withdrawal execution and contested investment advice in a sector facing a property market downturn. More dramatically, crowdfunding disputes jumped from just 8 cases in 2024 to 93 in 2025, a surge that the report attributes to the conclusion in 2025 of lengthy negotiations begun in 2024 with crowdfunding platforms. By mid-2026, 69 crowdfunding cases had already been handled.
For firms that advise clients across multiple asset classes, including tokenised real estate or crowdfunding instruments built on blockchain infrastructure, these figures are a reminder that regulatory dispute volume is rising broadly, not just in crypto. The compliance and client communication disciplines that reduce AML-related crypto complaints are the same disciplines that reduce disputes across other product lines.
Accounting and Compliance Implications for B2B Firms
The mediator's data has direct operational relevance for accounting practices, auditors, and CFOs managing digital asset portfolios or advising clients who hold them.
Documentation of AML-triggered actions
When an intermediary restricts a client's account under AML or CFT obligations, the restriction itself may be legally required and entirely defensible. What generates a mediation file is typically the absence of adequate explanation, poor recordkeeping, or a failure to give the client a clear route to resolution. Firms advising digital asset intermediaries should be testing whether their clients' AML procedures include client notification protocols that are proportionate and legally sound. A restriction that cannot be explained in writing to the client, and ultimately to the mediator, is a compliance failure waiting to become a dispute.
Audit trails and crypto bookkeeping software
The rise in AML-related crypto disputes reinforces the case for robust digital asset accounting software that maintains a granular, timestamped record of every transaction and every compliance action taken against an account. When a client challenges a restriction, the intermediary's first line of defence is contemporaneous documentation. Digital asset accounting software that logs compliance events alongside transaction records gives auditors and legal teams exactly the evidence chain they need. Firms that rely on manual spreadsheets or disconnected systems face a material documentation risk in this environment.
Cross-border transfer complexity
The PEA dispute data, where nearly three-quarters of cases involve transfer difficulties to or between financial institutions, echoes a pattern familiar in crypto: cross-border or inter-platform transfers create the most dispute-prone moments in a client relationship. For digital asset intermediaries, the practical lesson is that transfer workflows require the same level of procedural rigour, client communication, and audit-trail integrity as any other high-risk transaction type. This is precisely what aggressive AML enforcement looks like across jurisdictions, and France is not an outlier.
What the Numbers Mean for French Digital Asset Firms
The AMF mediator's statistics are a lagging indicator: they tell you what went wrong in client relationships over the previous year. The 38% rise in crypto complaints in 2025, and the 61 cases already logged in the first half of 2026, suggest the trend has not peaked. For firms operating in France's digital asset sector, or auditing those that do, the practical response involves three areas.
Client communication at the point of restriction
AML-driven account restrictions should trigger an immediate, documented communication to the client. The communication does not need to reveal the details of a suspicious activity report, but it should explain that a regulatory procedure is underway, give a realistic timeline, and identify a named contact point. Clients who understand what is happening and why are significantly less likely to escalate to the mediator.
Internal review of prior restriction cases
Firms should conduct a retrospective review of any AML-triggered restrictions applied over the past 18 months. The questions to ask: Was each restriction documented in a compliance file? Was client communication recorded? Was the restriction lifted promptly once the review concluded? If the answer to any of these is no, the firm carries residual dispute risk that a proactive internal review can reduce before it reaches the mediator.
Crypto bookkeeping software integration with compliance workflows
The most durable solution is structural. Crypto bookkeeping software that integrates with compliance management systems, so that a compliance flag on an account automatically generates a documented record within the accounting ledger, closes the gap between operational action and evidentiary trail. This is the standard that sophisticated digital asset intermediaries and their auditors should be working toward, and the AMF mediator's data makes the business case for getting there faster.
Frequently Asked Questions
What does the AMF mediator actually do?
The AMF mediator is an independent dispute resolution service within France's financial markets regulator. When a client has a complaint against a regulated financial intermediary and cannot resolve it directly, they can refer it to the mediator. The mediator reviews the file and issues a non-binding proposal that the parties are free to accept or reject, though the 2025 report shows a 92% acceptance rate.
Why are so many crypto complaints outside the mediator's competence?
The mediator's remit covers regulated activities and regulated intermediaries. A large portion of crypto-related complaints involve alleged fraud or scams by entities that are not regulated, or they fall under the jurisdiction of a different mediator. Only disputes involving licensed digital asset service providers operating within the French regulatory perimeter are typically eligible.
What types of AML restrictions are generating the most crypto disputes?
The 2025 report does not break down specific restriction types in granular detail, but it identifies account access restrictions applied under AML and CFT regulation as the primary driver of eligible crypto cases. This encompasses account freezes, withdrawal holds, and onboarding refusals where clients believe the restriction is unjustified or has not been adequately explained.
Does the rise in complaints indicate that French crypto firms are non-compliant?
Not necessarily. A rise in mediation cases reflects increased client awareness of dispute resolution options, the growing number of digital asset account holders in France, and in some cases genuine procedural shortcomings at the intermediary level. The mediator's data does not establish regulatory breach; enforcement actions by the AMF itself are a separate process. The complaints do, however, signal areas where compliance execution and client communication need strengthening.
How should an accounting firm advising a French digital asset client respond to this report?
The most immediate action is a documentation review: confirm that all AML-triggered account actions over the past 18 months are recorded in compliance files with contemporaneous client communications attached. Beyond that, the report supports a broader recommendation to clients to invest in digital asset accounting software that logs compliance events alongside transaction records, reducing the evidential gap that most often turns a restriction into a formal dispute.