AMF Reissues Bitget Blacklist Warning: Compliance and Accounting Implications for Firms
France's Autorité des marchés financiers has refreshed its public blacklist notice against Bitget, the crypto asset trading platform, reminding investors and market participants that the exchange has been operating in France without the mandatory PSAN registration since at least November 2023. For accounting firms, auditors, and CFOs relying on digital asset accounting software to monitor client exposure, this enforcement signal carries material implications that go beyond a simple regulatory footnote.
What the AMF Has Actually Said
The AMF's notice is direct. Bitget has not registered as a prestataire de services sur actifs numériques (PSAN) under the French Code monétaire et financier, yet it has been providing services to French residents that fall squarely within the scope of mandatory registration. Those services include custody of digital assets for third parties, the purchase and sale of digital assets against legal tender, the exchange of digital assets for other digital assets, and the operation of a digital asset trading platform.
The Blacklist and Its Legal Basis
Bitget was first added to the AMF blacklist on 7 November 2023. The regulator's July 2026 communication is a public reminder that this status remains in force. French law gives the AMF the power to seek a court order blocking access to the platform's website, and the notice explicitly reserves that right. The AMF is also calling on any French-resident investor who has funds on the platform to take immediate steps to secure access to their assets, warning that a sudden suspension of services for French users is a genuine risk.
Why PSAN Registration Matters
The PSAN framework exists to preserve public order in the financial markets. Registration is not merely administrative: it requires a provider to demonstrate the capacity to meet anti-money laundering and counter-terrorist financing obligations, and it involves checks on the fitness and propriety of directors and significant shareholders. An unregistered provider that bypasses this process offers none of those protections to its clients. From a compliance standpoint, any client holding assets on an unregistered platform is exposed to a gap in the AML chain that can create liability for the firm advising them.
The Transition from PSAN to MiCA CASP Licensing
The timing of this notice matters. France completed its MiCA transition period in early 2026, meaning that crypto asset service providers operating in France now require authorisation as a MiCA-compliant CASP rather than simply a legacy PSAN registration. The AMF has taken on a strengthened supervisory role under that framework. As covered in our earlier analysis of France's MiCA transition and the AMF's new supervisory role, the shift raised the bar for market participants and gave the regulator expanded tools to act against non-compliant operators.
Bitget's situation sits in an uncomfortable position. The platform was already non-compliant under the older PSAN regime. Under MiCA, the requirement is now more demanding, not less. The AMF's decision to reissue its warning in July 2026 suggests that French-resident clients continue to access the platform, prompting the regulator to reinforce its public guidance.
A Pattern Across the EU
France is not acting in isolation. Belgium's FSMA flagged six unauthorised CASPs after the MiCA deadline, signalling that national competent authorities across the bloc are actively scanning for non-compliant operators and using their public warning and blacklist powers with increasing frequency. For firms with clients operating across multiple EU jurisdictions, this coordinated enforcement pattern is the new baseline expectation.
Accounting and Audit Implications
When a client holds digital assets on a blacklisted, unregistered platform, several accounting and audit issues arise simultaneously. Each deserves attention from the firm's engagement team.
Asset Recoverability and Going-Concern Questions
The AMF's specific warning about the risk of a sudden service suspension for French users is a material flag for auditors. If a client holds a significant balance on Bitget and access is blocked or restricted at short notice, those assets could become temporarily or permanently irrecoverable. Under IFRS and French GAAP, auditors are required to assess whether assets are recoverable and whether any impairment provision is necessary. If the risk is material, it may also feed into going-concern assessments for entities with concentrated crypto holdings.
Custody and Counterparty Risk Disclosure
Auditors reviewing financial statements that include digital assets held on third-party exchanges are expected to obtain evidence of the existence and completeness of those balances. Holding assets on a platform that is both blacklisted and unregistered creates a custody risk that requires disclosure in the notes to the financial statements. The counterparty risk is not hypothetical: a regulator-mandated site block would immediately impair access. Firms should ensure that this risk is explicitly addressed in the audit file and, where material, in the financial statements themselves.
AML and Client Due Diligence
For firms providing accounting or advisory services to clients with Bitget exposure, the platform's unregistered status is relevant to client due diligence. An entity knowingly using an unregistered provider to conduct crypto transactions is operating in a grey zone at minimum. Depending on the volume and nature of activity, this could trigger enhanced due diligence obligations for the accounting firm itself under applicable AML frameworks. The firm's MLRO should be aware of any client with known or suspected Bitget balances, and a documented risk assessment should be on file.
Tax Reporting Integrity
Transactions conducted through an unregistered platform do not carry any automatic reporting or withholding infrastructure that a regulated PSAN or MiCA CASP would normally provide. In France, crypto asset gains are taxable as flat-rate income under the prélèvement forfaitaire unique regime, and accurate transaction data is the foundation of compliant reporting. If a client's transaction history on Bitget is incomplete, inaccessible, or subject to disruption because of a potential site block, the firm must ensure it has obtained and preserved all relevant records now, before access is restricted. Robust crypto bookkeeping software that ingests exchange data via API or CSV export should be used immediately to capture the full transaction history.
Practical Steps for Accounting Firms and CFOs
The AMF's notice is not merely a public warning to retail investors. It is a signal that firms advising French-resident individuals or entities with digital asset holdings should act on promptly.
Client Portfolio Review
Run a check across your client base to identify any individual or entity that holds, or has held, digital assets on Bitget. This is where digital asset accounting software with exchange connectivity becomes operationally critical: the ability to pull transaction histories, current balances, and custody locations across multiple platforms in one place allows firms to act quickly rather than chase clients for manual data exports.
Immediate Data Preservation
Advise any affected client to download their full transaction history from Bitget without delay. Export formats, API access, and account statements should all be captured and stored in a format that is independent of continued platform access. If the AMF pursues a site-blocking order and it is granted, that access window closes.
Asset Withdrawal Assessment
The AMF has explicitly advised French-resident investors to take all necessary steps to avoid being locked out of their holdings. For clients with material balances, the firm should facilitate a structured conversation about withdrawal to a registered, MiCA-compliant CASP or to self-custody, with appropriate advice on the tax treatment of any resulting transactions.
File Documentation
For audit and AML purposes, document the review, the findings, and any advice given. If an affected client chooses to maintain their position on the platform despite the risks, that decision and the advice given should be on record.
The Broader Enforcement Signal
The Bitget blacklist entry has been in place since November 2023. The AMF's decision to reissue and amplify the warning in July 2026, specifically referencing the risk of a court-ordered site block, indicates a willingness to escalate. Regulators across the EU are increasingly treating the public warning list not as a passive reference document but as an active enforcement tool. Firms that treat a blacklist entry as background noise rather than a live compliance trigger are taking on unnecessary risk.
The AMF's mandate covers investor protection, market transparency, and the integrity of financial markets. When an unregistered platform continues to attract French-resident users despite being on the blacklist for nearly three years, the regulator's next logical step is the courts. Firms and their clients should plan accordingly.
Frequently Asked Questions
What does it mean that Bitget is on the AMF blacklist?
The AMF blacklist identifies firms that are providing regulated services to French residents without the required authorisation. Bitget has been on that list since 7 November 2023 because it has offered crypto asset services subject to mandatory PSAN registration without holding that registration. Using or recommending an operator on this list carries regulatory, AML, and financial risk.
Can the AMF block access to Bitget's website?
Yes. The French Code monétaire et financier authorises the AMF to apply to a court for an order requiring internet service providers to block access to a non-compliant platform's website. The AMF's July 2026 notice explicitly reserves this right in relation to Bitget.
What should an accounting firm do if a client holds assets on Bitget?
The immediate priorities are to obtain and preserve the client's full transaction history, assess the materiality of the balance for audit and tax purposes, conduct an AML risk assessment, and advise the client to consider withdrawing assets to a registered, MiCA-compliant provider. All steps should be documented in the client file.
Does MiCA change the compliance requirement for crypto platforms in France?
Yes. Following the end of France's MiCA transition period, operators now need MiCA CASP authorisation rather than legacy PSAN registration. The bar is higher, the supervisory scrutiny is greater, and the AMF has expanded tools to act against non-compliant providers. Bitget did not meet the lower PSAN threshold, let alone the MiCA CASP standard.
How does a client's use of an unregistered exchange affect the accounting firm's AML obligations?
A client using an unregistered exchange represents a potential gap in the AML chain. The firm's MLRO should be informed, and a documented enhanced due diligence assessment should be prepared. Depending on the nature and volume of the client's activity, the firm may also need to consider whether a suspicious activity report is warranted under applicable AML legislation.