CHD ¦ Reforming Article 506‑1 (Update)

Penal Code Reform Expands the Scope of Money Laundering Offenses

The Law of 12 December 2025 introduces a significant amendment to Article 506-1 of the Penal Code, reshaping the legal approach to money laundering and related conduct. By removing the former list of “primary offenses” and replacing it with a global reference to all crimes and offenses, the legislator has opted for a broader and more flexible framework. This reform clearly aims to close gaps that could previously be exploited when proceeds originated from offenses not expressly listed in the law.

From enumerated offenses to a comprehensive reference

Before this reform, Article 506-1 relied on a defined catalog of predicate offenses. The amended provision now covers property that is the object or the proceedings, direct or indirect, of any crime or offense. This changes considerably widens the scope of criminal liability. Any illicit origin, regardless of the nature of the underlying offense, may now trigger the application of the money laundering provisions.

Clarified and reinforced incriminations

The revised Article 506-1 maintains a structured approach to incrimination. It covers the facilitation of false justification of the nature, origin, location, disposition, movement or ownership of assets derived from a crime or an offense. It also targets assistance in operations such as placement, concealment, disguise, transfer or conversion of such assets. In addition, the acquisition, holding or use of assets deriving from criminal activity remains punishable when the person knew, at the time of receipt, that the property originated from a crime or an offense. Attempts of these offenses are explicitly punishable by the same penalties, reinforcing the preventive and repressive nature of the provision.

Bastian Schwind-Wagner _Follow

"The amendment to Article 506-1 of the Penal Code marks a decisive expansion of the money laundering offense by extending its scope to the proceedings of any crime or offense. By abandoning an exhaustive list of predicate offenses, the legislator has significantly reduced legal uncertainty and loopholes in enforcement.

This reform reinforces the preventive role of financial crime regulation, particularly for professionals subject to reporting obligations. The focus is now firmly on the suspicious nature and criminal origin of assets, rather than on the precise qualification of the underlying offense."

Consistent penalties reflecting the seriousness of the offense

The sanctions attached to Article 506-1 remain substantial. Offenders face imprisonment ranging from one to five years and a fine between 1,250 euros and 1,250,000 euros, or one of these penalties only. These sanctions underline the importance attributed to combating money laundering and preserving the integrity of the financial system.

Implications for reporting obligations

The reform must be read in conjunction with the amended Law of 12 November 2004 on the fight against money laundering and the financing of terrorism. Article 5 (1) a) of that law recalls that obligated entities must report suspicious transactions without qualifying the underlying offense. The extension of Article 506-1 to all crimes and offenses reinforces this principle. Professionals are not required, nor expected, to identify the precise predicate offense, but rather to focus on the suspicious nature of the transactions and the potential criminal origin of the assets involved.

A clear message to practitioners and institutions

With this reform, the legislator sends a strong signal to financial institutions, professionals subject to AML obligations and the wider legal community. The fight against money laundering is no longer constrained by technical debates on the classification of underlying offenses. Instead, the emphasis is placed on the illicit origin of assets and the knowledge or intent of those involved. This evolution aligns the Penal Code more closely with international standards and strengthens the overall effectiveness of the anti–money laundering framework.

Dive deeper

• Legilux ¦ Loi du 12 décembre 2025 portant modification: 1° du Code pénal; 2° du Code de procédure pénale (Projet de loi 8486) ¦ Link
• CRF ¦ New article 506-1 of the Penal Code ¦ Link