TRACFIN’s 2024-2025 Threat report: Key lessons for real-estate agents, yacht brokers and asset managers

27/10/2025

Published on 29 September 2025, TRACFIN’s third volume of “LCB-FT : état de la menace 2024-2025” sets out 21 typologies of money-laundering and terrorist-financing (ML/TF) schemes observed in recent years. For professionals in real estate, asset management, and yachting, the report provides valuable insights into how illicit capital infiltrates high-value asset markets and the roles intermediaries may unknowingly play.

21 Typologies – A Warning for Luxury Asset Markets
TRACFIN’s case studies show that financial crime in France increasingly targets tangible prestige assets—villas, apartments, yachts, and investment portfolios. The report highlights:

Use of front structures and nominees in offshore jurisdictions to purchase or hold luxury assets.
Funds arriving from opaque intermediaries, often via change offices or payment platforms before entering France.
Apparent overvaluation or undervaluation of property or yacht sales compared to market reality.
Rapid resale or refinancing of high-value assets to justify “clean” liquidity.
Interposition of asset-management mandates to distance UBOs from suspicious transactions.

These typologies mirror trends seen by in Monaco and confirm that DNFBPs in both jurisdictions remain exposed to complex, multi-layered laundering strategies.

Real-Estate Agents: Strengthening Source-of-Funds Controls
For French registered real-estate agents, TRACFIN emphasises vigilance when clients:

purchase through foreign entities or trusts,
finance transactions with foreign currency transfers or manual exchange operations,
or display wealth inconsistent with their declared occupation or tax situation.

Agencies in France and Monaco must ensure that KYC and source-of-funds documentation are complete and traceable, particularly where notaries rely on the agent’s initial verification. TRACFIN’s examples demonstrate that missing documentation or “routine” acceptance of opaque buyers remains one of the most common weaknesses identified during AML inspections.

Yacht Brokers: Complex Ownership, Complex Risks
Yachting transactions often involve multi-jurisdictional holding and financing arrangements, combining leasing companies, SPVs, and cross-border flagging. TRACFIN identifies repeated use of:

Shell leasing companies with no real operations;
Bearer share entities still active in some offshore jurisdictions;
and frequent re-registration or sale of vessels to disguise true ownership.

Brokers should enhance beneficial-owner verification, scrutinise the economic rationale for ownership transfers, and document how the source of purchase funds aligns with the client’s declared wealth and activity.

Asset Managers: Heightened Scrutiny of Client Structures
Asset managers, family offices, and wealth advisors are increasingly used to layer funds through discretionary mandates or asset-holding companies. TRACFIN urges particular attention to:

investment mandates funded from non-transparent offshore accounts;
cross-product transfers (e.g. property sale proceeds invested into funds or life insurance);
and rapid portfolio turnover inconsistent with normal investment strategies.

Enhanced transaction monitoring and ongoing due diligence are essential where the client profile or source of funds is ambiguous.

Practical Steps for Professionals
Rosemont recommends that regulated professionals in France and Monaco now:

Update their AML/FT risk assessments to integrate TRACFIN’s 2024-2025 typologies as concrete red-flag indicators;
Document jurisdictional risk scoring for each entity or vehicle involved in asset transactions;
Record detailed rationale for complex structures, particularly where a trust, foundation, or offshore holding is involved;
Reinforce training for sales, relationship, and compliance teams on emerging typologies and red flags;
Strengthen communication with counterparties (banks, notaries, managers) to ensure end-to-end verification and coordinated suspicious transaction reporting;
Use best of breed screening tools (such as Lexco) for ongoing daily customer screening for sanctions, enforcements, adverse media, and PEP checks.

Rosemont’s Perspective
At Rosemont Consulting Monaco, we support professionals in the luxury asset, yachting, and real-estate sectors to align their governance and AML frameworks with the latest guidance from TRACFIN, AMSF, and FATF.
Our compliance specialists help DNFBPs:

map typology-based risk indicators into practical client and transaction scoring tools;
review and update AML manuals and training modules;
and implement proportionate, risk-based controls adapted to cross-border clientele.

Contact us to arrange a consultation or risk-model review in light of the “TRACFIN’s 2024-2025 Threat report” findings: consulting@rosemont.mc