The AMF Enforcement Committee has issued multiple enforcement decisions against financial investment advisors and their management for breaches of professional obligations, with the most recent and significant case involving Carat GP and its directors receiving combined fines of €2.5 million and permanent/extended bans from operating as financial investment advisors. These cases establish critical precedent regarding advisor duties around client disclosure, product authorization, conflict of interest management, and honest/fair conduct—requirements that apply across the entire financial investment advisory sector.
#
What Changed
The enforcement decisions clarify and reinforce several core professional obligations for financial investment advisors:
*Transparency and Disclosure Obligations**
Financial investment advisors must inform clients of any remuneration received for their advice and justify improvements to advisory services in return for compensation received. Advisors cannot recommend financial products without first ensuring their marketing is authorized in the relevant jurisdiction.
*Competence and Care Standa
What You Need To Do
- *Immediate Compliance Review
- *Governance and Documentation
- *Training and Culture
- *Regulatory Engagement
Key Dates
19 December 2023 - AMF Enforcement Committee decision against Séquence 13 and Jean-Louis Lehmann (€15,000 fines each; 5-year ban)
11 April 2022 - AMF Enforcement Committee decision against DCT and Didier Maurin (€150,000 and €200,000 fines; 5-year ban)
9 September 2024 - Conseil d'Etat judgment dismissing appeal by DCT and Didier Maurin
24 October 2022 - AMF Enforcement Committee decision against Salzillo Finance and Jean Salzillo (€20,000 and €80,000 fines; 3-year ban)
2 July 2019 - AMF Enforcement Committee decision against Invest Securities and financial advisors (€90,000 to €60,000 fines)
Compliance Impact
Urgency: HIGH