A practical guide for foreign auction houses, galleries and art advisers
A London auction house receives a consignment from a French company. A New York gallery sells a work to a French collector purchasing through a corporate vehicle. A Swiss dealer needs to verify the identity and authority of a French intermediary.
In each case, the foreign professional may need reliable information about a person or company located in France before completing its own KYC or enhanced due diligence.
France provides access to substantial corporate information through official registers. But understanding what those records prove, identifying the correct documents and obtaining beneficial ownership information can be more complex.
French counsel can provide local support without replacing the foreign professional’s own compliance function or the AML rules applicable in its jurisdiction.
What can be checked about a French company?
The first step is to establish the precise identity of the counterparty.
French companies have a unique SIREN number. Public French registers make it possible to verify a company’s existence and obtain information including its legal name, corporate form, registered office and certain information concerning its officers.
The French National Business Register (Registre national des entreprises or RNE) is maintained by the Institut national de la propriété industrielle, or INPI. Public information and documents available through the register may be consulted electronically.
The French official company directory also allows searches using a SIREN or SIRET number, corporate name, officer’s name or geographic location, and provides access to an RNE registration certificate.
For a foreign auction house or gallery, these sources can establish an essential first layer of due diligence.
They should not, however, be read mechanically. A valid registration does not answer every KYC question.
Does the person contacting you have authority to act for the company?
Identifying the company is only part of the exercise.
A foreign professional should also establish who is acting on its behalf and whether that person has authority to enter into the contemplated transaction.
This may require reviewing public information concerning the company’s officers, its articles of association or other corporate documents. Where the person acts under a specific delegation or mandate, additional evidence may be necessary.
The question becomes particularly important in art transactions where an adviser, broker, employee, family member or intermediary communicates with the foreign professional while another person or company appears as buyer or seller.
The relevant question is not merely “Does this company exist?” It is also “Who is entitled to commit it to this transaction?”
How can beneficial ownership information be checked in France?
This point requires particular care.
France maintains a Register of Beneficial Owners (Registre des bénéficiaires effectifs or RBE). However, beneficial ownership information is no longer freely accessible to the general public.
Since 31 July 2024, access has been restricted. French legislation adopted in 2025 and a decree of 24 April 2026 now provide a framework under which certain authorised persons and persons demonstrating a legitimate interest may obtain access.
The 2026 rules provide, in particular, that legitimate interest is assessed by reference to the applicant’s function or occupation and, in relevant cases, the applicant’s connection with the company or legal entity concerned.
A foreign professional should therefore not assume that French beneficial ownership information can simply be downloaded from an open corporate database.
Depending on the circumstances, it may be appropriate to assess whether access to the French register is available, obtain beneficial ownership documents directly from the counterparty, and compare the information received with the company’s public corporate information.
French counsel can assist with this process and with the interpretation of French records and documents.
What information should be requested from a French individual?
Where the counterparty is a French individual rather than a company, the professional will generally need reliable evidence establishing that person’s identity.
French AML legislation itself illustrates the distinction between identification and verification. It provides for the collection of core identification data concerning an individual and, among the available verification methods, the use of a valid official document bearing a photograph.
A foreign professional must, of course, apply the rules governing its own KYC process. The French framework can nevertheless help determine which French documents are relevant and whether the information provided is internally consistent.
Problems often arise not from the absence of a document but from inconsistencies between several documents.
The most important KYC check may be consistency
A compliant-looking file can still raise questions.
The identity of the seller may differ from the owner identified in the transaction documents. A buyer may request that the invoice be issued to a company after bidding personally. Payment may arrive from another individual or entity. The bank account may not correspond to the contracting party. An intermediary may be unable to produce clear evidence of authority.
Each difference may have a legitimate explanation.
The purpose of due diligence is to identify the difference and obtain that explanation before proceeding.
This is particularly important in the art market, where transactions can involve collectors, companies, trusts, family offices, advisers, dealers, agents and other intermediaries across several jurisdictions.
In its February 2026 sectoral focus, Tracfin specifically identified international transactions, multiple intermediaries and confidentiality among the characteristics that expose the art market to money-laundering risk.
When should enhanced due diligence be considered?
The precise legal test will depend on the law applicable to the foreign professional.
French AML law nevertheless provides a useful illustration of the circumstances that call for closer scrutiny. French regulated professionals must conduct enhanced examination of a transaction that is particularly complex, unusually large or appears to lack economic justification or a lawful purpose.
In such circumstances, French law requires enquiries concerning the origin and destination of funds, the purpose of the transaction and the identity of the person benefiting from it.
For a foreign professional dealing with a French buyer or seller, unusual structures, unexplained third-party payments or inconsistencies between the contracting party and the economic beneficiary may therefore justify further verification.
What can French counsel add to a foreign KYC process?
The value of French counsel is not to duplicate a KYC platform or the foreign professional’s compliance department.
It is to provide the French legal and documentary layer of the due diligence.
Fournol & Associés can assist foreign auction houses, galleries, dealers, art advisers, family offices and their legal or compliance teams when they need to understand or verify a French counterparty.
The Firm can review French corporate records and documents, analyse the legal existence and representation of a French entity, review documentation concerning authority to act, assist with beneficial ownership issues and applicable access rules, examine French-language KYC documents, identify inconsistencies requiring further enquiries, and communicate directly with the French buyer, seller, intermediary or their advisers where appropriate.
Where several jurisdictions are involved, we can work alongside the client’s existing compliance team or foreign counsel.
The foreign professional remains responsible for determining the AML and KYC requirements applicable to it under its own law. Our role is to make the French side of the transaction intelligible, documented and capable of verification.
KYC support for international art transactions involving France
Local assistance can be particularly useful where a foreign professional is dealing with a French company, where the transaction involves a French collector acting through a corporate structure, where beneficial ownership information is incomplete or difficult to reconcile, where a French intermediary acts for an undisclosed or insufficiently documented principal, or where the documents received do not clearly establish who is buying, selling or receiving the funds.
These issues are easier to resolve before the transaction reaches completion.
For foreign professionals, obtaining targeted French-law assistance can avoid repeated document requests, misunderstandings about French corporate records and unnecessary delays in an international sale.
An article written by Alexis Fournol, Attorney at the Paris Bar and Partner at the firm.
How Fournol & Associés can assist
Fournol & Associés is a Paris-based law firm advising art-market professionals and collectors in France and internationally.
The Firm regularly acts as French counsel in cross-border art transactions and works in English with foreign auction houses, galleries, dealers, collectors, advisers and lawyers.
Our understanding of French corporate information, AML/KYC requirements and art-market practice allows us to provide focused assistance on the French counterparty while coordinating with the client’s wider compliance process.
Related sector
- Art Market – Fournol & Associés acts as French counsel for foreign auction houses, galleries, dealers, collectors and intermediaries in transactions and regulatory matters involving France.
- Related expertise – Auction Law | Business Law | Contract Law | Art-Related Criminal Law
For the buyer’s perspective, see also: Why Is a French Auction House Asking for My ID? AML and KYC Rules for Art Buyers in France.
Frequently Asked Questions
Can a foreign auction house verify a French company online?
Yes. A substantial amount of French corporate information is publicly available through official sources, including the National Business Register and the French official company directory. The information available can include the company’s legal identity, registration details, registered office and certain information concerning its officers.
Is the French beneficial ownership register public?
Not generally. Access to the French Register of Beneficial Owners is restricted. Certain authorised persons have access, while other applicants may obtain access where they meet the applicable legitimate-interest requirements.
Can a French lawyer conduct KYC checks for a foreign auction house or gallery?
French counsel can assist with the French component of a KYC process by verifying and analysing French corporate information and documentation, dealing with beneficial ownership issues where appropriate, reviewing authority to act and identifying inconsistencies that require additional enquiries. The foreign professional must separately ensure compliance with the AML rules applicable to it.
What should I do if the French buyer, seller and payer are different persons?
The respective roles of each person should be identified and documented before the transaction proceeds. A difference between the contracting party, economic beneficiary and source of payment does not necessarily indicate wrongdoing, but it may justify further due diligence.
This publication provides general information on French law and does not constitute legal advice. The applicable requirements depend on the circumstances of each transaction and, for foreign professionals, on the AML/KYC rules applicable in their own jurisdiction.
