Prosecutors from France’s National Financial Prosecution Office (PNF) on 28 March 2023 raided the offices of 5 of the country’s major banks in the framework of a criminal probe into aggravated tax fraud through so-called cum-cum transactions. The raids are reported to have involved 160 members of the tax administration’s 250-strong financial judicial investigations division, and 16 of the PNF’s total of 19 prosecutors. Cum-cum transactions generally involve transfers (often through securities lending transactions) by non-residents of French stock to French banks close to the dividend declaration date, followed by their repurchase shortly thereafter. The purpose of the transaction is...