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CONSEIL NATIONAL DES GREFFIERS DES TRIBUNAUX DE COMMERCE

CNGTC

Le Conseil national des greffiers des tribunaux de commerce (CNGTC), est chargé d’assurer la défense des intérêts collectifs de la profession de greffier de tribunal de commerce.

Lobbying Activity

Meeting with Dan Dionisie (Head of Unit Justice and Consumers)

3 Dec 2025 · Business Wallet, 28th Regime

Response to EU Drugs Strategy and European Action Plan Against Drug Trafficking

26 Sept 2025

The Conseil National des Greffiers des Tribunaux de Commerce (CNGTC) represents registrars of Frances commercial courts. Through its management of the Trade and Companies Register (Registre du Commerce et des Sociétés - RCS)holding records on more than 6 million businessesand the Beneficial Ownership Register (RBE), the CNGTC guarantees the reliability, traceability, and accessibility of economic data. These registers are essential tools for securing transactions and enhancing transparency across the French and EU business landscape. By verifying company data at every stagefrom creation to dissolutionregistrars help prevent economic and financial risks. This oversight positions the CNGTC as a key economic policing authority, whose role in combating illicit financial flows was recognised by the FATF in its March 2022 evaluation of France. It is particularly strategic in the fight against money laundering, terrorist financing, and drug trafficking, as it enables the swift identification of opaque structures and criminal financial networks. Integrating Economic Intelligence into the EUs Fight Against Drug Trafficking: We welcome the Commissions initiative to establish a new European strategy on drugs. Updating existing frameworks and introducing concrete measures is essential to respond to the evolving dynamics of drug trafficking both within the EU and internationally. The proposed EU Action Plan against Drug Trafficking represents a major strategic lever. By targeting criminal networks and weakening their economic models, the plan can disrupt their operations and reduce their capacity to adapt. Because drug trafficking generates the largest illicit profits for criminal organisations, the economic dimension is fundamental. Their strength lies in their ability to convert illicit revenues into legal economic activity, often through registered companies. We therefore recommend that the future action plan give high priority to analysing and tackling the economic dimension of drug trafficking. Drawing on our White Paper, '15 proposals to strengthen the fight against financial crime', we put forward several recommendations that could usefully inform EU-level deliberations and strengthen the Unions ability to anticipate, prevent and contain threats posed by illicit drug markets. Selected Recommendations - Strengthen Economic Surveillance to Detect Fraudulent Companies Early One of our key proposals calls for granting commercial court registrars access to the National File of Bank Accounts and Similar (Ficoba). This access would allow verification of the bank accounts declared for depositing share capital, thereby improving ex-ante controls and significantly reducing false capital deposit certificates. Such strengthened controls would directly support the identification of shell companies often used to channel illicit financial flows, including those linked to drug trafficking. At EU level, similar mechanisms could be considered to give competent authorities secure access to bank account information for verification purposes. - Clean Up the European Economic Fabric Since 2023, French commercial court registrars have been empowered to strike companies off the Trade and Companies Register (RCS) if they fail to comply with beneficial ownership reporting obligations. If a company does not regularise its situation within three months of a formal notice, it may be automatically removed. This swift, targeted mechanism prevents dormant or shell companiesoften used by drug traffickers to launder money or conduct illicit transactionsfrom remaining operational. Without a business registration number, these entities cannot open a bank account or engage in commercial activity. In addition to this mechanism, registrars are now empowered to initiate ex officio deregistration proceedings when a company fails to declare its beneficial owners. (see the document).
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Response to Digital services for simplifying business operations and reducing administrative costs – the business wallet

12 Jun 2025

Presentation of the CNGTC and its missions The CNGTC serves as the representative body for France's Commercial Court Registrars. Our mission revolves around gathering, verifying, and distributing certified information via the Trade and Companies Register (RCS), which contains records on more than 6 million businesses. This registry is instrumental in fostering transparency and security in economic transactions across France and the EU. The commercial court registrar are also in charge of maintaining the beneficial ownership register. Additionally, it plays a key role in combating money laundering and overseeing insolvency proceedings. Given our engagement in every stage of a businesss existencefrom its establishment to its closurewe ensure the integrity and reliability of commercial data. Presentation of the challenges of the future EU Business Wallet and the CNGTC's positions The future EU Business Wallet aims to provide companies with a harmonized, legally recognized solution enabling them to identify themselves, authenticate themselves, share their certificates and receive official notifications throughout the European Union. This infrastructure is based on a cloud computing approach, guaranteeing interoperability, security and reliability of data exchanges. The CNGTC fully endorses this vision, and recognizes the major interest of this initiative in digitizing and simplifying companies' administrative processes. However, it is crucial to anticipate the challenges and points of vigilance, in order to avoid certain pitfalls linked to data security, governance and adoption of the system. The CNGTC thus highlights several critical points to be taken into account by the Commission while wring the proposal, to ensure the success of the EU Business Wallet: 1. Automatically secure the verification of companies identity with the business register, 2. Leverage existing solutions and ensure their interoperability with the future EU Business Wallet, 3. Harmonize and standardize the data exchanged on company identification, 4. Adopt a robust and secure technical architecture for the EU Business Wallet, based on a SaaS model. 5. Introduce certification for business wallet, and ensure that their suppliers are subject to strict specifications to reinforce trust and prevent fraud. 6. Facilitate the issuance and revocation of attestations, with an agile system enabling companies to manage their attestations efficiently, with appropriate trust registers to guarantee their authenticity. 7. Clarify the business model, including who will fund the EU Business Wallet and who will bear the costs. 8. Establish a harmonized EU Power of Attorney (EU PoA) framework to standardize the delegation of power within a secure, harmonized European framework, and ensure that it is integrated into the EU Business Wallet. 9. Encourage synergies between European initiatives to open up new use cases for the EU Business Wallet. These points are integrated and detailed in the attached annex.
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