1. Context

On 19 June 2025, the Sanctions Committee of the French Prudential Supervision and Resolution Authority (ACPR) issued a decision against Banque Delubac & Cie, delivering a formal reprimand and imposing a financial penalty of €600,000 for multiple breaches of its anti-money laundering and counter-terrorism financing (AML/CFT) obligations.

The decision, which is notably detailed, highlights systemic shortcomings in the bank’s internal organisation, alert detection and handling, and the reporting of suspicious transactions. Although the ACPR did not directly allege a breach of international sanctions regulations, both the supervisory report and the charges retained reveal a worrying exposure of the bank to this type of risk.

This article focuses specifically on that dimension: the risk of circumventing international financial and economic sanctions, viewed through the lens of AML/CFT compliance and the growing importance of geopolitical due diligence.

2. A business model exposed to sanctions risks

As part of a strategic repositioning, Banque Delubac developed a line of business centred on:

  • Supporting companies operating to or from high-risk jurisdictions, including countries subject to economic or financial sanctions;
  • Offering correspondent banking services;
  • Conducting cross-border transactions involving sensitive zones such as Russia or other intermediary jurisdictions deemed high-risk.

However, this model suffered from the absence of robust screening and alert mechanisms.

3. ACPR inspection findings

An on-site inspection conducted in early 2023 uncovered the following:

  • Systemic weaknesses in identifying transaction flows linked to high-risk or sanctioned countries:
    • The alert system [A] was unable to detect or process transactions based on their country of origin or destination.
    • Monitoring efforts only targeted clients who had initially declared such links at onboarding, without updates throughout the relationship.
  • A lack of enhanced due diligence measures for certain high-risk clients or sensitive transactions;
  • Cases where account closures or flagged operations were handled without any report to TRACFIN, even when the nature of the flows appeared suspicious or inconsistent with the geopolitical context (e.g. Russia, the UAE, Panama).

4. Consequences

Although the facts did not amount to a direct breach of sanctions regimes in a criminal or customs sense, the ACPR concluded that:

  • The bank’s systems were structurally unfit to prevent indirect circumvention of international sanctions;
  • This failure constitutes a serious breach of the bank’s duty of vigilance and the requirement that its AML/CFT framework be effective, particularly in the current context of regulatory scrutiny over financial flows linked to sanctioned states (e.g. Russia, Iran, Syria).

The final penalty — a reprimand and a €600,000 fine — was therefore partly justified by the bank’s insufficient control over the risk of sanctions circumvention.