Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company for several breaches of its professional obligations
The AMF Enforcement Committee fined asset management company Altaroc Partners €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) on 15 September 2025 for multiple breaches of professional obligations, including lack of operational procedures for fund investments/divestments, inadequate AML/CFT due diligence, unproven benefits of fee retrocessions to distributors, and shortcomings in marketing materials. This decision underscores AMF's focus on operational controls, due diligence, and transparency in asset management, serving as a key enforcement precedent that highlights personal liability for senior managers. Compliance teams must review it to strengthen internal procedures and governance amid rising AMF scrutiny on these issues.
What Changed
This is an enforcement action, not a regulatory change introducing new rules; it enforces existing obligations under French financial regulations for asset management companies (sociétés de gestion de portefeuille). Key breaches clarified include:
Absence of operational procedures for investment/divestment processes, failing to verify lender authorizations, breaching duties to act honestly, fairly, professionally, with skill, care, and diligence.
Inability to demonstrate that retrocessed management fees to distributors improved client services.
Failure to systematically perform AML/CFT due...
What You Need To Do
- Implement and document operational procedures for all investment/divestment processes, including third-party authorization checks (e
- Conduct and document systematic AML/CFT due diligence on fund assets/liabilities, ensuring risk mapping and procedures are operational
- Substantiate retrocessions of fees to distributors with evidence of enhanced client services; otherwise, cease or disclose fully
- Review and enhance fund marketing materials for accuracy, comprehensiveness, and non-misleading content
- Senior managers
Key Dates
15 September 2025 - AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners and managers.
16 September 2025 - French version of press release published.
2025 09 (date not specified in available data).
Compliance Impact
Urgency: High - This recent (2025) decision signals intensified AMF enforcement on core operational failures in asset management, with total fines of €1.3 million and personal accountability, amid a pattern of similar actions (e.g., M Capital Partners €305,000 in Dec 2025, Eternam €400,000 in Sep 2025). It matters because AMF uses such rulings educationally to clarify expectations, increasing audit risks and penalties for non-compliance; firms without robust procedures face immediate exposure, especially with appeals not suspending applicability.
Asset Manager
Sustainable Finance Journalists Investment services providers Investment management companies Listed companies and issuers The ACPR and AMF publish their report on climate-related commitments of French financial institutions
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Warning Savings protection Miscellaneous assets Warning The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
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Warning Savings protection Forex and binary options Crypto-assets Warning The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
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Asset management Prospectus The AMF and the Banque de France publish an update of the inventory of liquidity management tools in French funds
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Professional certification Sustainable Finance Certification in sustainable finance: the AMF names the first certified training organisations
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Supervision The AMF updates its investigation and inspection charters
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Differential Pricing and Business Interruption Insurance demonstrate Central Bank’s focus on conduct, culture and customer treatment Over €130 million paid in business interruption insurance claims to date Insurance sector needs to be prepared for the challenges ahead including digitisation and climate change Speaking at the Deloitte 2022 Insurance Industry Trends event Director General, Financial Conduct Derville Rowland discussed the position of the insurance sector in Ireland, the effect o...
Insurance
Remarks by Director General, Financial Conduct Derville Rowland at the Deloitte Global Insurance Webinar Good morning everybody and thank you to Deloitte for the invitation to speak at this webinar. Some people think of insurance as a relatively modern financial concept. But of course, as the insurance experts in this audience know, its origins can be traced all the way back to certain kinds of shipping loans in Babylon, through Ancient Rome and Greece, and into Medieval Europe. In the 17 th ...
Insurance
Warning Savings protection Miscellaneous assets Warning The AMF is warning the public against several companies proposing atypical investments without being authorized to do so
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Sustainable Finance Annual report Disclosure Obligations Taxonomy Article 8: The AMF informs issuers about the phased application of reporting requirements
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Asset management Transposition of the directive on the cross-border distribution of collective investment undertakings: the AMF amends its General Regulation and its policy
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MMF The AMF publishes a study about potential explanatory variables for the record outflows that French MMFs faced in March 2020
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Review finds that differential pricing practices can result in unfair outcomes for some consumers Proposal to ban the practice of ‘price walking’ to end the loyalty penalty for consumers who do not switch insurance provider regularly Proposals will ensure that new business discounts are still available to allow consumers to seek the best prices, while ensuring that those who remain with the same insurance provider are not penalized The Central Bank is proposing to ban the practice of price wa...
The Central Bank of Ireland (CBI) proposes banning "price walking" in private car and home insurance to eliminate the loyalty penalty, where long-term customers pay significantly higher premiums (14% more for car, 32% more for home after 9 years) than new customers with similar risk profiles. This stems from a 2021 review finding differential pricing unfair to loyal or less mobile consumers, with regulations finalized and effective from 1 July 2022, confirmed effective in subsequent reviews. It matters as it enforces fair treatment under CBI's consumer protection mandate, requiring insurers to overhaul pricing models while preserving new customer discounts to maintain competition.
What Changed
Ban on price walking: Insurers cannot charge second or subsequent renewal customers a higher premium than an equivalent year-one renewal customer with similar risk and service cost.
Disclosure of new business discounts: Firms must clearly disclose to new customers that lower prices include a new business discount.
Annual pricing policy reviews: Providers must review pricing policies yearly to ensure focus on customer impact, adherence to rules, and fair treatment.
Automatic renewals requirements: Introduce consumer consent for automatic renewals and enhanced information/reminders to support...
What You Need To Do
- Pricing model adjustments
- Disclosure updates
- Governance and reviews
- Renewal processes
- Monitoring and reporting
Key Dates
22 October 2021 - Consultation period closes for proposals in the final report.
Early 2022 - CBI intends to finalize measures post-consultation.
15 March 2022 - Publication of final Insurance Requirements Regulations 2022.
1 July 2022 - Regulations apply to insurance undertakings and intermediaries; ban on price walking effective.
2023/2024 - CBI review confirms regulations working, no loyalty penalty observed, no further measures needed at that time.
Compliance Impact
Urgency: low (as of 2026). Rules have been effective since July 2022, with CBI's 2023/2024 review confirming no loyalty penalties, no unintended consequences, and market stability—Ireland was first EU state with such a ban. Firms compliant since 2022 face ongoing low-risk monitoring; non-compliance risks enforcement under Section 48(1), but positive outcomes reduce immediate pressure. Matters for legacy audits or CPC reviews.
Insurance
Asset management The AMF has postponed the effective date of the authorisation withdrawal of the asset management company Nestadio Capital
The Autorité des Marchés Financiers (AMF) postponed the effective date of the authorization withdrawal for Nestadio Capital, a portfolio asset management company, to allow time for fund transfers or liquidation following repeated non-compliance with authorization terms. This matters for compliance professionals as it illustrates AMF's enforcement approach to regulatory breaches in asset management, emphasizing orderly wind-downs to protect investors while signaling risks of judicial intervention if issues persist. The case culminated in judicial liquidation by 2022, highlighting long-term consequences for non-compliant firms.
What Changed
Initial authorization withdrawal decided on 17 December 2019 due to Nestadio Capital's failure to comply with authorization terms, including capital requirements, with original effective date at the latest 1 July 2020 (or upon fund transfer/liquidation).
Multiple postponements: 9 June 2020 and 8 December 2020 extended to 30 June 2021; 8 June 2021 further extended to 31 December 2021 to facilitate fund sales and liquidation.
7 December 2021 postponement tied withdrawal effect to full fund liquidation or judicial liquidation closure, triggered by commercial court judgment on 17 December 2021...
What You Need To Do
- For Nestadio Capital (historical)
- For investors
- For industry peers
- AMF referrals to courts underscore need for firms to self-report issues early to avoid escalation
Key Dates
17 December 2019 - AMF Board decides authorization withdrawal.
1 July 2020 - Original latest effective date for withdrawal (or fund transfer/liquidation).
9 June 2020 & **8 December 2020** - Postponements to **30 June 2021**.
8 June 2021 - Postponement to **31 December 2021** for fund sales/liquidation.
4 October 2021 - Conseil d'Etat rejects Nestadio's appeal.
Compliance Impact
Urgency: low - This is a resolved 2019-2022 enforcement case with no ongoing deadlines or new rules as of 2026; Nestadio is in judicial liquidation. It matters as a precedent for AMF's phased withdrawal process, protecting investors via extensions and liquidators, but warns asset managers of severe outcomes for breaches like capital shortfalls—review governance and capital monitoring to mitigate similar risks.
Asset Manager
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