SANCTIONS LISTS AND WATCHLISTS EXPLAINED · GUIDEUPDATED 2026-09-04
Sanctions Lists and Watchlists Explained
Registre national des gels: 6,578 asset freezes, of which 79 are purely French
France's national asset-freeze register from DG Trésor: what gel des avoirs means, the JSON and XML feeds, and the small national layer inside it.
Ask a French compliance officer about the gel des avoirs and you get a national register; ask an outsider and you get a shrug about the EU list. Both are right, and the interesting part is the ratio. The Registre national des gels, maintained by the Direction générale du Trésor under article L. 562-4 of the code monétaire et financier, is the single authoritative statement of every asset freeze in force on French territory: UN designations, EU designations, and the small set France imposes itself by ministerial arrêté under articles L. 562-2, L. 562-2-1 and L. 562-3. In the file published on 3 September 2026 there were 6,578 measures, and exactly 79 of them rested on a French arrêté alone — mostly domestic terrorism financing cases, each identified by an ECOT reference. Everything else traces to Brussels or New York. The register is free, published as JSON and XML with schemas through an open API at gels-avoirs.dgtresor.gouv.fr, and it is unusually generous with contact data: 565 entries carry a website, 523 a telephone number and 518 an email address, which no other major European list publishes.
What this workflow covers
SCOPE- 6,578 measures in the publication dated 3 September 2026: 4,632 personnes physiques (natural persons), 1,907 personnes morales (legal entities) and 39 navires (vessels).
- 79 measures rest on a French national arrêté alone, cited as ECOT references under the dispositif national de gel des avoirs. The remainder implement EU regulations or UN Security Council decisions.
- Field coverage in that file: 6,326 records carry MOTIFS (the statement of reasons), 4,345 an ALIAS, 3,950 a DATE_DE_NAISSANCE, 2,811 a NATIONALITE, 545 a PASSEPORT and 39 a NUMERO_OMI.
- Cross-references are explicit: 2,051 records carry a REFERENCE_UE and 337 a REFERENCE_ONU, so you can join a French entry back to the EU or UN listing that produced it.
- The single largest regime is EU Regulation 269/2014 on Ukrainian territorial integrity, behind 3,027 of the 6,578 measures — nearly half the register.
- Downloads: JSON at /ApiPublic/api/v1/publication/derniere-publication-fichier-json and XML at the matching -xml endpoint, each with a published schema, plus a filterable list and PDF export on the site. No key, no fee, no fixed cadence and no delta file — DG Trésor updates as measures are made, runs a Flash info email alert for new freezes and removals, and stamps every file with a DatePublication that is your only freshness signal.
- Sectoral EU measures, export bans and ownership analysis sit outside the register entirely. A company controlled by a designated person is caught by the freeze without appearing here, and French guidance applies a control test rather than a bare percentage.
- False positives cluster around Cyrillic and Arabic transliterations rendered in French orthography, where Chevtchenko, Shevchenko and Ševčenko are the same person, and around the 2,628 records with no date of birth at all.
- A hit means both limbs of a freeze: block the funds and economic resources, and make nothing available directly or indirectly. Reporting goes to DG Trésor, not to a supervisor. France sits among the main jurisdictions on our coverage register, screened by default rather than as an add-on.
Key statistics
DATA- Measures in the register published 3 September 2026
- 6,578 (4,632 persons, 1,907 entities, 39 vessels)
- Counted from the DG Trésor JSON publication
- Measures resting on a French national arrêté alone
- 79
- Counted from the FONDEMENT_JURIDIQUE field of the same publication
- Legal basis for the register
- Article L. 562-4, code monétaire et financier
- Direction générale du Trésor, Registre national des gels
Compliance glossary
TERMS- Gel des avoirs
- Asset freeze in French law: funds and economic resources of a listed party are immobilised, and nothing may be made available to them or for their benefit, directly or indirectly.
- Registre national des gels
- The DG Trésor register listing every person, entity and vessel subject to an asset freeze in force in France, whether the measure originates with the UN, the EU or France itself.
- Arrêté de gel
- A French ministerial order freezing assets under articles L. 562-2, L. 562-2-1 or L. 562-3 of the code monétaire et financier, identified in the register by an ECOT reference.
- Fondement juridique
- The legal-basis field on each register entry, naming the EU regulation, UN committee decision or French arrêté that imposed the freeze. One entry can carry several.
Authoritative references
SOURCES- 01Registre national des gels
Direction générale du Trésor, Ministère de l'Économie et des Finances
- 02API Gels-avoirs — publication JSON
Direction générale du Trésor
- 03Sanctions économiques — mise en œuvre des mesures de gel
Direction générale du Trésor
- 04Financial Sanctions Database (FSD) — EU consolidated list files
European Commission
Frequently asked questions
Q&A- What does gel des avoirs actually mean in French law?
- It is an asset freeze with two limbs, the same structure as an EU freeze. Funds and economic resources belonging to or controlled by the listed party are immobilised, and no funds or economic resources may be made available to them or for their benefit, directly or indirectly. The measure is administrative and takes effect on publication.
- Is the French register just a copy of the EU list?
- Mostly, but not entirely, and the difference is the point of having it. Of the 6,578 measures published on 3 September 2026, 79 rest on a French arrêté with no EU or UN equivalent. If you screen only the EU consolidated list, those 79 are invisible to you while being fully binding in France.
- How do I download the gel des avoirs list in a machine-readable format?
- Call the public API at gels-avoirs.dgtresor.gouv.fr. The endpoint derniere-publication-fichier-json returns the whole current register as JSON, and the matching XML endpoint returns the same data; both have published schemas. No registration, no key, and the response carries the publication timestamp in its header.
- How often is the registre national des gels updated?
- Whenever a measure is made, which follows Council adoptions, UN committee decisions and French arrêtés rather than a calendar. DG Trésor offers a Flash info subscription that emails new freezes, modifications and removals. Read the DatePublication field in the file; that is the only statement of how current your copy is.
- Who do I report a match to in France?
- The Direction générale du Trésor. France, like every member state, enforces EU restrictive measures through its own competent authority, and that authority also administers the national freezes. Tracfin handles suspicious-transaction reporting, which is a separate obligation with a separate trigger.
- Does the register list vessels?
- Yes, but sparingly. There were 39 navires in the 3 September 2026 file, each carrying a NUMERO_OMI. That is a thin vessel schema next to the UK Sanctions List, so ship screening in a French programme still needs an IMO-based source rather than this register alone.
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