Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti (SR 946.231.139.4) publiziert.
BankAsset ManagerWealth Manager Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung über Massnahmen betreffend Guatemala (SR 946.231.137.6) publiziert.
BankWealth ManagerAll Firms
Sanctions & settlements MAR Compliance Journalists Investment services providers The AMF Enforcement Committee fines an investment services provider and its director a total of €850,000
Broker DealerAll Firms
On 6 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 2.500 euros on BayWa Aktiengesellschaft.
The Federal Office of Justice (BfJ) imposed a €2,500 disciplinary fine on BayWa Aktiengesellschaft on 6 November 2025 for failing to submit its 2024 financial year accounting documents electronically to the Bundesanzeiger within the required period, breaching section 325 HGB. This enforcement action underscores BaFin's oversight of basic disclosure obligations under the German Commercial Code, serving as a reminder that even minor procedural lapses can trigger sanctions amid heightened scrutiny of listed companies' reporting. Compliance teams should note this as indicative of rigorous enforcement on timely electronic filings, particularly for firms under financial stress like BayWa.
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What Changed
This is not a regulatory change but an enforcement of existing requirements under the German Commercial Code (HGB):
Section 325 HGB: Mandates submission of accounting documents (e.g., annual financial statements, management reports) for public disclosure via the Bundesanzeiger operator in electronic form within prescribed deadlines (typically three months after fiscal year-end for annual reports).
Section 335 HGB: Provides the legal basis for disciplinary fines by the BfJ for non-compliance, wit
What You Need To Do
- Verify internal processes for electronic submission of accounting documents to Bundesanzeiger within HGB timelines (e
- Implement automated reminders and dual-checks in finance/reporting workflows to prevent delays, especially during restructurings or audits
- Review and update compliance calendars for all HGB-disclosure obligations; conduct training for finance teams on section 325/335 HGB
- Monitor Bundesanzeiger portal for submission confirmations and retain proofs of timely filing to defend against BfJ inquiries
- For firms like BayWa in StaRUG proceedings, coordinate with courts/legal advisors to file provisional disclosures if full audits are delayed
Key Dates
31 December 2024 End of BayWa AG's financial year; accounting documents due for submission shortly after (typically by 31 March 2025 for three-month deadline under section 325 HGB). DEADLINE
6 November 2025 BfJ issues disciplinary fine order for late submission.
23 January 2026 BaFin publishes the enforcement notice.
2026 _01_23_baywa_ag_2_en.html
Compliance Impact
Urgency: low – This is a minor fine (€2,500) for a procedural breach with no appeal, signaling routine enforcement rather than a policy shift. It matters as a low-cost warning for all HGB-reporting firms to automate filings, avoiding escalation in repeat cases or amid BaFin's focus on disclosure (e.
The Federal Office of Justice in Germany imposed a disciplinary fine of 2,500 euros on BayWa Aktiengesellschaft for failing to submit its accounting documents for the financial year 2024 in electronic form within the prescribed period. This action highlights the importance of compliance with section 325 of the German Commercial Code. Companies must ensure timely submission of financial reports to avoid similar penalties.
What Changed
The Federal Office of Justice enforced section 325 of the German Commercial Code, which requires companies to submit their accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form within the prescribed period.
What You Need To Do
- Ensure timely submission of accounting documents in electronic form to the German Federal Gazette
- Review internal procedures to guarantee compliance with section 325 of the German Commercial Code
Key Dates
6 Nov 2025 The Federal Office of Justice imposed a disciplinary fine on BayWa Aktiengesellschaft
Non-Compliance Risk
Disciplinary fines, such as the 2,500 euros imposed on BayWa Aktiengesellschaft, for non-compliance with section 325 of the German Commercial Code
Related Regulations
German Commercial Code (HGB)
Confidence: high
All Firms
On 6 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 2.500 euros on BayWa Aktiengesellschaft.
The Federal Office of Justice (BfJ) imposed a €2,500 disciplinary fine on BayWa Aktiengesellschaft on 6 November 2025 for failing to submit its 2024 consolidated accounting documents electronically to the Bundesanzeiger within the required period, violating section 325 HGB. This enforcement action underscores BaFin's oversight of financial reporting obligations under German law and serves as a reminder of strict deadlines for public disclosure, even amid corporate challenges like BayWa's ongoing restructuring. Compliance teams should note it as a low-value but procedurally significant sanction, highlighting risks of administrative penalties for late filings.
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What Changed
This is not a regulatory change but an enforcement of existing requirements under the German Commercial Code (HGB):
Section 325 HGB: Mandates submission of consolidated accounting documents (e.g., annual financial statements, management reports) for disclosure in electronic form to the Bundesanzeiger operator within prescribed periods (typically three months after fiscal year-end for AGs, i.e., by 31 March for calendar-year filers).
Section 335 HGB: Provides the legal basis for disciplinary fine
What You Need To Do
- Verify filing processes
- Conduct gap analysis
- Train staff
- Monitor Bundesanzeiger confirmations
- No appeal if fined
Key Dates
31 March 2025 - Presumed deadline for BayWa to submit 2024 consolidated documents (three months post-31 December FY-end under § 325 HGB para. 1). DEADLINE
6 November 2025 - Date BfJ imposed the €2,500 fine.
23 January 2026 - BaFin publication date of the enforcement notice[https://www.bafin.de/SharedDocs/Veroeffentlichungen/EN/Massnahmen/40c_neu_124_WpHG/neu/meldung_2026_01_23_baywa_ag_1_en.html].
Compliance Impact
Urgency: low - Fine is minimal (€2,500), procedural (no market manipulation or fraud), and isolated to one late filing amid BayWa's broader crises (e.g., forecast withdrawal 6 Oct 2025[https://www.investegate.co.uk/announcement/eqs/baywa-ag-baywa-ord-shs--0ah7/eqs-adhoc-baywa-ag-baywa-ag-withdraws-f
The Federal Office of Justice in Germany imposed a disciplinary fine on BayWa Aktiengesellschaft for failing to submit its consolidated accounting documents for the financial year 2024 within the prescribed period. This action highlights the importance of timely submission of financial reports. Companies must ensure compliance with section 325 of the German Commercial Code to avoid similar penalties.
What Changed
The Federal Office of Justice imposed a disciplinary fine due to a breach of section 325 of the German Commercial Code, which requires companies to submit their consolidated accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form within the prescribed period.
What You Need To Do
- Ensure timely submission of consolidated accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form
- Review and update internal procedures to comply with section 325 of the German Commercial Code
Key Dates
6 Nov 2025 The Federal Office of Justice imposed a disciplinary fine on BayWa Aktiengesellschaft
Non-Compliance Risk
Disciplinary fine of up to 2,500 euros for non-compliance with section 325 of the German Commercial Code
Related Regulations
German Commercial Code (HGB)
Confidence: high
All Firms
No description available.
The Hong Kong Securities and Futures Commission (SFC) successfully prosecuted retail trader Ng Ka Hei for seven counts of false trading involving six Main Board-listed companies, resulting in conviction on January 22, 2026. This enforcement action demonstrates the SFC's active surveillance and prosecution of market manipulation tactics, specifically "scaffolding" and wash trading strategies that artificially inflate share prices and mislead market participants.
What Changed
This is not a regulatory change but rather an enforcement precedent establishing that:
"Scaffolding" strategy is prosecutable: Repeatedly placing and cancelling trading orders at progressively higher prices constitutes false trading under section 295 of the Securities and Futures Ordinance.
Wash trading across multiple accounts is actionable: Using various securities accounts to simultaneously act as both buyer and seller of shares violates false trading prohibitions.
Price impact + market de
What You Need To Do
- *For brokers and licensed intermediaries
- *Enhance surveillance systems to detect scaffolding patterns (repeated placement and cancellation of orders at progressively higher prices)
- *Monitor cross-account trading to identify wash trading where the same beneficial owner trades with themselves across multiple accounts
- *Implement controls to flag suspicious trading activity that artificially impacts share prices without genuine economic purpose
- *Document compliance procedures for detecting and reporting false trading under section 295 of the Securities and Futures Ordinance
Key Dates
20 September 2022 – 24 October 2023 Period during which false trading occurred
22 January 2026 Conviction date (Eastern Magistrates' Courts)
12 February 2026 Sentencing hearing (case adjourned)
Compliance Impact
Urgency: HIGH
The Securities and Futures Commission (SFC) has convicted a retail trader for false trading in the shares of six Hong Kong-listed companies, highlighting the importance of market integrity and the need for firms to monitor and prevent such activities. The conviction demonstrates the SFC's commitment to enforcing securities laws and protecting market participants. Firms should review their trading practices and ensure they have adequate controls in place to prevent false trading.
What Changed
The SFC has successfully prosecuted a case of false trading under section 295 of the Securities and Futures Ordinance, which constitutes an offence.
What You Need To Do
- Implement or review existing controls to detect and prevent false trading, including monitoring for suspicious trading patterns such as 'scaffolding' and wash trades
- Provide training to trading staff on the risks and consequences of false trading
Key Dates
12 Feb 2026 Sentencing of Mr Ng Ka Hei
Non-Compliance Risk
Enforcement action, fines, and reputational damage may result from non-compliance with securities laws and regulations related to false trading.
Related Regulations
Securities and Futures Ordinance
Confidence: high
Broker DealerAll Firms
Policy Statement 2/26
The PRA's PS2/26 finalizes the retirement of the "refined methodology" in Pillar 2A capital requirements, effective 1 January 2027, aligning with Basel 3.1 implementation to simplify the framework by eliminating an operationally burdensome adjustment originally designed to address conservatism in the standardized approach (SA) to credit risk. This matters for compliance professionals as it reduces complexity in ICAAP and SREP processes, with expected neutral aggregate capital impact, though firm-specific effects may vary and require supervisory engagement.
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What Changed
Retirement of refined methodology: The refined methodology, introduced in 2018 (PS22/17) to mitigate perceived conservatism in CR SA relative to IRB for lower-risk assets, is fully retired from Pillar 2A as Basel 3.1 CR SA enhancements achieve similar risk sensitivity without it. No transitional period; immediate replacement by Basel 3.1 standards.
Amendments to SS31/15: Updates to Supervisory Statement 31/15 on ICAAP and SREP (Appendix 1), including minor prior adjustment to paragraph 5.12A for
What You Need To Do
- Review and update ICAAP/SREP processes
- Recalculate Pillar 2A requirements
- Align with related frameworks
- Monitor firm-specific impacts
- Governance and reporting
Key Dates
2024 CP9/24 consultation on streamlining Pillar 2A, including proposal to retire refined methodology.
28 October 2025 PS18/25 near-final policy published.
20 January 2026 PS2/26 final policy published.
1 January 2027 Effective date for retirement of refined methodology; aligns with Basel 3.1 implementation (PS1/26), CRR restatement (PS3/26), and SDDT simplified regime (PS4/26).
Compliance Impact
Urgency: High – With less than 11 months to 1 January 2027 effective date (as of January 2026 publication), firms face immediate need to remodel Pillar 2A under Basel 3.1, potentially affecting capital planning, stress testing, and regulatory reporting. Non-compliance risks supervisory scrutiny duri
The Prudential Regulation Authority (PRA) has finalized the policy to retire the refined methodology to Pillar 2A, which will take effect on January 1, 2027, aligning with the implementation of the Basel 3.1 standards. This change affects all PRA-regulated banks, building societies, and designated investment firms. The refined methodology will no longer apply to these firms, including Small Domestic Deposit Takers (SDDTs), as they will be subject to the Basel 3.1 standardized approach to credit risk.
What Changed
The PRA has retired the refined methodology to Pillar 2A, which was previously used to determine capital requirements for firms. The new policy aligns with the Basel 3.1 standards and introduces a simplified capital regime for SDDTs.
What You Need To Do
- Update internal capital adequacy assessment processes (ICAAP) to reflect the changes to Pillar 2A
- Review and implement the Basel 3.1 standardized approach to credit risk
- Ensure compliance with the new simplified capital regime for SDDTs, if applicable
Key Dates
1 Jan 2027 The policy to retire the refined methodology to Pillar 2A takes effect, aligning with the implementation of the Basel 3.1 standards DEADLINE
Non-Compliance Risk
Failure to comply with the new policy may result in enforcement action, fines, or other regulatory penalties
Related Regulations
Basel 3.1CRR
Confidence: high
Bank
No description available.
The CFTC announced three major enforcement actions on January 16, 2026, resolving cases involving **market manipulation (spoofing), misappropriation of confidential information, and unregistered commodity pool operations**. These cases demonstrate the CFTC's continued enforcement focus on fraudulent trading practices and registration violations, with combined penalties exceeding $685,000 and criminal sentences totaling over six years in prison.
What Changed
The enforcement actions establish precedent in three critical areas:
*Market Manipulation (Spoofing): The CFTC secured consent orders against precious metals futures traders for spoofing—placing and canceling orders to create false market impressions. The orders impose three-year and six-month trading bans** and require cease-and-desist compliance with the Commodity Exchange Act's spoofing prohibition.
*Misappropriation and Fictitious Trading: The CFTC obtained permanent injunctive relief requ
What You Need To Do
- *For Registered Futures Firms and Banks
- trade and post-trade compliance controls
- *For Commodity Pool Operators and Investment Advisors:
- by-jurisdiction licensing analyses before soliciting investors
- *For All Market Participants
Key Dates
September 2019 - CFTC enforcement action filed against Smith and Nowak
December 2021 - CFTC complaint filed against Miller and Omerta Capital; DOJ criminal charges filed
December 2022 - CFTC complaint amended against Miller and Omerta Capital
August 2023 - Smith and Nowak sentenced to prison (criminal case)
June 2024 - Miller sentenced to prison (criminal case)
Compliance Impact
Urgency: HIGH
The CFTC has announced enforcement updates, including civil monetary penalties and trading bans for spoofing in precious metals futures markets and misappropriating confidential information. These updates highlight the importance of compliance with CFTC regulations. Firms must ensure they are registered and comply with anti-spoofing and anti-fraud regulations.
What Changed
The CFTC has obtained federal court orders imposing civil monetary penalties and trading bans on individuals and firms for spoofing and misappropriating confidential information. The CFTC has also charged an unregistered commodity pool operator with fraud and registration violations.
What You Need To Do
- Verify registration with the CFTC at NFA BASIC before committing funds
- Review and update anti-spoofing and anti-fraud policies and procedures
- Ensure compliance with CFTC regulations regarding commodity pool operations and futures market participation
Key Dates
1 Sept 2021 CFTC enforcement action filed against Gregg Smith and Michael Nowak
10 Dec 2021 Department of Justice charged Peter Miller with conspiracy to commit commodities fraud
1 Jun 2024 Peter Miller sentenced to five months in prison and five months of home confinement
10 Dec 2024 Department of Justice charged Travis Ford with conspiracy to commit wire fraud
Non-Compliance Risk
Enforcement action, fines, trading bans, and registration revocation
Related Regulations
Commodity Exchange ActCFTC regulations
Confidence: high
Broker DealerAsset ManagerCrypto Exchange Communiqué
The CSSF's January 2026 enforcement report documents the results of its 2025 examination campaign on 2024 financial and non-financial disclosures by issuers under Luxembourg's Transparency Law. This publication is critical for compliance professionals because it reveals systematic compliance gaps across financial reporting (IFRS), sustainability reporting (ESRS), and Alternative Performance Measures (APMs), with 27% of enforcement decisions resulting in injunctions for non-compliance.
What Changed
The regulatory landscape has evolved significantly with the introduction of new sustainability reporting requirements:
ESRS Implementation (First Year): 2024 marked the first full reporting year under the European Sustainability Reporting Standards (ESRS), with the CSSF conducting a fact-finding exercise to assess reporting quality. The CSSF noted an overall increase in reporting quality with better-structured reports and more relevant disclosures, though key improvement areas remain in compreh
What You Need To Do
- *Financial Information (IFRS)
- *Enhanced Note Disclosures
- *Cash Flow Statement Presentation
- *Segment Reporting Completeness
- *Going Concern Assessment
Key Dates
4 July 2025 - European Commission adopted Delegated Act amending Taxonomy Disclosures (Omnibus package)
18 August 2025 - CSSF published full results of fact-finding exercise on ESRS reporting
5 December 2024 - CSSF published enforcement priorities press release for FY2024 reporting
January 2026 - CSSF published enforcement results report (current publication)
Compliance Impact
Urgency: HIGH
All Firms
On 07 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 50.000 euros on pferdewetten.de AG.
The Federal Office of Justice (BfJ) imposed a €50,000 disciplinary fine on pferdewetten.de AG on November 7, 2025, for violations related to the publication of financial reports under German securities law (WpHG - Wertpapierhandelsgesetz). This enforcement action underscores regulatory expectations for timely and accurate financial disclosure compliance, particularly for publicly traded or regulated entities in the gaming/betting sector.
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What Changed
Based on the enforcement context, the regulatory requirements at issue involve:
Financial Reporting Obligations: Entities subject to WpHG must publish financial reports in accordance with statutory deadlines and content requirements
Disclosure Standards: Reports must meet quality and completeness standards established under German securities law
Enforcement Mechanism: The BfJ has authority to impose disciplinary fines for non-compliance with publication requirements
No Safe Harbor: Delayed or d
What You Need To Do
- *Audit Current Compliance
- *Strengthen Internal Controls
- *Document Procedures
- *Monitor Deadlines
- *Legal Review
Key Dates
November 7, 2025 - BfJ imposed €50,000 disciplinary fine on pferdewetten.de AG
January 15, 2026 - BaFin published enforcement action notice
Ongoing - WpHG financial reporting obligations remain in effect with no stated grace period modifications
Compliance Impact
Urgency Rating: HIGH
All Firms
On 07 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 50.000 euros on pferdewetten.de AG.
The Federal Office of Justice (BfJ) imposed a €50,000 disciplinary fine on pferdewetten.de AG on 7 November 2025 for violations related to the publication of financial reports under the German Securities Trading Act (WpHG). This enforcement action underscores BaFin's and BfJ's strict oversight of timely and accurate financial disclosures by public companies, serving as a warning to listed firms on the consequences of non-compliance. It matters because it highlights procedural lapses in ad-hoc publicity and annual reporting, potentially increasing scrutiny on similar entities amid ongoing regulatory emphasis on market integrity.
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What Changed
This is not a regulatory change or new requirement but an enforcement decision enforcing existing obligations under § 37w WpHG (disciplinary measures for breaches of publication duties) and related provisions of the WpHG. Key requirements reiterated include:
Timely publication of annual financial reports and ad-hoc announcements via electronic means (e.g., DGAP platform).
Ensuring completeness and accuracy of published financial statements, including management reports.
Immediate correction of a
What You Need To Do
- Conduct an internal audit of recent financial report publications (last 12-24 months) for timeliness, accuracy, and platform compliance (e
- Implement or enhance pre-publication checklists, including dual approvals and automated validation tools to flag delays or errors
- Train IR and compliance staff on WpHG §§ 15, 111-114 (ad-hoc and periodic reporting) and § 37w (sanctions)
- Review outsourcing arrangements for reporting (e
- Document remedial actions and report to the supervisory board; consider voluntary self-disclosure for any identified breaches to mitigate fines
Key Dates
07 November 2025 - Date BfJ imposed the €50,000 disciplinary fine on pferdewetten.de AG.
Compliance Impact
Urgency: Medium. This matters as a concrete example of BfJ's willingness to levy fines (here €50,000, modest but precedential) for reporting lapses, signaling heightened enforcement post-2025 ESMA-aligned updates to transparency rules. Firms with similar profiles face elevated audit risk, especially
All Firms
On 7 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 50,000 euros on TTL Beteiligungs- und Grundbesitz-AG
The Federal Office of Justice (BfJ) imposed a €50,000 disciplinary fine on TTL Beteiligungs- und Grundbesitz-AG on 7 November 2025 for failing to publish required financial reports, violating transparency obligations under the German Securities Trading Act (WpHG). This enforcement action underscores BaFin's heightened focus on financial reporting compliance for listed companies, serving as a warning for timely and accurate disclosures amid strategic priorities on market integrity and early risk detection. Compliance teams should view it as a signal of rigorous enforcement against reporting lapses, potentially leading to escalated penalties for repeat or severe breaches.
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What Changed
No new regulatory changes are introduced; this is an enforcement case applying existing WpHG requirements for periodic financial reporting by publicly listed entities. The case reinforces the statutory duty under Section 40c WpHG (as referenced in the BaFin publication title) to publish financial reports promptly, with BfJ acting as the disciplinary authority for such violations. It aligns with BaFin's ongoing risk-based enforcement on financial reporting for publicly traded companies, emphasizi
What You Need To Do
- Conduct immediate gap analysis of financial reporting processes to ensure compliance with WpHG Sections 37 et seq
- Implement automated monitoring and reminders for publication deadlines (e
- Strengthen internal controls, including pre-publication reviews by compliance and legal teams, with escalation to senior management
- Train responsible personnel on disciplinary risks, documenting adherence to avoid BfJ fines (up to €5 million or 3% of turnover for severe cases)
- For listed firms, integrate reporting into broader governance frameworks, aligning with BaFin's data-driven supervision expectations
Key Dates
7 November 2025 - BfJ imposes €50,000 disciplinary fine on TTL Beteiligungs- und Grundbesitz-AG for financial reporting violations.
Compliance Impact
Urgency: Medium - This fine is modest (€50,000) and targets a specific reporting failure, not systemic issues like AML or IT deficiencies seen in larger cases (e.g., J.P. Morgan's €45 million fine). It matters as a precedent in BaFin's 2026-2029 strategy prioritizing market transparency, financial r
All Firms
On 7 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 50,000 euros on TTL Beteiligungs- und Grundbesitz-AG
The Federal Office of Justice (BfJ) imposed a €50,000 disciplinary fine on TTL Beteiligungs- und Grundbesitz-AG on 7 November 2025 for failing to publish required financial reports, highlighting enforcement of financial reporting obligations under German securities law (WpHG). This case underscores BaFin's and BfJ's commitment to market transparency and integrity, serving as a warning to listed companies on the consequences of non-compliance with ad-hoc and periodic reporting duties. Compliance professionals should note it as evidence of intensified scrutiny on reporting accuracy amid BaFin's 2026-2029 strategic priorities.
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What Changed
No new regulatory changes are introduced; this is an enforcement action enforcing existing requirements under the German Securities Trading Act (WpHG § 124), which mandates timely publication of financial reports for publicly listed companies. The case reaffirms the disciplinary framework where BfJ, as the competent authority, can impose fines up to €700,000 (or 5% of turnover) for violations, with this €50,000 fine reflecting a proportionate measure for the breach. It aligns with BaFin's strate
What You Need To Do
- Conduct immediate gap analysis of financial reporting processes to ensure compliance with WpHG §§ 37c, 115, and 124 on publication of annual, half-yearly, and ad-hoc reports via electronic means (e
- Implement automated monitoring and reminders for reporting deadlines, with dual sign-off by compliance and finance teams
- Train management on personal liability for reporting failures, including documentation of internal controls to demonstrate due diligence in supervisory reviews
- For firms with similar profiles, voluntarily self-report past lapses to BfJ/BaFin to potentially mitigate fines, referencing this case as precedent
Key Dates
7 November 2025 - Date BfJ imposed the €50,000 disciplinary fine on TTL Beteiligungs- und Grundbesitz-AG for financial reporting violations.
Compliance Impact
Urgency: Medium - This fine, while modest, signals BfJ's active enforcement role in financial reporting, amplified by BaFin's 2026-2029 strategy prioritizing "market transparency and integrity" through increased monitoring of publicly traded companies. It matters because reporting breaches erode inv
All Firms
Introduction Good morning and thank you to Michael for inviting me to speak at the Compliance Institute’s Annual General Meeting. It is always a real pleasure to engage with compliance professionals. At the Central Bank, we recognise the essential role played by the compliance community in ensuring that financial firms are well-run and contributing to a financial system that is trusted and resilient. We also recognise the important role played by the compliance institute, equipping those work...
This speech by Gerry Cross, Director of Capital Markets and Funds at the Central Bank of Ireland (CBI), outlines key supervisory priorities including securing customers' interests via the revised Consumer Protection Code, Individual Accountability Framework (IAF) implementation, regulatory simplification, resilience, technology leverage, and an evolving outcomes-focused supervision approach. It matters because it signals CBI's expectations for compliance professionals to drive these outcomes in firms, emphasizing proportionality and ongoing engagement amid regulatory evolution. Compliance teams must integrate these themes to align with CBI's shift toward less process-driven, more effective oversight.
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What Changed
Revised Consumer Protection Code: Introduces new Standards for Business, building on the Code reviewed with industry input; focuses on delivering good outcomes for consumers and the economy.
Individual Accountability Framework (IAF): Implemented 18 months prior (circa mid-2024); enhances clarity on responsibilities, supports governance, and aligns with outcomes-focused regulation rather than enforcement-heavy approaches.
Supervisory Approach Evolution: Shifting in 2025-2026 to risk-based, outcom
What You Need To Do
- Implement Revised Consumer Protection Code
- Adopt Outcomes-Focused Practices
- Engage with CBI
- Leverage Technology
Key Dates
24 March 2026 - Revised Consumer Protection Code comes into force; firms must ensure full readiness and ongoing embedding of provisions, including new Standards for Business. DEADLINE
January 2026 speech).
Compliance Impact
Urgency: Medium. This speech reinforces imminent obligations like the 24 March 2026 Consumer Protection Code effective date (less than 2 months from speech/publication), requiring immediate readiness checks, but lacks new rules or critical enforcement threats. It matters for long-term alignment with
Asset ManagerBankAll Firms
ESMA promotes clarity in communications on ESG strategies 14 January 2026 Sustainable finance The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, published today a second thematic note on sustainability-related claims, focusing on ESG strategies. The note concentrates on ESG integration and ESG exclusions, as references to these strategies are often made by market participants and widely referenced in marketing communications directed to ...
ESMA published a thematic note on January 14, 2026, providing guidance on clear, fair, and not misleading communications regarding ESG strategies, specifically ESG integration and ESG exclusions, to mitigate greenwashing risks in non-regulatory materials like marketing. This matters because sustainability claims heavily influence investor decisions, and misleading communications can lead to supervisory actions, reputational damage, and loss of trust, aligning with existing EU rules under SFDR and related frameworks without imposing new disclosures.
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What Changed
This is not a formal regulatory change but supervisory guidance reinforcing four principles for non-regulatory communications (e.g., marketing materials, websites, investor presentations, voluntary reports):
Accurate: Claims must fairly represent sustainability profiles without exaggeration, falsehoods, omissions, cherry-picking, vagueness, or misleading ESG terminology/imagery.
Accessible: Information must be easy to understand and navigate, with layered substantiation in electronic formats
What You Need To Do
- Review and update all non-regulatory ESG communications (marketing, websites, presentations, DDQs, PPMs) against the four principles and do's/don'ts
- Define and clearly explain ESG integration/exclusions (e
- Ensure consistency across channels, substantiate claims with accessible evidence, and avoid vagueness or overstatements
- Train compliance/marketing teams; monitor for updates as further thematic notes may follow
- Cross-reference with first note and regulations like SFDR, Cross-Border Distribution Regulation
Key Dates
14 January 2026 - Publication date of the thematic note on ESG strategies (second in series).
1 July 2025 - Publication of ESMA's first thematic note on ESG credentials (to be read in combination).
Compliance Impact
Urgency: High – Immediate risk of enforcement for greenwashing in high-visibility ESG marketing, amid rising supervisory scrutiny; non-compliance threatens fines, remediation, and reputational harm as investor focus on sustainability grows. Proactive alignment builds trust and differentiates firms.
Asset ManagerAll Firms
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 2 der Verordnung vom 22. Juni 2005 über Massnahmen gegenüber der Demokratischen Republik Kongo (SR 946.231.12) publiziert.
The Swiss Federal Department for Economic Affairs, Education and Research (WBF) updated Annex 2 of the Ordinance on Measures against the Democratic Republic of Congo (SR 946.231.12) on January 12, 2026, modifying the list of sanctioned persons, companies, and organizations, with changes effective January 13, 2026, at 23:00 UTC. This matters for Swiss financial intermediaries as it triggers immediate asset freezing, reporting to SECO, and potential AML checks under the Anti-Money Laundering Act (GwG), ensuring compliance with Switzerland's implementation of international sanctions via the Embargo Act (EmbG).
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What Changed
Amendment to Annex 2 of SR 946.231.12, updating the list of sanctioned individuals, entities, and organizations subject to financial restrictions.
Integration into the SECO Sanctions Management (SESAM) database, with urgent publication on the SECO website.
Reinforcement of prohibitions: asset freezing, ban on making funds available, and reporting of affected business relationships to SECO; does not exempt from GwG Art. 6 due diligence or Art. 9 suspicious activity reports.
These align with ongoi
What You Need To Do
- Screen client portfolios and transactions against the updated SESAM database immediately upon effectiveness
- Freeze assets of newly listed sanctioned parties and prohibit making funds/resources available
- Report affected business relationships to SECO without delay
- Conduct GwG Art
- Monitor MyFINMA for FINMA alerts and update internal sanctions screening tools
Key Dates
January 12, 2026 - WBF publishes amendment to Annex 2.
January 13, 2026, 23:00 UTC - Changes enter into force; immediate implementation required. DEADLINE
December 12, 2026 - Related EU sanctions extended to this date (Swiss alignment expected).
Compliance Impact
Urgency: High - Immediate effect from January 13, 2026, 23:00 UTC demands rapid screening and freezing to avoid EmbG violations, which can trigger FINMA enforcement (e.g., fines, license actions). Matters due to sanctions lists' frequent updates (e.g., prior May 2024 change) and overlap with AML obl
BankAsset ManagerWealth Manager Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen des Anhangs 1 der Verordnung vom 28. März 2018 über Massnahmen gegenüber Venezuela (SR 946.231.178.5) publiziert.
On January 13, 2026, Switzerland's State Secretariat for Economic Affairs (SECO) updated Annex 1 of the Ordinance on Measures against Venezuela (SR 946.231.178.5), reflecting changes to the list of designated persons and entities subject to Swiss asset freezing measures. This update is critical for Swiss financial institutions and regulated entities as it directly impacts sanctions compliance obligations and requires immediate verification of client and counterparty lists against the revised designations.
What Changed
The regulatory update modifies the designated persons list under Switzerland's unilateral freezing measures against Venezuela. While the search results reference a separate FINMA ordinance (RS 196.127.85) adopted on January 5, 2026, which froze assets of 37 persons in the context of Venezuela, the January 13 update to SR 946.231.178.5 represents an amendment to Switzerland's broader sanctions ordinance framework. The specific changes to Annex 1 require Swiss entities to:
Update their sanctions
What You Need To Do
- *Immediate Screening
- *Asset Identification
- *Freeze Implementation
- *Notification
- *Transaction Review
Key Dates
January 5, 2026 - FINMA ordinance on asset freezing (RS 196.127.85) enters into force at 11 a.m., freezing assets of 37 designated persons
January 13, 2026 - SECO publishes updated Annex 1 to SR 946.231.178.5 (the update referenced in your query)
Immediate - Compliance obligations commence upon publication; no grace period for implementation DEADLINE
Compliance Impact
Urgency: CRITICAL
BankWealth ManagerAsset Manager Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen der Verordnung vom 4. März 2022 über Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) publiziert.
The Swiss Federal Department for Economic Affairs, Education and Research (WBF) has published updates to the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning Swiss sanctions with ongoing international restrictions targeting Russia. This matters for Swiss financial institutions as it reinforces asset freezing and economic resource restrictions, heightening compliance risks amid prolonged geopolitical tensions, with the ordinance valid until at least November 2026.
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What Changed
The publication announces amendments to SR 946.231.176.72, though specific details in the notice are limited; it signals ongoing refinements to sanctions measures originally enacted on March 4, 2022. Related documentation indicates persistent expansions, such as broader restrictions on Russian energy sector activities (e.g., prohibiting certain services, financing, and transactions), definitions encompassing financial instruments like derivatives, crypto-assets, and securitizations, and prohibit
What You Need To Do
- Block prohibited activities in energy sector, financial services (e
- Update internal policies, screening tools, and training to reflect changes; maintain records of compliance checks and authorizations (if applicable under Article 11)
- Monitor FINMA's sanctions page for full ordinance text and related guidance
Key Dates
January 13, 2026 - Publication of amendments by WBF, triggering immediate review obligations.
Various historical dates (e.g., March 25, 2022 at 23:00; January 25, 2023 at 18:00) - Prior amendment effective dates, illustrating pattern of rapid implementation.
November 22, 2026 - Current expiry of ordinance (subject to extension).
Compliance Impact
Urgency: High - Ongoing amendments to this long-standing ordinance (active since 2022) demand immediate screening and blocking to avoid FINMA enforcement, fines, or reputational damage, especially with crypto and energy sector expansions capturing evolving risks. Non-compliance risks asset release v
BankPayment ProviderCrypto Exchange The Securities and Exchange Commission today announced that Paul H. Tzur and David M. Morrell have been named as Deputy Directors of the Division of Enforcement. Mr. Tzur joined the Commission on January 6, 2026, as the Deputy Director overseeing the…
The SEC announced on January 12, 2026, the appointment of Paul H. Tzur and David M. Morrell as Deputy Directors of the Division of Enforcement, with Tzur joining on January 6, 2026, to oversee key operations. This personnel change is part of a broader reorganization replacing Regional Directors with Deputy Directors for more centralized oversight of investigations. It matters for compliance teams as it signals greater consistency in enforcement approaches, potentially affecting investigation timelines, Wells process strategies, and settlement negotiations across SEC-regulated entities.
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What Changed
This announcement reflects structural reforms rather than new substantive regulations:
Replacement of Regional Directors with Deputy Directors, centralizing reporting from local offices (e.g., Boston, Fort Worth, Atlanta) and specialized units directly to headquarters-led Deputy Directors.
Enhanced supervision of enforcement decisions, aiming for consistency and reduced regional variations in handling investigations.
Complements parallel Wells process reforms under Chairman Paul Atkins, includin
What You Need To Do
- Review and update internal protocols for SEC investigations to align with centralized reporting structures, anticipating uniform standards across regions
- Train legal/compliance staff on refined Wells process (e
- Monitor upcoming SEC communications for Enforcement Director Judge Margaret Ryan's guidance on fraud-focused priorities
- Assess current or potential matters for earlier engagement with Deputy Directors on case theories and resolutions
Key Dates
January 6, 2026 - Paul H. Tzur joins SEC as Deputy Director of the Division of Enforcement.[User Query]
January 12, 2026 - SEC announces appointments of Paul Tzur and David Morrell as Deputy Directors.[User Query]
Compliance Impact
Urgency: Medium. This matters due to its role in ongoing SEC transition under Chairman Atkins and Director Ryan, promising more predictable enforcement but requiring adaptation to centralized decision-making and Wells enhancements. While not imposing immediate obligations, it could accelerate case r
Asset ManagerBroker DealerHedge Fund Administrative sanction imposed on BigRep SE
The CSSF imposed a €10,000 administrative fine on BigRep SE on 12 January 2026 for failing to publish its half-yearly financial report as of 30 June 2025, as required under Article 4 of Luxembourg's Transparency Law of 11 January 2008 (as amended). This enforcement action underscores the CSSF's rigorous supervision of periodic disclosure obligations for issuers with Luxembourg as their home Member State, serving as a reminder of the consequences for non-compliance with transparency requirements. Compliance professionals should note this as evidence of ongoing CSSF scrutiny on timely reporting, with potential fines scaled based on circumstances per Article 26a.
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What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the Transparency Law of 11 January 2008 (as amended), specifically Article 4, which mandates issuers to publish half-yearly financial reports, including effective dissemination, storage on the Officially Appointed Mechanism (OAM), and filing with the CSSF. No new rules are introduced; the sanction reinforces the unchanged deadlines and processes for periodic information publication, with the CSSF
What You Need To Do
- All affected parties
- BigRep SE specifically
- wide actions are mandated beyond general adherence, but proactive audits are advisable given CSSF's supervisory focus
Key Dates
30 June 2025 - Period-end date for the required half-yearly financial report that BigRep SE failed to publish. DEADLINE
12 January 2026 - Date of administrative sanction imposition by CSSF and publication of the decision.
Within 3 months of 12 January 2026 (i.e., by 12 April 2026) - Deadline for BigRep SE to lodge a court action with the Tribunal administratif against the sanction, per Article 27 of the Transparency Law. DEADLINE
Compliance Impact
Urgency: Medium – This matters as a specific enforcement example in CSSF's ongoing verification of periodic information publication, signaling heightened scrutiny rather than a systemic shift. While the €10,000 fine is modest, it demonstrates fines for even isolated breaches (scaled per Article 26a)
All Firms
No description available.
This CSSF publication, dated January 12, 2026, identifies the specific population (likely a firm or individual) subject to an enforcement action, such as an administrative sanction, as part of the CSSF's transparency in supervisory measures. It matters because it signals CSSF's active enforcement priorities, potentially in areas like AML or reporting failures, enabling firms to assess similar risks in their operations and strengthen compliance to avoid parallel actions. Published amid rising focus on financial crime typologies like sexual extortion, it underscores the regulator's commitment to public accountability.
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What Changed
No new regulatory changes or requirements are introduced in this publication, as it is an enforcement notice rather than a circular or guideline. It serves as a disclosure of an ongoing or concluded enforcement case, aligning with CSSF's practice of publishing sanction details to deter non-compliance and inform the market, without altering existing rules.
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What You Need To Do
- For the named population
- For all supervised firms
- Update internal policies, train staff on enforcement precedents, and ensure robust reporting under Circular CSSF 19/726 or Transparency Law obligations
Compliance Impact
Urgency: High – Immediate relevance for the named party facing direct consequences; medium-to-high for peers due to CSSF's pattern of public enforcements signaling heightened scrutiny on financial crime, especially amid rising OCSE/FSEC cases noted in recent CSSF guidance. It matters as it could pre
BankPayment ProviderAll Firms
Administrative sanction imposed on the alternative investment fund manager Premium Capital Management (“AIFM”)
The CSSF imposed a €10,000 administrative fine on 11 September 2025 against alternative investment fund manager (AIFM) Premium Capital Management for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties, signaling heightened scrutiny on timely supervisory cooperation amid ongoing AML risks in Luxembourg. Compliance teams should view this as a reminder of the low tolerance for even administrative lapses, with potential for escalated fines in repeat cases.
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What Changed
This is not a regulatory change but an enforcement precedent under existing rules: non-compliance with Article 5(1) of the AML/CFT Law, which mandates annual submission of a financial crime questionnaire ("Questionnaire") to the CSSF. The fine was calculated per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a), considering circumstances under Article 8-5(1). Publication followed Article 8-6(1) after a proportionality assessment, confirming no market stability risks. No new requirements were introduced;
What You Need To Do
- Immediately review internal processes for annual Questionnaire submission, ensuring calendar invites and automated reminders for the 4 April deadline (covering prior year-end data)
- Conduct a gap analysis on AML/CFT cooperation obligations under Article 5(1), including response protocols to CSSF reminders or queries
- Update compliance calendars and train staff on escalation procedures; document all submissions with proof (e
- If late, proactively submit overdue items and request meetings if needed, as non-response forfeits mitigation opportunities
Key Dates
31 December 2024 - Reference year-end for the financial crime Questionnaire.
4 April 2025 - Statutory deadline for Questionnaire submission to CSSF. DEADLINE
11 September 2025 - Date CSSF imposed the €10,000 administrative fine after non-submission despite reminders.
9 January 2026 - Publication date of the sanction decision.
Compliance Impact
Urgency: Medium – This €10,000 fine for a straightforward reporting failure demonstrates CSSF's willingness to penalize non-cooperation swiftly, even without aggravating factors, but the amount is modest and targeted at administrative breaches. It matters as a warning shot in Luxembourg's AML landsc
Asset ManagerHedge Fund
Administrative sanction imposed on the alternative investment fund manager Sunbricks GP S.à r.l. (“AIFM”)
The CSSF imposed a **€10,000 administrative fine on Sunbricks GP S.à r.l.**, an alternative investment fund manager, for failing to submit a mandatory annual financial crime questionnaire by the April 4, 2025 deadline, despite two formal reminders. This enforcement action demonstrates the CSSF's strict approach to cooperation obligations under Luxembourg's anti-money laundering and counter-terrorist financing (AML/CFT) framework and signals that non-submission of required compliance documentation—even without evidence of underlying financial crime—triggers regulatory penalties.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All professionals supervised, authorized, or registered by the CSSF must submit an annual questionnaire on financial crime by April 4 each year, covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, which includes timely su
What You Need To Do
- regulated entities must
- *Establish Calendar Controls
- *Designate Responsible Parties
- *Prepare Documentation
- *Monitor Communications
Key Dates
April 4, 2025 – Annual financial crime questionnaire submission deadline (for year ending December 31, 2024) DEADLINE
Before September 11, 2025 – Two reminder notices issued by CSSF to Sunbricks GP
September 11, 2025 – Administrative fine decision date; questionnaire still not submitted
January 9, 2026 – Publication date of enforcement decision
2026 (for the year ending December 31, 2025).
Compliance Impact
Urgency: HIGH
Asset ManagerAll Firms
Administrative sanction imposed on the alternative investment fund manager Capitalis Premiere Group (“AIFM”)
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) Capitalis Premiere Group on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties, signaling heightened scrutiny on timely supervisory cooperation for Luxembourg-regulated entities. Compliance teams should note this as a low-value but public reminder of potential fines for administrative lapses in AML processes.
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What Changed
This is not a regulatory change or new requirement but an enforcement precedent under existing rules: non-compliance with the annual financial crime questionnaire submission, mandated by Article 5(1) of the AML/CFT Law, triggers fines per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a). The CSSF considered all relevant circumstances under Article 8-5(1) to set the €10,000 fine amount and published the sanction nominatively after proportionality assessment per Article 8-6(1), confirming no market stabi
What You Need To Do
- Ensure timely submission of annual financial crime questionnaires by 4 April each year (for prior calendar year data); implement calendar reminders and escalation processes for CSSF requests
- Respond promptly to CSSF reminders or queries on AML/CFT compliance to avoid escalation to fines; document any delays with justification evidence
- No retroactive actions needed for this case, but conduct gap analysis on reporting workflows to prevent similar breaches
Key Dates
4 April 2025 - Deadline for submitting the annual financial crime questionnaire covering the year ending 31 December 2024. DEADLINE
11 September 2025 - Date CSSF imposed the €10,000 administrative fine on Capitalis Premiere Group for non-submission.
9 January 2026 - Date of CSSF publication of the sanction decision.
Compliance Impact
Urgency: Medium - This €10,000 fine is modest but publicly names the firm, amplifying reputational risk in Luxembourg's competitive fund domicile; it matters as a clear CSSF signal of zero tolerance for basic cooperation failures in AML, potentially foreshadowing stricter enforcement amid EU AML har
Asset ManagerHedge Fund
Administrative sanction imposed on the alternative investment fund manager Lion Management (“AIFM”)
The CSSF imposed a €10,000 administrative fine on Lion Management, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the 4 April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing framework, with direct implications for all AIFMs regarding timely compliance with supervisory reporting requirements.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations. However, it reinforces critical compliance requirements:
Mandatory Annual Questionnaire Submission: All CSSF-supervised professionals, including AIFMs, must submit an annual questionnaire on financial crime by the specified deadline (in this case, 4 April 2025 for the year ending 31 December 2024).
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on the fight against mon
What You Need To Do
- *Establish Calendar Controls
- *Designate Responsible Parties
- *Monitor CSSF Communications
- *Document Submission
- *Escalate Non-Compliance Immediately
Key Dates
4 April 2025 - Deadline for submission of annual financial crime questionnaire for year ending 31 December 2024 DEADLINE
11 September 2025 - Date CSSF imposed administrative fine after two reminders went unheeded
9 January 2026 - Publication date of the administrative sanction decision
Compliance Impact
Urgency: HIGH
Asset ManagerHedge Fund
Administrative sanction imposed on the alternative investment fund manager Max Gain Capital S.à r.l. (“AIFM”)
The CSSF imposed a €10,000 administrative fine on Max Gain Capital S.à r.l., an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's active monitoring of AML/CFT compliance obligations and its willingness to sanction non-cooperation, even for procedural failures unrelated to substantive money laundering violations.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All CSSF-supervised professionals must submit an annual questionnaire on financial crime covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT imposes a non-negotiable duty to cooperate with CSSF supervisory requests.
Enforcement Escalation: The CSSF will issue reminders before imposin
What You Need To Do
- regulated entities must
- *Identify Reporting Obligations
- *Calendar Management
- *Documentation
- *Escalation Protocol
Key Dates
4 April 2025 - Deadline for submission of financial crime questionnaire for the year ending 31 December 2024 DEADLINE
Before 11 September 2025 - CSSF issued two reminders to Max Gain Capital after the missed deadline DEADLINE
11 September 2025 - CSSF imposed the €10,000 administrative fine
9 January 2026 - CSSF published the administrative sanction decision
Compliance Impact
Urgency: HIGH
Asset ManagerAll Firms
Administrative sanction imposed on the alternative investment fund manager Agriland Management S.A. (“AIFM”)
The Commission de Surveillance du Secteur Financier (CSSF), Luxembourg's financial regulator, imposed a **EUR 10,000 administrative fine on Agriland Management S.A.**, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing (AML/CFT) framework and signals heightened scrutiny of compliance with supervisory reporting requirements.
What Changed
This is not a regulatory change but rather an enforcement action that clarifies existing obligations:
Mandatory Annual Reporting: All CSSF-supervised professionals must submit an annual questionnaire on financial crime by 4 April each year, covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, including timely submission of requested documentation.
Enforcement Esc
What You Need To Do
- *Establish Reporting Calendars
- *Designate Responsible Personnel
- *Respond to Regulatory Requests
- *Document Justifications
- *Monitor Supervisory Communications
Key Dates
4 April 2025 – Deadline for submission of financial crime questionnaire for year ending 31 December 2024 DEADLINE
Before 11 September 2025 – Two reminder notices issued by CSSF to Agriland Management S.A.
11 September 2025 – Administrative fine imposed
9 January 2026 – Sanction published by CSSF
Compliance Impact
Urgency: HIGH
Asset Manager
Administrative sanction imposed on the alternative investment fund manager Bedrock I GP S.à r.l. (“AIFM”)
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) Bedrock I GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of AML reporting duties and serves as a public warning to supervised entities on timely supervisory compliance. It matters because it demonstrates that even modest fines are pursued for basic reporting lapses, potentially signaling heightened scrutiny on AIFMs' AML processes amid ongoing regulatory focus on financial crime risks.
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What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended Law of 12 November 2004 on the fight against money laundering and terrorist financing (AML/CFT Law). Specifically, it reaffirms the mandatory annual submission of the CSSF's financial crime questionnaire ("Questionnaire") by supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, as part of the cooperation duty in Article 5(1). The fine was cal
What You Need To Do
- Immediately verify submission status of the 2024 Questionnaire (or any outstanding); if overdue, submit promptly with justification to mitigate further escalation
- Implement automated calendar alerts and internal workflows for all CSSF reporting deadlines, including annual AML/CFT Questionnaire
- Conduct a compliance gap analysis on cooperation obligations under Article 5(1) AML/CFT Law, documenting reminder responses and evidence retention
- Train senior managers and compliance teams on supervisory interactions, including rights to request in-person meetings before fines
- Review governance for timely escalation of CSSF reminders to decision-makers
Key Dates
31 December 2024 - Reference period end for the Questionnaire covering financial crime compliance. DEADLINE
4 April 2025 - Statutory deadline for Questionnaire submission to CSSF. DEADLINE
11 September 2025 - Date of administrative fine imposition (€10,000) after non-submission despite reminders.
9 January 2026 - Publication date of the sanction decision by CSSF.
Compliance Impact
Urgency: Medium - This is a post-facto enforcement on a past breach (2024 reporting cycle), with the €10,000 fine relatively low, indicating proportionality for a first-time or isolated lapse. It matters as a leading indicator of CSSF's 2025-2026 focus on AML cooperation, with multiple similar AIFM
Asset ManagerHedge Fund
Administrative sanction imposed on the alternative investment fund manager C5 Haven Cyber GP S.à r.l. (“AIFM”)
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) C5 Haven Cyber GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of AML reporting duties and serves as a public warning to supervised entities on the consequences of non-cooperation. It matters because it demonstrates that even modest fines will be levied for procedural lapses, potentially signaling increased scrutiny on timely AML compliance submissions amid broader regulatory focus on financial crime risks.
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What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended AML/CFT Law:
Annual Questionnaire Submission: Supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, must submit an annual financial crime questionnaire ("Questionnaire") to CSSF as part of the cooperation duty in Article 5(1).
Fine Provisions: Fines are imposed per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a), with amounts determined by relevant
What You Need To Do
- Immediate Review
- Remediation if Late
- Process Enhancements
Key Dates
31 December 2024 - Reference year-end for the financial crime Questionnaire.
4 April 2025 - Statutory deadline for submitting the Questionnaire for the year ending 31 December 2024. DEADLINE
11 September 2025 - Date CSSF imposed the €10,000 administrative fine after noting non-submission despite reminders.
9 January 2026 - Date of CSSF publication of the sanction decision.
Compliance Impact
Urgency: Medium - This is a low-value fine (€10,000) for a procedural breach, not involving substantive AML failures like suspicious transactions or sanctions screening delays seen in higher fines (e.g., €185,000 on Rakuten Bank). It matters as a precedent for CSSF's willingness to publicly name-and
Asset ManagerHedge Fund
Administrative sanction imposed on the alternative investment fund manager C5 S.à r.l. (“AIFM”)
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager C5 Haven Cyber GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of reporting duties in AML/CFT compliance, serving as a warning to supervised entities on the consequences of administrative delays. It matters because it highlights low-tolerance for even minor procedural lapses, potentially signaling increased scrutiny on annual reporting amid broader AML/CFT priorities.
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What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended AML/CFT Law:
Article 5(1) mandates supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, to cooperate fully with CSSF, including submitting the annual financial crime questionnaire ("Questionnaire").
Breach occurred due to non-submission of the 2024 year-end Questionnaire, with fine determined per Articles 8-4(1), 8-4(2)(f), 8-4(3)(a), and 8-
What You Need To Do
- Review and confirm timely submission of all pending or future CSSF financial crime questionnaires; establish automated calendar reminders for annual deadlines (e
- Implement escalation protocols for CSSF reminders, ensuring immediate response and submission within days, not weeks
- Conduct internal audit of AML/CFT cooperation obligations, documenting justifications for any delays and preparing evidence for potential CSSF hearings or meetings
- Update compliance policies to prioritize Article 5(1) duties, including training for responsible persons on fine risks under Article 8-4
Key Dates
4 April 2025 - Deadline for submission of financial crime Questionnaire covering year ending 31 December 2024. DEADLINE
11 September 2025 - Date CSSF imposed €10,000 administrative fine on C5 Haven Cyber GP S.à r.l. for non-submission despite reminders.
9 January 2026 - Date of CSSF publication announcing the sanction.
Compliance Impact
Urgency: Medium - Matters due to CSSF's demonstrated willingness to impose and publicize fines for straightforward reporting failures, even at €10,000, which could escalate for repeat or severe cases; acts as a precedent amid rising AML/CFT enforcement (e.g., larger fines like €214,000 in similar co
Asset ManagerHedge Fund
Administrative sanction imposed on JTC (Luxembourg) S.A.
The CSSF imposed a €102,000 administrative fine on JTC (Luxembourg) S.A. on 23 July 2025 for breaches in its professional obligations as a depositary of non-financial assets under the AIFM Law, identified during an on-site inspection from February 2023 to January 2024 covering activities up to December 2022. This enforcement action highlights CSSF's scrutiny of depositary functions, particularly risk assessment and oversight controls, serving as a warning for similar entities to strengthen compliance amid rising supervisory focus on AIFM depositaries.
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What Changed
This is an enforcement action, not a regulatory change; it enforces existing requirements under Article 51(1) (1st and 7th indents) and Article 51(2) (1st sub-paragraph, 3rd indent) of the amended Law of 12 July 2013 on AIFMs (AIFM Law), and related provisions like Article 92(1) of Commission Delegated Regulation (EU) No 231/2013 (CDR 231/2013). Key breaches include: failure to properly assess risks tied to AIFs' strategies and AIFMs' organization for oversight processes; lack of processes to ve
What You Need To Do
- related entities) must
- Conduct immediate gap analyses on risk assessment processes for AIF strategies and AIFM organization per Article 92(1) CDR 231/2013
- Implement robust verification processes for AIFM compliance with asset delegation rules
- Ensure availability of key documentation and evidence of controls for the depositary function, addressing pre-2022 gaps if applicable
- Develop and test oversight processes, leveraging self-identified improvements and action plans as mitigating factors, as JTC did prior to inspection
Key Dates
February 2023 - January 2024 Period of CSSF on-site inspection on depositary obligations, covering activities up to December 2022.
23 July 2025 Date CSSF imposed the €102,000 administrative fine on JTC (Luxembourg) S.A.
9 January 2026 Date of official CSSF publication announcing the sanction.
Compliance Impact
Urgency: High – This matters due to the fine's size (€102,000), reflecting breach accumulation, severity, and duration, despite JTC's partial remediation; it signals intensified CSSF on-site scrutiny of depositary functions post-2023 inspections, with potential for higher penalties absent proactive
Asset Manager
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including non-operational investment systems, deficient AML/CFT procedures, inadequate conflict of interest management, and poor due diligence traceability. This decision underscores AMF's focus on operational robustness in asset management, with personal liability for senior managers, signaling heightened enforcement risk for similar firms. Compliance teams must prioritize reviewing internal procedures to avoid comparable sanctions, as appeals are possible but do not suspend obligations.
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What Changed
This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under the French Monetary and Financial Code for asset managers to maintain operational procedures. Key breaches highlighted include:
Imprecise investment allocation processes lacking traceability, rendering systems non-operational.
Failure to fulfill conflict of interest identification, prevention, and management obligations.
Deficient AML/CFT systems with inadequate due diligence on fund assets/lia
What You Need To Do
- Conduct immediate gap analysis of investment processes for operationality, traceability, and precision in allocation rules
- Enhance AML/CFT systems
- Review conflict of interest frameworks for identification, prevention, and management; document controls rigorously
- Senior managers
- Audit marketing materials, fee retrocessions, and valuation procedures (e
Key Dates
31 December 2025 - AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors.
08 January 2026 - Public news release date for the decision.
August 2019 - December 2023 - Period of breaches investigated.
Compliance Impact
Urgency: High - This reflects a pattern of 2025-2026 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc 15 Sep 2025; €400k on Eternam 9 Sep 2025), indicating intensified scrutiny and personal accountability. Firms risk multimillion fines and reputational damage; immedia
Asset Manager
The Securities and Exchange Commission today proposed amendments to the rules that define which registered investment companies, investment advisers, and business development companies qualify as small entities for purposes of the Regulatory Flexibility…
The SEC proposed amendments on January 7, 2026, to expand the definitions of "small entities" under the Regulatory Flexibility Act (RFA) for registered investment advisers (RIAs), investment companies, and business development companies by significantly raising asset thresholds last updated in 1998. This would increase the number of qualifying small entities, enabling the SEC to better assess regulatory impacts and potentially provide tailored relief like extended compliance timelines during rulemaking. It matters because it could indirectly reduce compliance burdens for mid-sized firms by influencing future SEC rules to minimize disproportionate effects on smaller players.
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What Changed
Raise the RAUM threshold for RIAs to qualify as small entities from $25 million to $1 billion, with conforming changes for control affiliates.
Increase the net asset threshold for investment companies from $50 million to $10 billion.
Update aggregation of related funds from "group of related investment companies" to "family of investment companies" as defined in Form N-CEN for easier identification.
Introduce inflation adjustments to thresholds every 10 years via SEC order, without formal rulema
What You Need To Do
- Submit public comments by the deadline to influence thresholds, alternatives (e
- Monitor Federal Register for exact publication and comment instructions; review proposed rule and fact sheet on SEC site (https://www
- Assess internal status
- No immediate compliance changes, as this affects SEC rulemaking process only; prepare for potential indirect impacts via future rules
Key Dates
January 7, 2026 - SEC issues proposal and press release.
60 days after Federal Register publication - Public comment period closes (publication expected shortly after January 7; exact date TBD, likely March 2026 based on estimates).
No stated adoption date - Typically at least one year post-comment period under normal processes.
Every 10 years post-adoption - Inflation adjustments to thresholds via SEC order.
Compliance Impact
Urgency: Medium. This proposal does not impose direct new requirements or alter existing obligations—it's procedural for SEC's RFA analyses during rulemaking. However, adoption could lead to meaningful indirect benefits for mid-sized RIAs and funds, such as longer compliance phases or reduced burden
Asset Manager
No description available.
The Securities and Futures Commission (SFC) reprimanded and fined Saxo Capital Markets HK Limited (SCMHK) HK$4 million on 6 January 2026 for breaching regulations by distributing unauthorised virtual asset (VA) funds and VA-related products to retail clients via its online platform from 1 November 2018 to 25 November 2022. This enforcement action underscores the SFC's strict enforcement of suitability, due diligence, and professional investor-only restrictions for complex VA products, serving as a warning to intermediaries about online distribution risks. It matters because it highlights gaps in group-wide protocols and the need for robust VA-specific controls, especially post-SFC circulars mandating PI-only access.
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What Changed
This is an enforcement action, not a new rule change, but it reinforces existing SFC circulars requiring VA products (including unauthorised funds and exchange-traded VA derivatives) to be offered exclusively to professional investors (PIs). Key requirements reiterated include: conducting VA-specific product due diligence; assessing client knowledge of VA investments; providing sufficient VA-specific information and warnings; and implementing platform controls to restrict retail access to comple
What You Need To Do
- Conduct immediate VA product due diligence using SFC-specific procedures, not just group-wide protocols, to identify unauthorised VA funds and derivatives
- Implement client knowledge assessments for VA investments before transactions, especially for retail clients
- Provide VA-specific warnings and information on platforms and ensure retail access is blocked for PI-only products
- Review and enhance online platform controls for suitability checks on complex products; audit historical VA trades for compliance gaps
- Update internal policies to align with SFC circulars on VA distribution, including staff training on breaches like those at SCMHK
Key Dates
1 November 2018 - 25 November 2022 Period of breaches where SCMHK distributed VA products to retail clients in violation of applicable SFC circulars.
6 January 2026 Date of SFC announcement, reprimand, and HK$4 million fine imposition on SCMHK.
Compliance Impact
Urgency: High – This action signals intensified SFC scrutiny on VA online distribution post-2018 circulars, with fines for suitability failures even years later; firms risk similar penalties (HK$4m here) if platforms lack VA controls, especially amid Hong Kong's growing VA regime. It matters for ope
Broker DealerAll Firms
No description available.
The Swiss Federal Council adopted a new ordinance (RS 196.127.85) on 5 January 2026, mandating the immediate freezing of all assets in Switzerland belonging to Nicolás Maduro and 36 associated persons, under the Federal Act on the Freezing and Restitution of Illicit Assets held by Foreign Politically Exposed Persons (FIAA). This precautionary measure prevents asset outflows amid Venezuela's political upheaval, complementing existing sanctions since 2018, and enables future mutual legal assistance for potential restitution to the Venezuelan people. It matters for Swiss financial institutions as it imposes immediate reporting and freezing obligations with severe penalties for non-compliance.
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What Changed
Immediate asset freeze: All assets of any kind held by the 37 listed persons (Nicolás Maduro and associates) in Switzerland must be frozen without delay; this targets individuals not previously sanctioned under the Embargo Act.
Reporting obligation: Persons and institutions, including financial intermediaries, must report frozen assets or knowledge thereof to the Money Laundering Reporting Office Switzerland (MROS) per FIAA provisions.
Duration: The freeze is valid for four years until 4 January
What You Need To Do
- Screen and identify
- Freeze assets
- Report to MROS
- Internal updates
- Document compliance
Key Dates
5 January 2026, 11 a.m. Ordinance enters into force; immediate asset freezing and reporting required. DEADLINE
4 January 2030 Asset freeze expires after four years, unless extended or revoked.
5 January 2026 .
Compliance Impact
Urgency: Critical. This demands immediate action as the freeze took effect on 5 January 2026 at 11 a.m., with custodial penalties up to three years for failures; given today's date (25 January 2026), firms must confirm compliance now to avoid fines up to CHF 250,000 or enforcement. It heightens AML/
BankAsset ManagerWealth Manager The Securities and Exchange Commission today announced that Nekia Hackworth Jones, Deputy Director of the Division of Enforcement (Southeast), concluded her tenure with the agency on December 26, 2025.“I am thankful to Nekia for answering the call to…
This SEC press release announces the departure of Nekia Hackworth Jones, Deputy Director of the Division of Enforcement (Southeast), who concluded her tenure on December 26, 2025, after overseeing enforcement investigations and litigations across Washington D.C., Atlanta, and Miami offices. It matters to compliance professionals as personnel changes in SEC Enforcement leadership can signal potential shifts in enforcement priorities, investigation focus, or regional scrutiny intensity in the Southeast U.S.
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What Changed
There are no main regulatory changes, new requirements, or policy updates in this announcement; it is solely a personnel departure notice with no substantive regulatory implications.
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What You Need To Do
- related delays and monitor for successor announcements via https://www
Key Dates
December 26, 2025 - Nekia Hackworth Jones concludes her tenure at the SEC.
December 29, 2025 - SEC issues press release announcing the departure.
Compliance Impact
Urgency: low - This is a routine leadership transition with no immediate regulatory or enforcement changes; it matters peripherally for firms anticipating shifts in SEC Enforcement priorities under new leadership, but lacks direct compliance obligations.
Broker DealerAll Firms
Sanctions & settlements professional obligations Journalists Investment management companies Listed companies and issuers AMF Enforcement Committee fines the depositary CACEIS Bank for breaches of its professional obligations
The AMF Enforcement Committee fined CACEIS Bank €3.5 million and issued a warning on 17 December 2025 for breaches of its professional obligations as depositary for seven French-law UCITS funds managed by H2O AM LLP (later transferred to H2O AM Europe). This decision underscores the AMF's strict enforcement of depositary oversight duties, particularly in verifying fund managers' investment monitoring systems, asset valuations, and compliance with prospectus constraints like issuer limits and security ratings. It matters for compliance teams as it highlights personal accountability risks and potential fines for inadequate due diligence in fund depositary roles, signaling heightened scrutiny amid past H2O fund issues.
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What Changed
This is an enforcement action, not a regulatory change; it reinforces existing obligations under French UCITS rules (transposing UCITS Directive V) for depositaries. Key upheld objections include:
Failure to perform sufficient checks on the asset management company's (AMC) systems for monitoring UCITS investment ratios and valuing unlisted securities.
Inadequate verification of investment decision legality, such as compliance with prospectus limits on debt security ratings, derivative types, and
What You Need To Do
- Conduct gap analysis
- Enhance oversight processes
- Training and audits
- Monitor appeals
Key Dates
17 December 2025 - AMF Enforcement Committee decision date: €3.5M fine and warning imposed on CACEIS Bank.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision directly impacts depositaries with €3.5M precedent for oversight failures, amid AMF's pattern of multi-million fines (e.g., €5.67M total in related 2024 case involving CACEIS). It elevates risks for UCITS/AIF depositaries handling non-standard assets,
BankAsset ManagerAll Firms
On 16 December 2025, BaFin imposed two administrative fines amounting to €560,000 on flatexDEGIRO Bank AG. The company had contravened obligations under the German Securities Trading Act (Wertpapierhandelsgesetz - WpHG). At the beginning of 2022, flatexDEGIRO Bank AG advertised free investment services on two of its websites without clearly indicating that a processing fee would be charged on a regular basis. flatexDEGIRO Bank AG adapted its practices to comply with the legal requirements in ...
BaFin imposed €560,000 in administrative fines on flatexDEGIRO Bank AG on December 16, 2025, for misleading marketing of investment services that advertised free offerings without clearly disclosing mandatory processing fees. This enforcement action underscores BaFin's strict interpretation of fair and transparent marketing requirements under the German Securities Trading Act (WpHG) and demonstrates that even corrective action taken by firms does not eliminate regulatory penalties for past violations.
What Changed
The enforcement action clarifies BaFin's expectations regarding fair and clear marketing communications for investment services:
Investment services providers must explicitly and unambiguously disclose all material costs, including processing fees, when advertising services as "free"
Marketing materials must present both benefits and risks of services in a balanced manner, with relevant risks highlighted alongside advantages
These obligations apply across all marketing channels, including compa
What You Need To Do
- *For flatexDEGIRO Bank AG (already completed)
- Modify marketing materials to clearly and explicitly disclose all material costs and fees
- Ensure balanced presentation of benefits and risks across all marketing channels
- *For all investment services providers (preventive compliance):
- *Implement clear disclosure protocols requiring that:
Key Dates
Beginning of 2022 – flatexDEGIRO Bank AG violated WpHG requirements by advertising free services without disclosing processing fees
2022 – flatexDEGIRO adapted its practices to comply with legal requirements
December 16, 2025 – BaFin imposed two administrative fines totaling €560,000
December 22, 2025 – BaFin publicly announced the enforcement action
Compliance Impact
Urgency: HIGH
Broker DealerBankFintech
No description available.
The Securities and Futures Commission (SFC) successfully prosecuted Mr. Choi Chun Wai, former Vice President of Computershare Hong Kong Investor Services Limited, for insider dealing in ENM Holdings Limited shares, resulting in a two-month prison sentence, a HK$289,500 fine (equal to avoided losses), and HK$120,407 in SFC investigation costs on 18 December 2025. This enforcement action highlights the SFC's aggressive stance against market professionals misusing non-public information, serving as a deterrent to uphold Hong Kong's market integrity. Compliance teams should note it reinforces personal liability for insider dealing under the Securities and Futures Ordinance (SFO), even for those in support roles like proxy coordination.
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What Changed
This is an enforcement case, not a regulatory change; no new rules, requirements, or amendments to the SFO or Listing Rules were introduced. It exemplifies ongoing application of existing insider dealing prohibitions under SFO sections 270-271, where individuals with inside information (e.g., on privatization failure from proxy forms) must not deal in relevant securities. The court's emphasis on "immediate custodial sentence" for professionals in positions of trust signals stricter sentencing no
What You Need To Do
- Enhance insider dealing training
- Strengthen information barriers
- Monitor personal trading
- Conduct insider lists and attestations
- Audit workflows
Key Dates
2 June 2023 - ENM and Offeror announced proposed privatization, engaging Computershare for proxy and voting services.
22 September 2023 - Choi learned inside information on privatization failure from proxy forms.
25 September 2023 - Choi sold 1,500,000 ENM shares, avoiding HK$289,500 loss ahead of announcement.
26 September 2023 - Scheduled court meeting for privatization voting.
27 September 2023 - ENM announced privatization lapse; share price fell 10.26% to HK$0.35.
Compliance Impact
Urgency: Medium - This reinforces existing obligations rather than imposing new ones, but the custodial sentence for a mid-level professional elevates personal risk awareness, prompting immediate policy reviews to mitigate SFC scrutiny. It matters for firms in investor services or with staff in trus
Broker DealerAll Firms
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its former director a total of €500,000
The AMF Enforcement Committee fined asset management company Novaxia Investissement €400,000 and its former director Joachim Azan €100,000 on 10 December 2025 for breaches of professional obligations, primarily due to an incomplete and non-operational investment/divestment procedure lacking traceability of compliance checks and formalized due diligence. This enforcement action underscores AMF's focus on robust operational procedures in asset management, serving as a deterrent and educational tool for ensuring honest, fair, and diligent business conduct. Compliance teams should prioritize procedure operationalization to avoid similar sanctions, as this fits a pattern of recent AMF fines targeting procedural deficiencies.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces existing requirements under AMF professional obligations for asset managers (sociétés de gestion), including:
Fully operational investment and divestment procedures that ensure traceability of compliance checks against fund policies and constraints.
Formalized due diligence prior to allocating investment projects to funds.
No explicit changes to rules; instead, it clarifies enforcement expectations for procedure completenes
What You Need To Do
- Review and enhance investment/divestment procedures: Ensure completeness, traceability of all compliance checks (e
- Document all processes rigorously
- Conduct gap analysis against AMF expectations
- Senior manager training
- Appeal monitoring
Key Dates
10 December 2025 - AMF Enforcement Committee decision date imposing fines; appeals possible (no specific deadline stated, but typically within 2 months to Conseil d’État). DEADLINE
Compliance Impact
Urgency: High – This decision, part of a 2025 enforcement wave fining asset managers €400k–€1.3m for procedural lapses (e.g., non-operational investment processes, inadequate due diligence), signals intensified AMF scrutiny on operational integrity. Firms risk personal fines for managers and reputat
Asset Manager
With over 20 years’ experience and responsibility for supervising 5,000 firms, I know that when an issue arises, the first question is often: 'What action will you take?'That’s a fair question – enforcement is one of the most visible ways we act. It often grabs headlines with big fines and publicity.But our role as supervisors is to exercise judgement - selecting the right tool to achieve the best and fastest outcomes for consumers and markets.While enforcement is a vital part of the kit, it’...
This FCA blog post outlines the regulator's supervisory "toolkit" for addressing consumer harm, emphasizing proactive supervision over enforcement to achieve faster outcomes like redress and market-wide improvements. It matters because it signals FCA's preference for swift, non-enforcement interventions (e.g., skilled person reviews, voluntary requirements), urging firms to respond promptly to supervisory feedback to avoid escalation. Compliance teams should view this as a reminder to prioritize Consumer Duty compliance, as supervision tools are increasingly tied to it for rapid harm prevention.
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What Changed
No new rules or requirements are introduced; this is a supervisory strategy update highlighting FCA's full range of tools beyond enforcement. Key emphases include:
Prioritizing supervision for quick fixes, such as multi-firm reviews, good/poor practice guidance, and skilled person reviews (s.166) under FSMA.
Integration of Consumer Duty (Principle 12) as a core principle for assessing and remedying poor outcomes, e.g., unclear policy renewals or inadequate support.
Examples from insurance (e.g.,
What You Need To Do
- Embed proactive monitoring
- Respond swiftly to FCA contact
- Improve practices market-wide
- Evidence compliance
- Facilitate redress
Key Dates
October 2022 Boards to scrutinise and agree implementation plans.
July 2023 ) - Implement for new/existing products.
July 2024 ) - Extend to closed-book products.
Compliance Impact
Urgency: Medium – This reinforces existing obligations under Consumer Duty and Principles, but underscores risk of supervisory escalation if firms ignore early warnings. It matters because FCA prioritizes speed (supervision over enforcement), enabling quick harm fixes but exposing non-responsive fir
InsuranceAll Firms
Der Bundesrat hat am 12. Dezember 2025 beschlossen, die Iran-Sanktionen dem Stand von vor dem Abschluss des Wiener Abkommens über das iranische Atomprogramm anzupassen. Dazu hat er die Verordnung über Massnahmen gegenüber der Islamischen Republik Iran einer Totalrevision unterzogen. Die neue Verordnung (SR 946.231.143.6) trat am 12. Dezember 2025 in Kraft.
Switzerland has completely revised its Iran sanctions regulations effective December 12, 2025, restoring sanctions to pre-2015 levels following the automatic reinstatement of UN Security Council resolutions on September 28, 2025. This comprehensive overhaul requires Swiss financial institutions and businesses to immediately implement expanded asset freezes, trade restrictions, and sectoral prohibitions affecting Iran-related transactions and designated persons.
What Changed
The total revision introduces several critical regulatory shifts:
*Scope Expansion**: The revised ordinance restores seven previously suspended UN Security Council resolutions (1696, 1737, 1747, 1803, 1835, 1929, and 2224) and aligns Swiss sanctions with EU measures reactivated on September 29, 2025.
*Sectoral Restrictions**: New measures in the raw materials sector have been introduced, complementing existing prohibitions on:
Sale or supply of key energy sector equipment
Gold, precious metals
What You Need To Do
- *Immediate (Completed by December 12, 2025)
- related transactions and accounts for compliance with expanded prohibitions
- *Short-term (By January 1, 2026)
- September 30, 2025 contracts under legacy exemption provisions
- related transactions
Key Dates
September 28, 2025 - UN Security Council resolutions automatically reinstated (snapback mechanism triggered)
September 29, 2025 - EU reactivated suspended sanctions on Iran's proliferation activities
October 20, 2025 - Swiss State Secretariat for Economic Affairs (SECO) updated SESAM sanctions database with reinstated listings
October 21, 2025 - Updated sanctions list effective (23:00 UTC)
December 12, 2025 - Complete revision of Iran sanctions ordinance (SR 946.231.143.6) entered into force (23:00 UTC)
Compliance Impact
Urgency: CRITICAL
BankPayment ProviderAll Firms
Der Bundesrat hat die Sanktionslisten betreffend Russland und Belarus am 12. Dezember 2025 ausgeweitet. Die Schweiz übernimmt damit diverse Änderungen, welche die EU im Rahmen ihres 19. Sanktionspakets beschlossen hat.
The Swiss Federal Council expanded sanctions lists against Russia and Belarus on December 12, 2025, adopting changes from the EU's 19th sanctions package to align Swiss measures with EU restrictions. This matters for Swiss financial institutions as it imposes immediate asset freezes, transaction bans, and reporting obligations on newly listed entities, strengthening efforts to counter Russia's military-industrial complex and shadow oil fleet while preventing sanctions evasion.
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What Changed
Asset freezes and prohibitions: 22 natural persons and 42 companies/organizations added to asset freeze and prohibition on making funds/assets available lists.
Shipping restrictions: 116 new vessels (primarily Russian shadow fleet tankers evading oil price caps) subjected to comprehensive purchase, sale, and service bans.
Export controls: 45 new companies (including in third countries) under stricter export controls to block deliveries of critical goods to Russia's military-industrial sector.
Fi
What You Need To Do
- Immediate screening
- Asset freezing
- Transaction halts
- Ongoing monitoring
Key Dates
13 December 2025 - Measures enter into force; immediate implementation required. DEADLINE
29 October 2025 - Prior expansion decision (related 18th EU package adoption).
30 October 2025 - Entry into force of October measures (export restrictions, RDIF transaction bans).
31 December 2025 - Extension of certain derogations (e.g., Russia investment withdrawals).
Compliance Impact
Urgency: Critical - Effective immediately (13 Dec 2025), with no grace period for asset freezes/transaction bans, exposing non-compliant firms to severe penalties amid FINMA's active enforcement on sanctions (type: enforcement). This escalates existing Russia/Belarus regimes, targeting evasion vecto
BankWealth ManagerPayment Provider Mr Philip Smith, former Chief Executive Officer (CEO) and Executive Director of RSA Insurance Ireland DAC disqualified for 13 years by the Central Bank of Ireland for his admitted participation in a breach of financial services law by RSAII On 1 December 2025 the Central Bank of Ireland reprimanded Mr Smith and disqualified him for 13 years from being a person concerned in the management of a regulated financial service provider for his participation in a breach by RSA Insurance Ireland DAC (...
The Central Bank of Ireland (CBI) reprimanded and disqualified former RSA Insurance Ireland DAC (RSAII) CEO Philip Smith for 13 years from management roles in regulated financial service providers due to his admitted role in under-reserving large loss claims, breaching Article 13(1)(a) of the European Communities (Non-Life Insurance) Framework Regulations 1994 (S.I. No. 359/1994). This enforcement action underscores CBI's commitment to individual accountability for senior executives who circumvent controls, risking policyholder protection and firm solvency, as evidenced by RSAII's subsequent need for a major capital injection. It matters for compliance professionals as it demonstrates CBI's use of prolonged disqualifications and inquiries under the Administrative Sanctions Procedure (ASP) to deter governance failures in insurance firms.
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What Changed
This is not a regulatory change or new requirement but an enforcement precedent reinforcing existing obligations under the 1994 Regulations for insurers to maintain adequate technical reserves reflecting true liabilities. It highlights CBI's focus on senior executive accountability for deliberate policy circumvention, such as undocumented processes overriding claims handlers' estimates, which inflated reported profits and understated liabilities. No new rules were introduced; instead, it applies
What You Need To Do
- Review senior management oversight of claims handling; document all approvals and prohibit informal (e
- Enhance governance training for executives on personal liability under ASP, including simulations of reserving decisions and policyholder risk scenarios
- Assess historical exposures for under-reserving; remediate if needed, and prepare for potential CBI inquiries (noting 10+ year investigation timelines)
- Update conduct and culture frameworks to align with CBI expectations for CEOs to drive compliance, as per Deputy Governor Colm Kincaid's comments
Key Dates
2014 - CBI enforcement investigation into Mr Smith and RSAII commences.
December 2018 - CBI reprimands and fines RSAII €3.5m for related breaches, including reserve failures.
November 2022 - CBI decides to hold an Inquiry into Mr Smith's participation under Part IIIC of the Central Bank Act 1942.
1 December 2025 - Reprimand and 13-year disqualification imposed on Mr Smith, effective immediately under IAF Act transitional provisions (no High Court confirmation needed).
12 December 2025 - CBI publishes public statement on the enforcement action.
Compliance Impact
Urgency: High – This action signals intensified CBI scrutiny on individual accountability in insurance reserving, with 13-year bans possible for deliberate breaches risking policyholders, even without actual losses. It matters now (post-1 Dec 2025 effective date) as firms face elevated enforcement r
InsuranceAll Firms
Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung des Anhangs der Verordnung vom 7. August 1990 über Wirtschaftsmassnahmen gegenüber der Republik Irak (SR 946.206) publiziert.
This FINMA publication announces a SECO update to the annex of the Ordinance on Economic Measures against the Republic of Iraq (SR 946.206), reflecting UN Sanctions Committee amendments to the list of sanctioned individuals, companies, and organizations made on December 9, 2025. It matters because these changes are directly applicable in Switzerland, requiring financial intermediaries to immediately block affected assets and report business relationships to SECO to ensure compliance with UN sanctions. Failure to act risks enforcement by FINMA under its supervisory mandate.
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What Changed
The UN Sanctions Committee modified the sanctions list targeting persons, companies, and organizations related to Iraq on December 9, 2025; this amendment was published by SECO on its website and integrated into the SESAM sanctions database on December 10, 2025.
Switzerland automatically applies UN sanctions lists without delay per the Federal Council's Ordinance of March 4, 2016, making the update immediately binding.
Financial intermediaries must implement prohibitions, freeze assets of newly
What You Need To Do
- Screen against SESAM database
- Asset freeze
- Report to SECO
- Internal review
- Document compliance
Key Dates
December 9, 2025 - UN Sanctions Committee decision amending the Iraq sanctions list.
December 10, 2025 - SECO publishes update on its website and updates SESAM database; changes enter into force immediately in Switzerland.
Immediate (as of December 10, 2025) - Financial intermediaries must block assets and report to SECO without delay, per automatic application of UN sanctions. DEADLINE
Compliance Impact
Urgency: High - Automatic and immediate effect heightens breach risk, with FINMA enforcement powers including fines, reputational damage, or license revocation for non-compliance. It matters due to Switzerland's direct implementation of UN sanctions, amplifying AML/financial crime exposure amid ongo
BankAsset ManagerWealth Manager New report outlines the Central Bank’s approach to more effective and efficient regulatory and supervisory framework, reducing complexity and improving clarity while maintaining resilience and important protections in the system. This work builds on the Central Bank’s strategy to transform regulation and supervision, including the introduction of our new integrated supervisory approach and the improvements made in our gatekeeping processes in recent years. The roadmap sets out a comprehensive...
The Central Bank of Ireland published a comprehensive multi-year roadmap on December 10, 2025, aimed at streamlining its regulatory and supervisory framework across four pillars: supervision, regulation, gatekeeping, and reporting. This initiative represents a strategic shift toward more effective and efficient oversight while explicitly maintaining resilience standards and consumer protections, responding to EU calls for regulatory reform to enhance competitiveness.
What Changed
The roadmap encompasses four major reform areas:
*Supervision: Implementation of a new integrated, risk-based supervisory approach** introduced in January 2025, consolidating multidisciplinary teams and sharpening risk focus with clearer supervisory communications. This delivers more coherent firm engagement, stronger proportionality, and streamlined processes.
*Regulation: Comprehensive updates to the domestic rulebook, including:
Insurance: Major compatibility review to eliminate duplication
What You Need To Do
- *Immediate actions for compliance professionals
- *Monitor consultation releases
- *Assess rulebook changes
- *Evaluate supervisory engagement
- *Prepare for gatekeeping changes
Key Dates
January 2025 - New integrated supervisory model became effective
2026 - Public consultation on new Regulatory Impact Assessment Framework
2026 to first half of 2028 - Multi-year programme implementation period for all roadmap initiatives
2025 - Strategic review of Industry Funding Levy approach (consultation expected during 2025)
Compliance Impact
Urgency: HIGH
BankAsset ManagerInsurance Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung (WBF) hat den Anhang 2 der Verordnung vom 25. Mai 2005 über Massnahmen gegenüber Sudan (SR 946.231.18) geändert.
On December 9, 2025, Switzerland's State Secretariat for Economic Affairs (SECO) updated Annex 2 of the Sudan Sanctions Ordinance (SR 946.231.18), requiring Swiss financial intermediaries to implement changes to their sanctions screening and compliance procedures. This update reflects ongoing international coordination on Sudan sanctions enforcement and requires immediate implementation by all Swiss-regulated financial institutions.
What Changed
The regulatory update modified Annex 2 of the Sudan Sanctions Ordinance effective December 9, 2025 at 23:00 UTC. While the search results do not provide the specific entities added or removed from the sanctions list, the update was coordinated through FINMA's SESAM (SECO Sanctions Management) database, which serves as Switzerland's authoritative sanctions database for financial intermediaries.
The timing of this update aligns with broader international sanctions activity on Sudan. In July 2025,
What You Need To Do
- *Sanctions List Update
- *System Screening
- *Transaction Review
- *Blocked Assets
- *Staff Training
Key Dates
December 9, 2025, 23:00 UTC - Effective date of the urgent amendment to Annex 2 of SR 946.231.18; SECO updated the SESAM database on this date
Immediate - Financial intermediaries required to implement changes according to SR 946.231.18 regulations DEADLINE
Compliance Impact
Urgency: CRITICAL
BankPayment ProviderWealth Manager
No description available.
The CFTC filed a civil enforcement action on November 21, 2025, against Brian Mitchell, Kevin Mack Jr., and their unregistered entity Young Pros Investment Group LLC (YPIG) for fraudulently soliciting ~$1 million from 33 pool participants to trade commodity futures, using misrepresentations, Ponzi payments, false statements, and registration violations, including Mitchell's breach of a prior 2021 CFTC order. This case underscores the CFTC's aggressive enforcement against unregistered commodity pools and fraud, seeking restitution, disgorgement, penalties, trading bans, and injunctions under the Commodity Exchange Act (CEA). Compliance teams must prioritize registration checks and fraud prevention to avoid similar actions, as it highlights personal liability for controlling persons.
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What Changed
This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements. It reinforces longstanding CEA and CFTC rules on:
Mandatory registration as a Commodity Pool Operator (CPO) and Associated Persons (APs) for pools trading commodity futures (CFTC Regulation 4.13 exemptions do not apply here due to fraud and public solicitation).
Prohibitions on fraud, misrepresentations, guarantees of profit, non-disclosure of risks, commingling funds, and operating pools as
What You Need To Do
- Verify registration
- Implement controls
- Conduct due diligence
- Train staff
- For SEC-registered advisers
Key Dates
2025 .
November 21, 2025 - CFTC files complaint in U.S. District Court for the Eastern District of Michigan.
~December 2020 - May 2022 - Alleged fraudulent solicitation and trading period.
2021 - Prior CFTC administrative order against Mitchell (Press Release 8427-21) prohibiting trading and registration activities for three years.
Compliance Impact
Urgency: High - This action signals intensified CFTC scrutiny on unregistered pools amid rising crypto/futures fraud (e.g., similar January 2026 case against Wolf Capital). It matters because penalties include personal bans, multimillion restitution/disgorgement, and whistleblower awards (10-30% of
Hedge FundAsset ManagerAll Firms
The CFTC today announced the U.S. District Court for the Central District of California entered a final judgement against Safeguard Metals LLC and Jeffrey Ikahn (aka Jeffrey Santulan and Jeffrey Hill) ordering them to pay $25.6 million in restitution to victims and a $25.6 million civil monetary penalty for operating a nationwide, precious metals fraud. Released: 11/20/2025
The CFTC, alongside 30 state regulators, secured a final judgment on November 20, 2025, against Safeguard Metals LLC and Jeffrey Ikahn, imposing $25.6 million in restitution to victims and a $25.6 million civil monetary penalty for a nationwide precious metals fraud scheme from October 2017 to July 2021 that defrauded over 450 elderly investors of more than $52 million. This enforcement action, resolving a February 2022 complaint, highlights coordinated federal-state-SEC efforts to combat commodity fraud and underscores personal liability for controlling persons under CEA Section 6(c)(1) and Regulation 180.1(a). It matters for compliance as it reinforces aggressive penalties for misrepresentations, overcharges, and targeting vulnerable populations, with offsets across parallel SEC proceedings.
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What Changed
This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements. It reaffirms existing CEA prohibitions on fraud, including Section 6(c)(1), 7 U.S.C. § 9(1), and 17 C.F.R. § 180.1(a)(1)-(3), covering material misrepresentations, omissions, and deceptive schemes in precious metals sales. Key takeaways include joint-and-several liability for entities and controlling individuals (Ikahn held liable for not acting in good faith), systematic overcharges as fraud
What You Need To Do
- Conduct immediate fraud risk assessments on precious metals sales scripts, disclosures, and pricing markups to ensure no material misrepresentations or undisclosed overcharges
- Enhance senior investor protections, including suitability reviews, cooling-off periods, and training on vulnerable customer targeting bans
- Review controlling person policies for good faith oversight, documenting supervisory failures to avoid personal liability
- Audit parallel SEC/CFTC exposures in commodity-linked activities, preparing for offset calculations in multi-agency actions
- Update compliance manuals with this case as precedent for CEA fraud in physical commodities; monitor whistleblower notices for internal reporting incentives
Key Dates
February 1, 2022 - CFTC and states file initial complaint alleging fraud scheme.
May 5, 2022 - Plaintiffs file First Amended Complaint.
September 6, 2023 - Second Amended Complaint filed.
May 2, 2025 - Court enters SEC remedies judgment ($25.6M disgorgement/penalty, with offsets).
September 30, 2025 - Court issues Statement of Decision granting restitution ($25.6M) and civil penalty ($25.6M).
Compliance Impact
Urgency: Medium - This resolved enforcement sets precedent for precious metals fraud penalties but imposes no new rules or immediate deadlines beyond whistleblower claims (March 9, 2026). It matters due to escalating CFTC-state coordination, personal liability risks, and focus on elder fraud amid ri
Broker DealerAsset ManagerAll Firms
The Securities and Exchange Commission today announced that Antonia M. Apps, Deputy Director of the Division of Enforcement (Northeast), will conclude her tenure with the agency effective Dec. 1, 2025. “I thank Antonia for her steadfast leadership in…
This SEC press release announces the departure of Antonia M. Apps, Deputy Director of the Division of Enforcement (Northeast), effective December 1, 2025. It signals ongoing leadership transitions within the restructured Enforcement Division under new SEC Chair Paul Atkins, which may influence enforcement priorities, transparency, and regional consistency, requiring firms to adapt compliance strategies amid a "return to basics" approach focused on core investor protection.
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What Changed
This announcement itself introduces no new regulatory changes or requirements; it is a personnel update. However, it occurs amid broader Enforcement Division restructuring, including:
Consolidation from one Deputy Director to four (three regional: Northeast, Southeast, West; one for specialized units), reducing reporting lines for a more unified nationwide enforcement program.
Rescission in March 2025 of delegated authority for the Enforcement Director to issue formal orders of investigation, no
What You Need To Do
- Review ongoing Northeast Regional Office investigations for potential leadership changes and engage early with new deputies on cooperation opportunities
- Enhance internal self-reporting and remediation protocols to align with Enforcement's stated rewards for cooperation and robust Wells processes
- Update compliance training on restructured reporting lines and Commission-authorized formal orders, ensuring defenses stick to established securities laws rather than novel theories
- Monitor SEC staff directory for replacement announcements, such as potential roles for Samuel Waldon or others in the Northeast
Key Dates
December 1, 2025 - Antonia M. Apps concludes her tenure as Deputy Director of Enforcement (Northeast).[User Query]
December 26, 2025 - Nekia Hackworth Jones concluded her tenure as Deputy Director of Enforcement (Southeast).
March 2025 - SEC rescinded delegation of formal order authority to Enforcement Director.
April 2025 - Nekia Hackworth Jones appointed Deputy Director (Southeast).
September 2, 2025 - Margaret A. Ryan appointed Director of Enforcement.
Compliance Impact
Urgency: Low - This is a routine personnel change with no immediate regulatory shifts or deadlines post-December 1, 2025. It matters indirectly as part of 2025's Enforcement Division overhaul (15% headcount reduction, regional consolidation), likely leading to prioritized, transparent enforcement on
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Sanctions & settlements Anti-money Laundering Governance Investment advice Other professionals Journalists Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its two directors a total of €2.5...
The AMF Enforcement Committee fined financial investment advisor Carat GP €300,000 and its directors Jimmy Guinet (€200,000) and Sébastien Renaud (€2 million) a total of €2.5 million on 5 November 2025, imposing permanent bans on Carat GP and Renaud, and a 10-year ban on Guinet, for breaches including inadequate documentation, failure to act honestly and professionally in clients' interests, AML failures, lack of conflict detection systems, and insufficient cooperation with inspectors. This decision marks the first time the Committee held directors personally liable for breaches, signaling heightened personal accountability for senior managers in French investment firms. It matters as it reinforces AMF's focus on governance, AML, and client protection, with severe sanctions serving as a deterrent amid rising enforcement trends.
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What Changed
This is an enforcement action, not a regulatory change, but it clarifies and strengthens application of existing AMF rules for conseillers en investissements financiers (CIFs) under French regulations:
Mandatory compliant documentation (e.g., investment proposals).
Obligation to act honestly, fairly, and professionally in clients' best interests, including systems to prevent managers exploiting positions for undocumented investments.
AML/CFT compliance, including prohibitions on directors receiv
What You Need To Do
- Audit documentation
- Strengthen governance
- Enhance AML/CFT
- Improve inspection readiness
- Senior manager reviews
Key Dates
5 November 2025 - AMF Enforcement Committee decision issued, imposing fines and bans.
6 November 2025 - French version of press release published.
1 January 2019 to 30 June 2024 - Relevant period of breaches for Carat GP.
Compliance Impact
Urgency: High - Recent (November 2025) decision with record €2.5m fines and novel personal director liability elevates risks for CIFs and managers, amid AMF's pattern of escalating sanctions on governance/AML failures (e.g., similar cases in 2019-2025). Firms must act promptly to avoid parallel enfo
Wealth ManagerAsset ManagerAll Firms
The Central Bank of Ireland has fined Coinbase Europe Limited €21,464,734 for breaching its anti-money laundering and counter terrorist financing transaction monitoring obligations between 2021 and 2025. The Central Bank of Ireland (the Central Bank) has fined Coinbase Europe Limited (Coinbase Europe) €21,464,734 for breaching its anti-money laundering (AML) and combatting terrorist financing (CFT) obligations with respect to transaction monitoring as required by the Criminal Justice (Money L...
The Central Bank of Ireland (CBI) fined Coinbase Europe Limited €21,464,734 for AML/CFT transaction monitoring failures under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010), involving over 30 million unmonitored transactions worth €176 billion from April 2021 to March 2025. This marks CBI's first enforcement against a crypto firm, highlighting regulators' focus on robust real-time monitoring and timely Suspicious Transaction Reporting (STR) for virtual asset service providers (VASPs). It matters as it sets a precedent for EU crypto compliance amid MiCA and AMLA implementation, signaling increased scrutiny and potential multimillion-euro penalties for similar lapses.
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What Changed
This is an enforcement action, not new legislation, but it reinforces existing CJA 2010 requirements for VASPs: ongoing transaction monitoring, immediate STR filing to the Financial Intelligence Unit (FIU) and Revenue Commissioners upon suspicion of money laundering or terrorist financing, and adoption of internal policies/controls to prevent/detect financial crime. Key breaches included: misconfigured monitoring systems missing 30,442,437 transactions (31% of activity over 12 months); delayed r
What You Need To Do
- Conduct Gap Analysis
- Enhance Controls
- Accelerate STR Processes
- Board/Compliance Reporting
- Third-Party Review
Key Dates
23 April 2021 - 19 March 2025 Period of breaches, including 12-month window of unmonitored €176 billion transactions.
5 November 2025 Settlement reached between CBI and Coinbase Europe.
6 November 2025 CBI public announcement and Settlement Notice published.
12 January 2026 High Court confirmed sanctions, making them final and effective.
CJA 2010 obligations remain perpetual.
Compliance Impact
Urgency: High – This establishes a €21.5m benchmark for VASP monitoring failures in the EU, with risks amplified by MiCA (effective 2024) and AMLA (2025 onward), where national regulators like CBI will enforce harmonized rules. Firms risk similar fines (30% settlement discount possible), reputationa
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Die Schweiz schliesst sich den weiteren Massnahmen des 18. Sanktionspakets der Europäischen Union (EU) gegenüber Russland sowie den zusätzlich zum 18. Sanktionspaket erlassenen Massnahmen gegenüber Belarus an. Dies hat der Bundesrat am 29. Oktober 2025 beschlossen. Im Fokus stehen Massnahmen im Güter-, Finanz und Energiebereich. Der Bundesrat hat dafür die Verordnung über Massnahmen gegenüber Belarus (SR 946.231.116.9) geändert.
Switzerland has aligned with additional EU measures from the 18th sanctions package against Russia and specific Belarus measures, amending the Ordinance on Measures against Belarus (SR 946.231.116.9) to focus on goods, financial, and energy sectors. This strengthens the sanctions regime against Belarus to mirror Russia's more closely, aiming to enhance effectiveness and prevent circumvention. Compliance teams must prioritize asset freezes, transaction prohibitions, and reporting to avoid enforcement risks from FINMA and SECO.
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What Changed
Alignment with EU's 18th sanctions package (adopted 18 July 2025) and additional Belarus-specific measures, targeting Belarus's involvement in Russia's war against Ukraine.
Amendments to SR 946.231.116.9, harmonizing Belarus sanctions with Russia's regime, particularly in goods (e.g., export restrictions on chemicals, metals, plastics for military/tech strengthening), financial services (e.g., transaction bans on additional banks), and energy sectors.
Requirements for financial intermediaries to
What You Need To Do
- Immediately screen client portfolios, transactions, and assets against updated SECO sanctions lists for Belarus (and cross-reference Russia lists)
- Freeze assets of newly sanctioned persons/entities and prohibit dealings (e
- Report all affected business relationships to SECO promptly; conduct parallel GwG AML checks and file SARs if suspicions persist
- Update compliance systems, transaction monitoring rules, and staff training for goods/financial/energy sanctions; cease any prohibited services (e
- Review third-party exposures (e
Key Dates
18 July 2025 - EU adopts 18th sanctions package against Russia and additional Belarus measures.
29 October 2025 - Swiss Federal Council decides to align and amends SR 946.231.116.9.
30 October 2025 - New provisions enter into force.
13 December 2025 - Related expansion of Russia/Belarus lists (22 persons, 42 entities, 116 ships, 45 trade firms) takes effect, relevant for harmonization context.
Compliance Impact
Urgency: High - Effective 30 October 2025, these changes demand immediate portfolio screening and reporting, with non-compliance risking FINMA enforcement, asset seizure, or criminal penalties under sanctions laws. Matters due to rapid alignment with evolving EU packages, increasing circumvention ri
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Europe & international Sanctions & settlements Publication of the annual ESMA Report on Sanctions and Measures for 2024: AMF imposes the highest amounts in Europe
The ESMA Annual Report on Sanctions and Measures for 2024, published on 16 October 2025, aggregates enforcement data from EEA national competent authorities (NCAs), highlighting that the French AMF imposed the highest total sanctions at €29.4 million—nearly a third of the EEA's €100 million aggregate—primarily under MAR and MiFID II. This matters for compliance professionals as it signals intensified enforcement focus on market abuse and investor protection across Europe, with France leading in both fine amounts and settlement usage, underscoring a trend toward higher penalties and agile resolution mechanisms.
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What Changed
This is not a new regulation but a retrospective report documenting 2024 enforcement trends; no direct regulatory changes are introduced. Key observations include a significant rise in total fine amounts to over €100 million (from €71 million in 2023) despite stable sanction volumes (975 vs. 976), with MAR (377 sanctions, €45.5 million) and MiFID II/MiFIR (294 sanctions, €44.5 million) dominating. Notable shifts: increased settlement usage (94 agreements for €21.9 million, 22% of total), with AM
Key Dates
16 October 2025 - ESMA publishes second consolidated Annual Sanctions Report for 2024 data.
covering 2024 activities.
Compliance Impact
Urgency: medium – This report reinforces existing rules without new requirements, but signals escalating financial penalties (up 40% YoY) and settlement trends, pressuring firms to prioritize MAR/MiFID compliance to avoid outsized AMF-style fines, especially in France or cross-EEA operations. Matter
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Die Schweiz schliesst sich den weiteren Massnahmen des 18. Sanktionspakets der Europäischen Union (EU) gegenüber Russland sowie den zusätzlich zum 18. Sanktionspaket erlassenen Massnahmen gegenüber Belarus an. Dies hat der Bundesrat am 29. Oktober 2025 beschlossen. Im Fokus stehen Massnahmen im Güter-, Finanz und Energiebereich. Der Bundesrat hat dafür die Verordnung über Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) geändert.
On October 29, 2025, the Swiss Federal Council (Bundesrat) adopted comprehensive sanctions measures aligned with the EU's 18th sanctions package against Russia and additional measures against Belarus, effective October 30, 2025. This enforcement action significantly expands financial transaction prohibitions, export restrictions, and asset freezes, requiring Swiss financial intermediaries to immediately implement new compliance obligations across banking, goods trade, and energy sectors.
What Changed
*Financial Sector Restrictions**
The Bundesrat expanded transaction prohibitions on Russian banks substantially:
Extended existing transaction bans from 23 Russian banks to cover all specialized payment messaging services, converting these to complete transaction prohibitions
Introduced new transaction prohibitions for 22 additional Russian banks
Prohibited all transactions with the Russian Direct Investment Fund (RDIF), its sub-funds, and affiliated enterprises, tightening restrictions previou
What You Need To Do
- *Implement transaction prohibitions on all 45+ Russian banks now subject to complete bans (previously 23 with partial restrictions)
- *Freeze assets of all sanctioned persons and entities immediately upon notice
- *Report affected business relationships to SECO—this reporting obligation does not relieve firms from conducting additional due diligence when suspicious indicators exist
- *Screen counterparties against updated sanctions lists, particularly the RDIF and its sub-funds
- *Cease all transactions with newly prohibited entities, including payment system operators and financial institutions in third countries (Belarus, Kazakhstan) supporting Russian war economy
Key Dates
October 29, 2025 - Federal Council decision adopted
October 30, 2025 - Measures effective date
Ongoing - Financial intermediaries must implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs) DEADLINE
Compliance Impact
Urgency: CRITICAL
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Policy statement 18/25
PS18/25, published by the PRA on 28 October 2025, retires the "refined methodology" for Pillar 2A capital calculations, replacing it with reliance on the Basel 3.1 Credit Risk Standardised Approach (CR SA) for greater risk sensitivity, transparency, and proportionality. This near-final policy simplifies the Pillar 2A framework, reduces administrative burdens, and aligns with broader Basel 3.1 implementation and the Strong and Simple regime for Small Domestic Deposit Takers (SDDTs), promoting safety, soundness, and competition. It matters because it directly impacts credit risk capital add-ons for affected firms, requiring updates to ICAAP/SREP processes ahead of Basel 3.1 timelines.
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What Changed
Retirement of Refined Methodology: Eliminates supervisory adjustments to Pillar 2A credit risk add-ons based on IRB benchmarking, as Basel 3.1 CR SA better captures risks and reduces gaps between standardised and IRB approaches.
Policy Material Updates:
- Near-final amendments to Statement of Policy (SoP) 5/15 – The PRA’s methodologies for setting Pillar 2 capital.
- Final amendments to Supervisory Statement (SS) 31/15 – The Internal Capital Adequacy Assessment Process (ICAAP) and Supervisor
What You Need To Do
- Review and update internal Pillar 2A methodologies, ICAAP/SREP documentation to remove refined methodology reliance and align with Basel 3
- Model/calculate potential capital impacts from CR SA changes vs
- Prepare for IRRBB/pension risk clarifications in SS31/15 submissions from 1 July 2026; monitor CP12/25 review
- Engage PRA supervisors on firm-specific transitions; update reporting (e
- Firms may apply changes early in ICAAP from relevant dates (e
Key Dates
28 October 2025 - PS18/25 publication with near-final policy and PRA feedback to CP9/24/CP7/24 consultations.
1 July 2026 - Effective date for pension obligation risk amendments in SoP5/15 and SS31/15 clarifications (IRRBB changes partially deferred).
Q2 2026 - Expected finalisation of CP12/25 Phase 1 proposals (Pillar 2A review, including IRB benchmarking removal).
Basel 3.1 Implementation Date (TBD, aligned with CR SA go-live) - Retirement of refined methodology and related credit/operational risk changes.
January 2026 - PS2/26 published as final policy, minor adjustment to SS31/15 para 5.12A.
Compliance Impact
Urgency: High – Firms must act now to recalibrate Pillar 2A capital ahead of Basel 3.1 and 1 July 2026 effective dates, as retirement eliminates adjustments that reduced add-ons for low-risk CR SA firms, potentially increasing capital requirements despite Basel 3.1 offsets. Non-compliance risks supe
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Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF, under which SECO operates) has published an update to the Annex of the Ordinance of 16 December 2022 on measures concerning Haiti, reflecting UN Security Council amendments to the sanctions list. This matters for Swiss financial institutions as it triggers immediate asset freeze checks and reporting obligations to ensure compliance with Switzerland's implementation of UN sanctions via FINMA and SECO oversight, avoiding enforcement risks amid Haiti's ongoing instability. The update aligns with global renewals of Haiti sanctions, emphasizing asset freezes on newly designated individuals and entities involved in destabilizing activities.
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What Changed
Amendment to the Annex of the Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti, incorporating UN Security Council updates to the sanctions list, likely adding individuals, companies, or organizations subject to asset freezes, travel bans, and arms embargo expansions.
Reflects broader UN measures, including renewal of travel bans, asset freezes, and arms embargoes; expansion of arms embargo scope to military goods, technology, technical assistance, financial services, and brokeri
What You Need To Do
- Screening and Freezing
- Ongoing Monitoring
- Licensing Checks
- Documentation
Key Dates
Immediate (publication date: 21 October 2025) - Swiss firms must check accounts, freeze assets or economic resources of newly listed persons without prior notice, and report to SECO/FINMA without delay. DEADLINE
18 October 2024 - UN Security Council Resolution 2752 adopted, expanding arms embargo (basis for Swiss/UK updates).
17-20 October 2025 - UNSC renews regime for one year, adds 2 entries to sanctions list (UK/Jersey notices align with Swiss publication).
23 July 2025 - UK Haiti Sanctions Amendment Regulations enter force, reflecting similar UN changes.
20 March 2025 - Canadian amendments add 3 individuals (related context).
Compliance Impact
Urgency: High - Immediate asset freeze and reporting requirements carry criminal penalties for non-compliance (e.g., aligned with UK fines up to updated monetary levels); failure risks FINMA enforcement, reputational damage, and misalignment with UN obligations amid Haiti's volatile security. Matter
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Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 24. Juni 2020 über Massnahmen gegenüber Nicaragua (SR 946.231.158.5) publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF/EAER) amended the annex of the Ordinance on Measures against Nicaragua (SR 946.231.158.5) on 20 October 2025, modifying entries for two individuals, with measures entering into force immediately thereafter. This update requires Swiss financial intermediaries to promptly screen and adjust sanctions compliance programs to reflect the revised designations, ensuring no prohibited dealings with the updated list. It matters because failure to implement could trigger FINMA enforcement, asset blocking obligations, and reporting requirements under Switzerland's Embargo Act (EmbG).
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What Changed
Modification of entries for two individuals in the annex of the Ordinance on Measures against Nicaragua (SR 946.231.158.5), likely involving updates to personal details, aliases, or sanction rationales.
These changes align with ongoing maintenance of the sanctions list, originally imposed in June 2020 due to human rights, democracy, and rule-of-law concerns in Nicaragua, mirroring EU measures from 2019-2020.
No broader structural changes to the ordinance itself; this is a targeted annex update,
What You Need To Do
- Immediate screening
- Block and report
- Update compliance systems
- Monitor ongoing
- Document implementation to demonstrate due diligence in case of FINMA audits
Key Dates
20 October 2025 - Amendment to the annex published by WBF/EAER.
21 October 2025, 11:00 pm - Measures enter into force; immediate blocking and screening obligations apply.
21 October 2025 - FINMA publishes updated sanctions notice and notifies via MyFINMA.
Compliance Impact
Urgency: High – Immediate effect from 21 October 2025 demands swift action to avoid violations, as asset freezing is retroactive and non-compliance risks FINMA enforcement (e.g., fines, license restrictions). This matters amid frequent 2025 sanctions updates (e.g., 10+ Nicaragua/Myanmar deltas), hei
BankAsset ManagerWealth Manager Am 20. Oktober 2025 hat das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF die Liste der in diesem Kontext sanktionierten Personen, Unternehmen und Organisationen geändert. Das WBF hat die für die Schweiz massgebliche Sanktionsdatenbank SESAM (SECO Sanctions Management) angepasst und die Anpassung auf seiner Internetseite dringlich veröffentlicht. Die Änderung tritt am 21. Oktober 2025 23:00 Uhr in Kraft. Die Finanzintermediäre werden gemäss den Vorschriften der Verordnu...
This FINMA publication notifies Swiss financial intermediaries of updates to the Swiss sanctions list against the Islamic Republic of Iran, as amended by the Federal Department of Economic Affairs, Education and Research (WBF) on October 20, 2025, via the SESAM sanctions database. It matters because financial firms must immediately screen clients, freeze assets, and report matches to comply with Swiss sanction ordinances, amid escalating global Iran sanctions following UN snapback mechanisms. Failure to act risks enforcement by FINMA or SECO.
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What Changed
The core change is the WBF's amendment to the SESAM (SECO Sanctions Management) database, updating the list of sanctioned persons, companies, and organizations related to Iran sanctions. This aligns with the Swiss Iran Ordinance and reflects broader international reimposition of UN sanctions via the JCPOA snapback mechanism triggered in late September 2025. No new Swiss-specific requirements are introduced beyond standard implementation of the updated list, but it emphasizes urgent publication a
What You Need To Do
- Immediate screening
- Asset freeze
- Transaction blocks and reporting
- Due diligence enhancement
- Internal controls
Key Dates
20 October 2025 - WBF amends SESAM database and publishes urgent update on its website.
21 October 2025, 23:00 Uhr - Changes enter into force, binding on all Swiss financial intermediaries.
29 September 2025 - Triggering UN snapback sanctions on Iran reinstated (contextual lead-in). https://www.mrllp.com/news-item/monthly-sanctions-update-october-2025/
12 December 2025 - Swiss Federal Council expands Iran Ordinance, adding humanitarian exceptions and authorization grounds. https://sanctionsnews.bakermckenzie.com/swiss-government-significantly-expands-sanctions-against-iran/
Compliance Impact
Urgency: High - Effective immediately (post-21 Oct 2025), with today's date (Jan 2026) indicating firms had ~3 months to implement but must verify ongoing compliance amid further expansions (e.g., Dec 2025). Matters due to FINMA's strict enforcement history on sanctions (e.g., independent freezing m
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Savings protection Warning Other professionals Executive & other private individuals Retail investors Professional investors Journalists Investment management companies Listed companies and issuers The AMF has...
The AMF enforced a trading suspension on MEXEDIA S.p.A. shares on Euronext from 11 September 2025 to 30 September 2025 due to indicators of **pump and dump** market abuse, urging investors to exercise extreme caution against unauthorized high-upside recommendations. This enforcement action underscores the AMF's proactive market surveillance and highlights ongoing risks of manipulative practices in listed equities, serving as a reminder for firms to bolster internal controls against such schemes. Compliance teams should note this as a signal of heightened regulatory scrutiny on price manipulation, potentially informing future enforcement trends.
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What Changed
This is an enforcement action rather than new regulatory changes; no legislative or rule amendments are introduced. Key elements include:
AMF's invocation of financial markets and market abuse regulations to mandate trading suspension via Euronext.
Explicit warning on pump and dump tactics, defined as unauthorized promotions inflating share prices for insider sales, leading to investor losses.
Follow-up resumption of trading on 1 October 2025 after suspension ended, with continued vigilance call
What You Need To Do
- Trading venues (e.g., Euronext)
- Investment firms and brokers
- Advisory firms
- All surveilled firms
- Investors and firms assisting them
Key Dates
11 September 2025 - Trading suspension in MEXEDIA shares effective at end of session.
12 September 2025 - AMF press release published (French version).
30 September 2025 - Scheduled end of suspension period (inclusive).
1 October 2025 - Resumption of trading confirmed; pre-suspension orders purged.
Compliance Impact
Urgency: Medium - This is a resolved, case-specific enforcement (suspension lifted 1 October 2025), not imposing new firm-wide rules, reducing immediate action needs as of January 2026. It matters for market abuse surveillance programs, signaling AMF's focus on pump-and-dump in equities, which could
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Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung über Massnahmen gegenüber Burundi (SR 946.231.121.8) publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF/DEFR) has updated the annex to the Ordinance on Measures against Burundi (SR 946.231.121.8), modifying the list of sanctioned persons, companies, and organizations in the SESAM database. This matters for Swiss financial institutions as it imposes immediate asset freeze and transaction restrictions, aligning with FINMA's heightened focus on sanctions risks amid geopolitical tensions.
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What Changed
Modification to the list of sanctioned individuals, enterprises, and organizations under the Burundi sanctions ordinance.
Update published in the SECO Sanctions Management (SESAM) database, which is the authoritative Swiss reference for sanctions compliance.
No details on specific additions, deletions, or alterations to designations are provided in the publication summary, but changes trigger mandatory screening and blocking obligations.
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What You Need To Do
- Screen clients, transactions, and assets against the updated SESAM database immediately upon effectiveness (post-8 October 2025, 23:00)
- Freeze assets of newly listed or modified sanctioned parties without prior notice and report to SECO/FINMA via MyFINMA notification system
- Cease any direct or indirect provision of funds/economic resources to sanctioned parties; conduct retrospective reviews of existing relationships for Burundi exposure
- Update internal sanctions screening tools, policies, and staff training to reflect SESAM changes; document compliance efforts for potential FINMA audits
Key Dates
6 October 2025 - DEFR modifies the sanctions list and updates SESAM database.
8 October 2025, 23:00 hours - Changes enter into force; asset freezes and prohibitions apply immediately thereafter.
Compliance Impact
Urgency: High - Immediate effectiveness (8 October 2025) requires swift database rescreening to avoid violations, with FINMA emphasizing sanctions evasion risks in its 2025 Risk Monitor amid geopolitical shifts; non-compliance risks enforcement actions, fines, or reputational damage.
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Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung (WBF) hat eine Änderung des Anhangs 1 der Verordnung vom 1. Juni 2012 über Massnahmen gegenüber Guinea-Bissau (SR 946.231.138.3) publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) published an amendment to Annex 1 of the Ordinance on Measures against Guinea-Bissau (SR 946.231.138.3) on October 7, 2025, updating the sanctions list maintained in the SESAM database. This change, effective October 8, 2025, requires Swiss financial intermediaries to immediately screen clients, freeze assets of listed individuals, and report to SECO, reinforcing compliance with UN Security Council Resolution 2048 (2012) and EU measures following the 2012 military coup. It matters for preventing sanctions evasion and ensuring adherence to Switzerland's Embargogesetz (EmbG), with non-compliance risking FINMA enforcement.
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What Changed
Amendment to Annex 1 of the Ordinance dated June 1, 2012, on measures against Guinea-Bissau, as published by WBF on October 6, 2025, and reflected in FINMA's announcement on October 7, 2025.
Updates to the SESAM (SECO Sanctions Management) database, which is the authoritative Swiss sanctions list; specific details on additions, deletions, or modifications to listed natural persons (e.g., changes for six individuals noted in related updates) were implemented.
Prohibition on dealings with listed p
What You Need To Do
- Screen customer relationships against the updated SESAM list immediately upon effectiveness using heightened due diligence per GwG Art
- Freeze assets of any matched listed persons/entities and prohibit new business
- Report affected relationships to SECO without delay; conduct additional checks and file SARs with MROS if suspicions remain
- Update internal sanctions screening systems and monitor MyFINMA for FINMA notifications
- Document compliance actions to demonstrate adherence in audits or FINMA inquiries
Key Dates
October 6, 2025 - WBF adjusts SESAM database and publishes changes on its website.
October 7, 2025 - FINMA publishes the sanctions notice.
October 8, 2025, 23:00 Uhr - Changes enter into force; immediate implementation required for asset freezes and prohibitions. DEADLINE
prior 2024 update had a similar timeline effective October 8, 2024, at 18:00 Uhr, indicating recurring list maintenance.)
Compliance Impact
Urgency: High - Immediate asset freeze and reporting are mandatory from October 8, 2025, with violations exposing firms to FINMA fines, reputational damage, or criminal liability under EmbG and GwG. This update underscores ongoing list volatility (e.g., similar 2024 change), demanding robust real-ti
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Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 7 der Verordnung vom 8. Juni 2012 über Massnahmen gegenüber Syrien (SR 946.231.172.7) publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) updated Annex 7 of the Ordinance on Measures against Syria (SR 946.231.172.7) on October 6, 2025, modifying the list of sanctioned persons, companies, and organizations, effective October 8, 2025. This change requires Swiss financial intermediaries to immediately implement asset freezes and report affected relationships to SECO, amid broader Swiss alignment with EU and US easing of Syria sanctions earlier in 2025. It matters for compliance as it mandates swift screening updates to avoid violations of ongoing targeted financial sanctions.
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What Changed
The WBF amended the list of sanctioned entities in Annex 7 of SR 946.231.172.7, updating the SESAM sanctions database (SECO Sanctions Management).
Financial intermediaries must enforce prohibitions, freeze assets of listed parties, and report business relationships to SECO.
Reporting to SECO does not exempt intermediaries from conducting due diligence under Art. 6 GwG (Anti-Money Laundering Act) and filing suspicions with the Money Laundering Reporting Office under Art. 9 GwG if issues persist.
What You Need To Do
- Screen client portfolios, accounts, and transactions against the updated SESAM database immediately upon effectiveness
- Freeze assets of newly listed or affected sanctioned parties and implement transaction prohibitions
- Report all impacted business relationships to SECO promptly
- Conduct GwG due diligence (Art
- Update internal sanctions screening systems and train staff on changes; retain evidence of compliance for audits
Key Dates
October 6, 2025 - WBF publishes update to Annex 7 and SESAM database.
October 8, 2025 at 23:00 - Changes enter into force; asset freezes and prohibitions apply immediately.
Compliance Impact
Urgency: High - Immediate asset freeze and reporting obligations take effect October 8, 2025, with non-compliance risking FINMA enforcement, fines, or criminal liability under sanctions laws. This matters as it occurs against a backdrop of Syria sanctions easing (e.g., Swiss economic sanctions lifte
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Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen des Anhangs 8 der Verordnung vom 4. März 2022 über Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) publiziert.
The publication announces updates by the Swiss Federal Department for Economic Affairs, Education and Research (WBF) to Annex 8 of the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning Swiss sanctions against Russia with ongoing international restrictions. This matters for Swiss financial intermediaries as it imposes immediate obligations to block assets, report relationships, and conduct AML checks, amid escalating sanctions that heighten compliance risks and enforcement scrutiny from FINMA.
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What Changed
Amendments to Annexes 8, 14, 15b, and 33 of the Ordinance, though specific details on new listings or prohibitions are not detailed in the announcement.
Continuation of standard requirements: Implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs).
These updates follow a pattern of prior changes, such as expanded export bans on dual-use goods (e.g., chrome ore, chemicals), transaction bans on additio
What You Need To Do
- Screen and freeze assets
- Report to SECO
- Conduct AML due diligence
- Review transactions
- Document compliance
Compliance Impact
Urgency: Critical – Effective immediately at 23:00 on January 13, 2026, with no grace period, this demands urgent system updates, screenings, and reporting to avoid FINMA enforcement (e.g., fines, licenses at risk). It amplifies AML / Financial Crime risks in a high-scrutiny environment, as FINMA's
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Sanctions & settlements professional obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines an asset management company and its two managers a total of €1.3 million
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) a total of €1.3 million on 15 September 2025 for breaches of professional obligations, including non-operational investment procedures, inadequate AML/CFT due diligence, deficient marketing materials, and unproven benefits from fee retrocessions to distributors. This decision underscores the AMF's heightened scrutiny on operational controls and senior accountability in asset management, serving as a critical enforcement signal for firms to strengthen procedures amid a pattern of similar sanctions.
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What Changed
This is an enforcement action rather than new legislation, but it reinforces and clarifies existing professional obligations under AMF regulations for asset managers (sociétés de gestion), particularly under the AIFM regime. Key expectations highlighted include:
Operational investment/divestment procedures: Must be fully implemented, with traceability of checks on lender authorizations and compliance with fund policies.
AML/CFT due diligence: Systematic verification required on fund assets and l
What You Need To Do
- Audit procedures immediately
- Enhance AML/CFT systems
- Validate marketing and fees
- Senior manager training
- Mock AMF inspections
Key Dates
15 September 2025 - AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners, Maurice Tchenio, and Patrick de Giovanni.
16 September 2025 - French version of press release published.
Post-15 September 2025 (exact date unspecified) - Appeal lodged by Altaroc Partners, Tchenio, and de Giovanni before the Conseil d’État against decision SAN-2025-09.
Compliance Impact
Urgency: High – This fits a 2025 enforcement trend targeting asset managers' operational deficiencies (e.g., similar fines against Novaxia Investissement on 10 December 2025, M Capital Partners on 31 December 2025, and Eternam on 9 September 2025), signaling AMF's zero-tolerance for non-operational
Asset Manager
No description available.
The CFTC issued an order on September 17, 2025, sanctioning Shinhan Securities Co. Ltd. with a $212,500 civil monetary penalty for engaging in wash sales and non-competitive transactions on NYMEX, involving near-simultaneous bids and offers for the same futures contracts under the same beneficial owner to avoid risk and price competition. This enforcement action underscores the CFTC's ongoing focus on market manipulation practices that undermine open and competitive trading, serving as a reminder for firms to enhance trade surveillance and compliance programs. Compliance professionals should note this as evidence of active CFTC scrutiny on wash trading violations under the Commodity Exchange Act (CEA).
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What Changed
This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements introduced. It reaffirms existing prohibitions under CEA Section 6(c)(2) against wash sales (fictitious sales) and non-competitive transactions that negate risk or price competition in futures markets. The case highlights CFTC's interpretation of wash sales as including trades where buy and sell orders for identical quantities of the same contract are executed near-simultaneously for accounts
What You Need To Do
- Enhance trade surveillance
- Conduct gap analysis
- Strengthen internal controls
- Self-reporting consideration
- Training and recordkeeping
Key Dates
September 17, 2025 - CFTC issues order filing and settling charges against Shinhan, requiring immediate payment of $212,500 penalty and cease-and-desist order.
Compliance Impact
Urgency: Medium - This action signals sustained CFTC enforcement on wash sales amid broader anti-manipulation priorities, with penalties reflecting cooperation but still material ($212,500). It matters because wash trades erode market integrity, and recent advisories incentivize proactive remediatio
Broker Dealer
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations
The AMF Enforcement Committee fined an asset management company €400,000 on 9 September 2025 for multiple breaches of professional obligations, including deficient marketing disclosures, inadequate conflict of interest systems, non-operational valuation procedures, failure to oversee external experts, and deficient AML/CFT systems in managing AIFs and club deals. This enforcement action underscores the AMF's focus on operational robustness and investor protection in asset management, serving as a critical reminder for firms to ensure procedures are not only documented but fully operational and effective. Compliance teams should review this to benchmark internal controls, as it highlights personal accountability for senior managers and recurring AMF priorities in recent sanctions.
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What Changed
This is an enforcement decision, not a regulatory change introducing new rules; it enforces existing professional obligations under AMF jurisdiction for asset managers. Key requirements reaffirmed include:
Providing comprehensive, accurate, and understandable information to investors on fee retrocessions to distributors in AIF marketing.
Implementing effective systems for preventing and managing conflicts of interest, particularly in joint investments like club deals classified as Other AIFs.
Ma
What You Need To Do
- Verify investor disclosures on fee retrocessions are comprehensive and understandable; update marketing materials for AIFs and club deals accordingly
- Formalize independent valuer roles and implement monitoring for external experts per activity programs
- Enhance AML/CFT due diligence on fund assets/liabilities, including risk mapping and procedure testing
- Senior managers
- Test procedures via internal audits; remediate deficiencies proactively to mitigate enforcement risk
Key Dates
9 September 2025 - AMF Enforcement Committee decision imposing €400,000 fine on Eternam for breaches.
Compliance Impact
Urgency: High – This recent (2025) decision aligns with a pattern of AMF fines on asset managers for similar operational and AML failures (e.g., €1.3M on Altaroc Partners for lacking investment procedures and AML due diligence; €200K+ on M Capital for non-operational systems and AML deficiencies). I
Asset Manager
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 7 der Verordnung vom 11. November 2015 über Massnahmen gegenüber der Islamischen Republik Iran (SR 946.231.143.6) publiziert.
On August 18, 2025, the Swiss State Secretariat for Economic Affairs (WBF) published an updated sanctions notification regarding Iran, specifically modifying Annex 7 of the Ordinance on Measures against the Islamic Republic of Iran (SR 946.231.143.6). This update is critical for Swiss financial institutions and businesses because it reflects the evolving sanctions landscape following the automatic reinstatement of UN Security Council resolutions on Iran's nuclear program in September 2025.
What Changed
The August 2025 notification updated the list of designated persons, entities, and organizations subject to Swiss sanctions against Iran. While the search results do not provide the specific details of individual entries added or removed from Annex 7, this type of notification typically reflects changes to the UN Security Council's consolidated sanctions list that Switzerland is obligated to implement under its Embargo Act (EmbG).
The broader context shows that Switzerland was preparing for sig
What You Need To Do
- *Immediate compliance obligations
- *Sanctions List Screening
- *Transaction Review
- *Account Monitoring
- *Policy Updates
Key Dates
August 18, 2025 - WBF published updated sanctions notification for Iran (Annex 7 modifications)
August 28, 2025 - Germany, France, and UK triggered UN snapback mechanism
September 15, 2025 - Harmonization of sanctions ordinances entered into force (affecting financial sanctions procedures across multiple jurisdictions including Iran)
September 27, 2025 - UN nuclear-related sanctions against Iran automatically reinstated
September 28, 2025 - EU reactivated suspended sanctions related to Iran's proliferation activities
Compliance Impact
Urgency: CRITICAL
BankAsset ManagerPayment Provider Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung der Liste der sanktionierten natürlichen Personen, Unternehmen und Organisationen der Verordnung vom 30. März 2011 über Massnahmen gegenüber Libyen (SR 946.231.149.82) publiziert.
This FINMA publication announces an update by Switzerland's State Secretariat for Economic Affairs (SECO) to the sanctions list under the Ordinance of 30 March 2011 on Measures against Libya (SR 946.231.149.82), aligning Swiss sanctions with changes in the UN Libya sanctions regime. It matters for Swiss financial institutions as it triggers immediate screening and compliance obligations to avoid violations of asset freeze and related restrictions on designated persons, entities, or organizations. Failure to act promptly risks enforcement by FINMA.
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What Changed
The core change is an amendment to the list of sanctioned natural persons, companies, and organizations in SR 946.231.149.82, as published by SECO. This reflects broader UN Security Council updates via Resolution 2769 (2025), which introduced new designation criteria for individuals/entities supporting armed groups or criminal networks through illicit exploitation/export of crude oil or refined petroleum from Libya, alongside exemptions for certain arms embargo activities, allowances for Libyan
What You Need To Do
- Screen immediately
- Freeze assets
- Cease dealings
- Update systems
- Monitor related flows
Key Dates
Immediate upon publication (19 August 2025) - Swiss firms must implement updated sanctions list screening and freeze applicable assets/transactions per FINMA/SECO requirements (https://www.finma.ch/en/news/2025/08/20250819-sr-946-231-149-82/). DEADLINE
1 May 2026 - Expiration of UN authorizations/measures on illicit petroleum exports from Libya (Resolution 2769).
15 May 2026 - End of UN Panel of Experts mandate monitoring Libya sanctions.
Compliance Impact
Urgency: High - Immediate action required due to asset freeze obligations; non-compliance risks FINMA fines, reputational damage, or criminal liability under Swiss AML/sanctions laws. This matters amid evolving geopolitical risks (e.g., petroleum smuggling destabilizing Libya), as flagged in FINMA's
BankWealth ManagerPayment Provider Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung des Anhangs 2 der Verordnung vom 12. August 2015 über Massnahmen gegenüber der Republik Südsudan (SR 946.231.169.9) publiziert.
FINMA has published an update notifying financial intermediaries of changes to Annex 2 of the Ordinance on Measures against the Republic of South Sudan (SR 946.231.169.9), as announced by SECO on August 18, 2025, effective August 20, 2025. This matters because it imposes immediate asset freeze and transaction ban obligations on Swiss financial institutions with exposure to newly or modified sanctioned entities, aligning with UN Security Council Resolution 2206 (2015) and EU measures to address South Sudan's ethnic conflict, human rights violations, and humanitarian crisis. Compliance failure risks enforcement actions under the Embargo Act (EmbG) and AML regulations (GwG).
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What Changed
SECO amended Annex 2 of the Ordinance, likely adding, removing, or modifying listings of sanctioned persons, companies, or organizations related to South Sudan.
The update requires implementation of prohibitions (e.g., no new business), asset freezing for listed parties, and reporting of affected relationships to SECO.
Changes stem from ongoing enforcement of UN and EU sanctions, with Switzerland implementing via the Embargo Act; Annexes are dynamically updated.
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What You Need To Do
- Screen client portfolios, transactions, and relationships against the updated SESAM database and Annex 2 via FINMA's website or MyFINMA portal
- Freeze assets of newly listed parties without delay; block prohibited transactions
- Report affected business relationships to SECO promptly; conduct additional GwG Art
- Update internal sanctions screening systems and train staff; document compliance for audit trails
Key Dates
18.08.2025 - SECO publishes amendment to Annex 2.
19.08.2025 - FINMA issues public notification of the update.
20.08.2025 - Amendment enters into force; asset freezes and prohibitions apply immediately.
Compliance Impact
Urgency: High - Immediate effect from August 20, 2025, mandates asset freezes and reporting with no grace period, exposing non-compliant firms to FINMA enforcement, fines, or reputational damage under EmbG and GwG. South Sudan sanctions are niche but cumulative updates (e.g., similar to Sudan change
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Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung (WBF) hat den Anhang 2 der Verordnung vom 25. Mai 2005 über Massnahmen gegenüber Sudan (SR 946.231.18) geändert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has amended Annex 2 of the Ordinance of May 25, 2005, on Measures against Sudan (SR 946.231.18), updating Switzerland's sanctions list in alignment with the SESAM database managed by SECO. This change, effective immediately on a urgent basis, requires Swiss financial intermediaries to implement updated asset freezes and transaction restrictions without delay, heightening compliance risks amid ongoing international sanctions escalation on Sudan-related actors. It matters because non-compliance exposes firms to FINMA enforcement, reputational damage, and penalties under anti-money laundering and sanctions regimes.
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What Changed
Amendment to Annex 2 of SR 946.231.18, which lists designated persons, entities, and assets subject to sanctions such as asset freezes and prohibitions on making funds or economic resources available.
Updates reflected in the official Swiss sanctions database SESAM (SECO Sanctions Management), published on the SECO website, ensuring harmonized implementation across Switzerland.
Urgent (dringliche) amendment entering into force immediately, bypassing standard consultation periods to address time-
What You Need To Do
- Screen against updated SESAM database
- Transaction screening and blocking
- Internal compliance update
- Reporting obligations
- Audit and evidence retention
Compliance Impact
Urgency: High – The urgent effective date mandates immediate action to avoid violations, with FINMA's enforcement history showing fines up to CHF 500,000+ for sanctions breaches. This matters amid Sudan's escalating conflict, where global sanctions (e.g., EU/UK additions in 2025) increase circumvent
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Adoption of the EBA Guidelines on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures (sanctions)
Circular CSSF 25/896 adopts the EBA Guidelines EBA/GL/2024/14 and EBA/GL/2024/15, mandating Luxembourg financial institutions to establish robust internal policies, procedures, and controls for complying with EU and national restrictive measures (sanctions). This matters because it sets binding EU-wide standards to prevent sanctions violations and circumvention, with absolute obligations for immediate asset freezing and reporting, amid escalating geopolitical tensions.
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What Changed
Institutions must develop, implement, and maintain up-to-date policies, procedures, and controls for identifying, investigating, and applying restrictive measures without delay, including risk management for violations and circumvention.
Management body responsibilities expanded: approve sanctions compliance strategy, oversee implementation, conduct at least annual assessments of exposure and controls, ensure remedial actions, and report deficiencies.
Screening and monitoring requirements: Maint
What You Need To Do
- Conduct annual exposure assessments to sanctions risks and circumvention; update policies accordingly
- Appoint senior management/board-level responsibility for approving and overseeing sanctions strategy, including annual reviews and deficiency reporting
- Implement reliable screening systems for customers, transactions, and lists; define screenable datasets; test systems regularly for effectiveness (e
- Provide documented training to relevant staff on sanctions, institutional exposure, and internal processes
- Establish processes for immediate action on matches: suspend transfers, freeze assets, report to Ministry of Finance/CSSF/FIU without delay; maintain whitelists only under strict conditions
Compliance Impact
Urgency: High – With less than 12 months until the 30 December 2025 deadline (as of January 2026), firms face binding requirements for absolute compliance, including personal accountability for management bodies; non-compliance risks enforcement by CSSF, reputational damage, and fines amid frequent
BankPayment ProviderCrypto Exchange
Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung des Anhangs der Verordnung vom 7. August 1990 über Wirtschaftsmassnahmen gegenüber der Republik Irak (SR 946.206) publiziert.
The Swiss State Secretariat for Economic Affairs (SECO) published an updated sanctions notification on August 13, 2025, reflecting modifications to the UN sanctions list targeting Iraq under the Ordinance of August 7, 1990 (SR 946.206). This update is automatically applicable in Switzerland and requires immediate compliance by all financial institutions and regulated entities, as Switzerland implements UN Security Council sanctions lists without delay through its automatic application framework.
What Changed
The UN Sanctions Committee modified the list of sanctioned individuals, companies, and organizations subject to Iraq-related sanctions on August 5, 2025. The specific modifications to the sanctions list were incorporated into Switzerland's SESAM database (SECO Sanctions Management), which serves as the authoritative sanctions reference for Swiss compliance purposes. Under Switzerland's automatic application ordinance adopted by the Federal Council on March 4, 2016, amendments to UN Security Coun
What You Need To Do
- *Update screening systems immediately - Integrate the August 5, 2025 modifications into transaction monitoring and customer due diligence systems
- *Review existing customer relationships - Screen all current customers, counterparties, and beneficial owners against the updated SESAM database
- *Audit transaction history - Identify any transactions processed between August 5-13, 2025 that may have involved newly sanctioned parties
- *Document compliance procedures - Maintain records demonstrating implementation of updated sanctions screening
- *Train compliance staff - Ensure all relevant personnel understand the updated sanctions list and screening requirements
Key Dates
August 5, 2025 - UN Sanctions Committee decision modifying the Iraq sanctions list
August 13, 2025 - SECO published the updated sanctions notification and SESAM database modifications
Immediate - Effective date in Switzerland (automatic application upon UN modification)
Compliance Impact
Urgency: CRITICAL
BankPayment ProviderAll Firms
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung der Anhänge 5, 13, 14 und 15 der Verordnung über Massnahmen gegenüber Belarus (SR 946.231.116.9) publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) published updates to Annexes 5, 13, 14, and 15 of the Ordinance on Measures against Belarus (SR 946.231.116.9), aligning Switzerland with additional EU sanctions imposed on July 18, 2025, in response to Belarus's involvement in Russia's war against Ukraine. This matters for Swiss financial institutions as it expands asset freezes, reporting obligations, and prohibitions, strengthening sanctions parity with Russia to prevent circumvention and enhance enforcement effectiveness.
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What Changed
The updates amend Annexes 5, 13, 14, and 15 of SR 946.231.116.9, incorporating EU measures beyond the 18th Russia sanctions package, focusing on goods, financial, and energy sectors. Specific enhancements include expanded lists of sanctioned goods for military/technological strengthening (Annex 3 updated 29.10.2025), high-priority goods (Annex 11a), and industrial strengthening goods (Annex 19). Financial sanctions reinforce asset freezes, prohibitions on providing funds/services to listed parti
What You Need To Do
- Screen clients, assets, and transactions against updated Annexes 5, 13-15, and related lists (e
- Conduct GwG Art
- Cease prohibited activities
- Update internal screening tools, policies, and training; monitor SECO/FINMA websites for ongoing Anhänge updates
- For trade/energy firms
Key Dates
30 October 2025 - New provisions from Bundesrat decision on 29 October 2025 enter into force, requiring immediate implementation of updated Belarus measures.
13 December 2025 - Expansions to sanctions lists for Russia/Belarus (including 22 persons, 42 entities, 116 ships, 45 trade firms, 5 banks) take effect.
15 September 2025 - Harmonization of financial sanctions across multiple regimes (including Belarus) enters into force, clarifying fund crediting on blocked accounts and reporting.
12 December 2025 - Publication of list expansions by WBF/SECO.
Compliance Impact
Urgency: High - Immediate effect from 30 October 2025 demands swift asset screening and reporting to avoid GwG/EmbG violations, with heightened FINMA scrutiny amid Russia-Belarus alignment and recent list expansions (e.g., December 2025). Non-compliance risks enforcement, reputational damage, and sa
BankWealth ManagerPayment Provider Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 28. Juni 2023 über Massnahmen betreffend Moldau (SR 946.231.156.5) publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) published an update to Annex of the Ordinance on Measures concerning Moldova (SR 946.231.156.5) on August 11, 2025, expanding the sanctions list for Moldova-related destabilizing activities. This matters for Swiss financial intermediaries as it imposes immediate asset freeze and reporting obligations under the Embargo Act (EmbG) and Anti-Money Laundering Act (GwG), aligning Switzerland with EU measures to counter threats to Moldova's sovereignty amid regional instability.
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What Changed
Updated Sanctions List: The WBF amended the Annex to include additional natural or legal persons, organizations, or entities subject to financial sanctions, effective immediately upon publication.
Financial Sanctions Reinforced: Mandatory asset freezes (sperre von Vermögenswerten), prohibitions on making funds or economic resources available (Bereitstellungsverbote), and reporting requirements to SECO for frozen assets remain core, mirroring EU Regulation 2023/888 updates.
No Change to Core Ordi
What You Need To Do
- Screen Client Base
- Freeze and Report Assets
- AML Due Diligence
- Internal Controls
- Monitor Ongoing
Key Dates
11.08.2025 - Publication of Annex update by WBF .
12.08.2025 - Measures enter into force (based on similar recent updates; immediate effect standard).
Immediate (unverzüglich) - Report frozen assets to SECO .
28.06.2023 - Original Ordinance effective date (context for baseline measures).
Compliance Impact
Urgency: High – Immediate asset blocking and SECO reporting are mandatory with no grace period, risking FINMA enforcement (e.g., fines, reputational damage) for non-compliance; matters due to expanding geopolitical risks in Eastern Europe, potential for rapid list growth, and overlap with high-volum
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Das Departement für Wirtschaft, Bildung und Forschung (WBF) hat die Erweiterung der Sanktionslisten betreffend Russland publiziert. Die Schweiz hat damit diverse Änderungen übernommen, welche die EU im Rahmen ihres 18. Sanktionspakets beschlossen hatte.
This FINMA publication announces Switzerland's adoption of the EU's 18th sanctions package against Russia, expanding the sanctions lists with new designations and restrictions via the Swiss State Secretariat for Economic Affairs (SECO/WBF). It matters because Swiss financial institutions must immediately screen and freeze assets of newly listed parties, aligning with heightened FINMA enforcement on Russia sanctions risks amid ongoing geopolitical tensions. Compliance teams face elevated legal, reputational, and secondary sanctions exposure from US/EU measures.
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What Changed
The core update involves Switzerland incorporating EU Council decisions from the 18th sanctions package, which typically include:
Additions to asset freeze lists targeting Russian individuals, entities, and sectors like energy, finance, and dual-use goods.
Expanded prohibitions on making funds or economic resources available to designated parties.
Alignment with EU sectoral restrictions on Russia's financial messaging services (e.g., SPFS), oil trade, and shadow fleet activities, now binding in
What You Need To Do
- Screen sanctions lists immediately
- Enhance customer due diligence (CDD)
- Report to FINMA/SECO
- Update policies
- Train staff
Key Dates
Immediate upon publication (August 13, 2025) - Swiss sanctions lists updated; asset freezes and prohibitions take effect instantly for newly designated parties.
15 December 2025 - Noted FINMA reference for ongoing list updates and independent freezing measures.
31 July 2026 - EU sectoral sanctions against Russia renewed until this date (adopted December 2025), influencing Swiss alignment.
Compliance Impact
Urgency: High - This directly expands enforceable prohibitions, with FINMA's targeted on-site reviews and "very high" Russia sanctions risk rating amplifying enforcement (https://www.finma.ch/en/~/media/finma/dokumente/dokumentencenter/myfinma/finma-publikationen/risikomonitor/20251117-finma-risikom
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No description available.
On July 31, 2025, Switzerland's State Secretariat for Economic Affairs (SECO) amended the annex to the Syria Asset Freezing Ordinance (SR 196.127.27), originally enacted March 7, 2025, to update the list of designated individuals subject to comprehensive asset freezes. This amendment reflects Switzerland's ongoing implementation of targeted financial sanctions against politically exposed persons connected to the former Assad regime, requiring immediate compliance from all financial intermediaries and asset holders operating in Swiss jurisdiction.
What Changed
The July 31, 2025 amendment modified the annex (list of designated persons) to the Syria Asset Freezing Ordinance without altering the substantive freezing requirements themselves. The original ordinance, enacted March 7, 2025, froze all assets of 17 designated individuals; the July amendment adjusted this list, though the specific names added or removed are not detailed in the available regulatory notices.
The amendment operates under the Federal Act on the Freezing and Restitution of Illicit
What You Need To Do
- *Immediate compliance steps for financial institutions:
- *Update sanctions screening systems to reflect the amended annex list as of July 31, 2025
- *Freeze all assets of newly designated individuals without delay, including bank accounts, securities, real estate, and other property of any kind
- *File mandatory reports with the Money Laundering Reporting Office (MROS) for all frozen assets under Article 3 of the FIAA
- *Conduct enhanced due diligence on existing client relationships to identify any connections to designated persons or their family members, associates, or controlled entities
Key Dates
March 7, 2025, 6:00 PM UTC – Original Syria Asset Freezing Ordinance entered into force
July 31, 2025, 6:00 PM UTC – Amendment to annex (list of designated persons) entered into force
Ongoing – Immediate freezing obligation upon designation; no grace period applies
Four-year validity – The ordinance remains valid for four years from March 7, 2025, unless extended or modified
Compliance Impact
Urgency: CRITICAL
BankWealth ManagerAsset Manager
Sanctions & settlements professional obligations Disclosure Obligations Other professionals Journalists The AMF Enforcement Committee fines a Danish investment bank for breaches of professional obligations committed by a French branch
The AMF Enforcement Committee imposed a €300,000 fine on Saxo Bank A/S on 16 July 2025 for multiple breaches of professional obligations committed through its French branch, including failures to properly inform clients about significant changes to derivatives procedures, margin calculations, and securities transaction incidents, as well as deficiencies in equity savings plan (PEA) transfers. This enforcement action demonstrates the AMF's active oversight of cross-border investment banks operating in France and highlights critical gaps in client disclosure practices that compliance teams must address.
What Changed
The enforcement decision does not introduce new regulatory requirements but rather clarifies existing obligations under current French financial regulations. The key compliance expectations reinforced include:
Client notification requirements for significant procedural changes affecting derivatives trading and margin calculations
Incident disclosure obligations for securities transactions that could materially affect order execution
Timely information provision regarding regulatory consequences
What You Need To Do
- *Implement incident reporting protocols for securities transactions that could affect order execution, with documented evidence of timely client notification
- *Review PEA transfer procedures to ensure compliance with regulatory timeframes and proper documentation of information provided to clients regarding Brexit-related consequences
- *Strengthen information governance to ensure all material operational changes are communicated to clients within required timeframes and with appropriate detail
- *Conduct compliance training for front-office and operations staff on professional obligations regarding client communication and information disclosure
Key Dates
16 July 2025 - AMF Enforcement Committee decision issued imposing €300,000 fine
22 July 2025 - Official publication of enforcement decision
No specified deadline - Appeal period available (no specific timeframe stated in the decision)
Compliance Impact
Urgency: HIGH
Broker DealerBank
Sanctions & settlements MAR professional obligations Investment advice Other professionals Journalists Listed companies and issuers The AMF Enforcement Committee fines eight individuals and two legal entities a total of €1,890,000 for late...
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Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti (SR 946.231.139.4) publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has published an update to Annex 2 of the Ordinance on Measures concerning Haiti (SR 946.231.139.4), dated December 16, 2022, aligning Switzerland's sanctions regime with recent UN Security Council decisions. This matters for Swiss financial institutions as it mandates immediate screening against potentially updated lists of designated persons and entities, reinforcing asset freezes, travel bans, and an expanded arms embargo to address Haiti's instability. Non-compliance risks FINMA enforcement actions under anti-money laundering and sanctions frameworks.
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What Changed
Annex Update: The amendment modifies the annex to the Haiti Ordinance, likely incorporating additions to the UN Sanctions List, such as new designated individuals or entities involved in destabilizing activities like illicit natural resource exploitation, as seen in parallel UN actions (e.g., 2 new entries added on October 17/20, 2025).
Sanctions Renewal and Expansion: Reflects UNSC Resolution 2752 (2024, adopted October 18, 2024) and subsequent renewals (e.g., Resolution 2794 (2025)), renewing
What You Need To Do
- Screen Immediately
- Cease Prohibited Activities
- Report Findings
- Update Policies/Systems
- License Checks
Key Dates
October 18, 2024 - UNSC Resolution 2752 adoption Expands arms embargo scope, basis for national implementations.
July 23, 2025 - UK Haiti Sanctions Amendment effective Parallel indicator of timeline for UN-aligned changes.
October 17/20, 2025 - UNSC Committee adds 2 entries to Sanctions List Triggers immediate asset freeze checks; Swiss update (SR 946.231.139.4) published in response.
October 21, 2025 - Swiss WBF/VTG announcement Confirms amended sanctioned list.
Immediate/publication date (2025/07/09 per FINMA notice) - Swiss Annex amendment effective No grace period specified; aligns with "without delay" freezing requirements.
Compliance Impact
Urgency: High – Immediate asset freeze obligations apply "without delay" upon list updates, with FINMA's enforcement type indicating potential fines or reputational damage for lapses; matters due to Haiti's volatility driving frequent UN changes, risking secondary sanctions exposure for Swiss firms
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Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung über Massnahmen betreffend Guatemala (SR 946.231.137.6) publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has published an update to Annex 2 of the Ordinance on Measures concerning Guatemala (SR 946.231.137.6), aligning Swiss sanctions with international developments targeting threats to democracy and rule of law in Guatemala. This matters for Swiss financial institutions as it mandates immediate screening and blocking of newly designated persons/entities to prevent sanctions violations, reinforcing Switzerland's commitment to international sanctions regimes amid ongoing geopolitical tensions in Central America. https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/
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What Changed
Amendment to Annex 2 of SR 946.231.137.6, likely adding or updating designations of individuals, groups, or entities involved in undermining Guatemala's democracy, rule of law, or election integrity, consistent with parallel EU actions.
Measures include asset freezes (prohibiting Swiss persons from dealing with designated assets) and transaction prohibitions, with independent freezing by FINMA where required under Swiss law.
Updates are published in the Federal Gazette and integrated into FINMA'
What You Need To Do
- Immediate screening
- Enhanced due diligence
- System updates
Key Dates
26 June 2025 - Publication of annex amendment by WBF; immediate effectiveness for screening and blocking obligations.
Ongoing (continuous) - Annex updates published in Federal Gazette; firms must integrate changes without specified delay. DEADLINE
15 December 2025 - Reference date for related FINMA sanctions annex maintenance (not specific to this update but indicative of cycle). https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/ https://www.finma.ch/en/documentation/international-sanctions-and-combating-terrorism/international-sanctions-and-independent-freezing-measures/
Compliance Impact
Urgency: High - Swiss sanctions take effect immediately upon publication, exposing non-compliant firms to FINMA enforcement (fines up to CHF 1M, reputational damage). This aligns with rising geopolitical risks flagged in FINMA Risk Monitor 2025, where sanctions evasion amid corruption flows could tr
BankWealth ManagerPayment Provider Sanctions & settlements MAR Journalists Listed companies and issuers The AMF Enforcement Committee fines an issuer €20,000 and its shareholders a total of €1.7 million
The AMF Enforcement Committee imposed fines totaling €1.72 million on 10 June 2025 against SMCP (an issuer) and its major shareholders European TopSoho, Dynamic Treasure Group, and Ms. Chenran Qiu for breaches including failure to report threshold crossings in shareholdings, disseminating false or misleading information constituting market manipulation, and SMCP's lapse in maintaining inside information confidentiality. This decision underscores AMF's rigorous enforcement of **Market Abuse Regulation (MAR)** obligations on issuers and shareholders, serving as a deterrent against opaque share transactions and premature disclosures that undermine market integrity. Compliance teams should prioritize robust monitoring of ownership changes and information controls to avoid similar sanctions, which can reach seven figures for individuals and entities.
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What Changed
This is an enforcement decision, not a regulatory change introducing new rules; it reinforces existing obligations under French financial markets law and MAR:
Shareholder reporting thresholds: Mandatory notification to AMF and issuers for crossing above or below capital/voting rights thresholds, plus six-month plans.
Prohibition on false/misleading information: Press releases denying control over entities when factual arrangements prove otherwise qualify as market manipulation.
Inside informatio
Key Dates
10 June 2025 - AMF Enforcement Committee decision issued, imposing fines.
Post-10 June 2025 - Appeal window opened; European TopSoho lodged appeal before Paris Court of Appeal.
Compliance Impact
Urgency: Medium - Matters due to substantial fines (€1.72M total, including €1M personal), personal liability for controllers, and appeal pending, signaling ongoing risk. Not critical as it's backward-looking enforcement (events 2016-2021), but elevates priority for listed firms handling ownership c
All Firms
Sanctions & settlements Executive & other private individuals Journalists The AMF Enforcement Committee fines three individuals and one legal entity a total of €700,000 for insider dealing breaches
The AMF Enforcement Committee imposed fines totaling €700,000 on three individuals and one legal entity for insider dealing violations, demonstrating the regulator's ongoing commitment to enforcing Market Abuse Regulation (MAR) prohibitions on trading with inside information. This case underscores the AMF's aggressive pursuit of insider networks and coordinated breaches, serving as a stark reminder for firms to bolster insider trading surveillance and training programs. Compliance teams should use it to reinforce policies amid rising detections of organized insider activities.
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What Changed
This is an enforcement action, not a regulatory change; it reaffirms existing MAR requirements under Articles 7 (inside information definition), 8 (insider lists), 14 (insider dealing prohibition), 17 (public disclosure), and 19 (PDMR trading restrictions, including 30-day black-out periods before financial results). No new rules are introduced, but it highlights AMF's reliance on firms for detection via internal policies, whistleblowing, and gift/invitation controls, as echoed in recent AMF-AFA
What You Need To Do
- Update insider policies
- Enhance training and awareness
- Strengthen surveillance
- Report promptly
- Conduct audits
Key Dates
December 4, 2024 - EU Regulation 2024/2809 enters force , amending MAR on inside information and disclosures.
June 5, 2026 - Certain amendments to insider trading policies (e.g., Groupe Casino policy) apply ; others immediate from February 2025.
June 30, 2026 - AMF General Regulation updates effective , covering certifications for financial instruments and prospectuses.
Within 3 trading days - PDMRs must report securities transactions to issuer and AMF.
Compliance Impact
Urgency: High – This enforcement signals intensified AMF focus on insider networks, with fines demonstrating willingness to penalize both individuals (€700,000 total) and entities amid a "worrying trend" of organized crime infiltration. Firms face elevated inspection risks, especially post-AMF-AFA v
Broker DealerAll Firms
Sanctions & settlements Journalists Listed companies and issuers The AMF Enforcement Committee clears three individuals and one legal entity for insider dealing breaches
The AMF Enforcement Committee dismissed insider dealing charges against three individuals and one legal entity, determining insufficient evidence of inside information use or disclosure. This decision underscores the Committee's rigorous evidentiary standards in market abuse cases, offering reassurance to compliance teams that weak indicia alone do not trigger sanctions, while reinforcing the need for robust defenses in investigations. It matters because it provides interpretive guidance on proving insider dealing, potentially reducing overreach in enforcement but heightening focus on documentation and transaction rationales.
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What Changed
No new regulatory changes or requirements are introduced; this is an enforcement decision, not a rulemaking. It clarifies application of existing Market Abuse Regulation (MAR) rules under AMF jurisdiction, emphasizing that sanctions require concrete proof beyond timing, atypical trades, or plausible disclosure channels—such as unconvincing explanations alone are insufficient for liability. The ruling aligns with prior cases where the Committee has cleared parties when evidence falls short, as se
What You Need To Do
- Enhance insider list maintenance and training to preempt failures, as fined in parallel cases
- Document transaction rationales proactively (e
- Conduct regular MAR compliance audits, focusing on disclosure channels and trade timing surveillance
- Review internal policies against AMF Enforcement Committee precedents, ensuring defenses emphasize alternative explanations for trades
Compliance Impact
Urgency: Medium—not critical as no new rules or fines imposed, but matters for firms under AMF scrutiny or with high insider dealing risk, as it illustrates acquittal thresholds (e.g., insufficient indicators like timing alone). Heightened relevance amid ongoing AMF enforcement wave on market abuse,
Broker DealerAll Firms
Sanctions & settlements Journalists The AMF Enforcement Committee fines three individuals a total of €590,000 for price manipulation
The AMF Enforcement Committee fined three individuals a total of €590,000 for engaging in price manipulation on French markets, highlighting the regulator's aggressive stance against market abuse. This enforcement action underscores the risks of coordinated trading schemes that distort supply, demand, or prices, serving as a deterrent for market participants. Compliance teams should note it as evidence of heightened AMF scrutiny on manipulative behaviors, even absent full case details.
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What Changed
This is an enforcement decision, not a regulatory change; it reaffirms existing prohibitions under the French Monetary and Financial Code (Article L. 433-1-2) and EU Market Abuse Regulation (MAR, Regulation (EU) No 596/2014) against price manipulation, including fixing prices at artificial levels, disseminating false/misleading signals on supply/demand, or using deceptive orders. No new requirements are introduced, but it signals AMF's interpretation of manipulation in coordinated individual act
Key Dates
11 December 2024 AMF decision fining entities €4.15M for false info and price manipulation.
24 January 2024 AMF decision fining seven for price manipulation (€400k-€2M); appeals filed, partial stay granted 10 July 2024.
19 July 2024 AMF fines Parrot and directors €420k total for manipulation.
13 December 2024 AMF fines US fund €10M for IPO-related manipulation.
15 September 2025 AMF fines asset managers €1.3M total (future-dated relative to publication patterns).
Compliance Impact
Urgency: High - Matters due to escalating fines (e.g., €590k here, up to €10M in ) and personal liability for individuals, amid AMF's pattern of 2024-2025 actions targeting manipulation across assets. Non-compliance risks reputational damage, trading bans, and appeals (e.g., ongoing in ); firms must
Broker DealerAsset ManagerAll Firms
Sanctions & settlements professional obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines Pharnext and its former directors a total of €800,000
The AMF Enforcement Committee fined Pharnext €500,000 and its former directors Daniel Cohen (€200,000) and David Horn Solomon (€100,000) on 20 January 2025 for failing to disclose inside information promptly and disseminating false or misleading information about FDA interactions for a drug candidate. This enforcement action reinforces AMF's strict stance on market abuse rules under EU MAR, highlighting personal liability for directors in listed biotech firms where investor expectations around product approvals are high. Compliance teams should note it as a reminder of timely disclosure obligations, especially amid appeals filed by the parties.
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What Changed
This is not a regulatory change but an enforcement decision applying existing obligations under the Market Abuse Regulation (MAR), specifically:
Article 17 MAR: Requirement to disclose inside information as soon as possible (breached by Pharnext's delays from 10 April 2019 and non-disclosure from 28 October 2020).
Article 12(1)(c) MAR: Prohibition on disseminating false or misleading information that could affect market prices, via press releases and shareholder letters overstating FDA progress.
What You Need To Do
- Review inside information policies
- Audit communications
- Director training
- Monitor appeals
- wide actions mandated beyond general MAR compliance, but proactive gap analysis recommended
Key Dates
10 April 2019 - FDA request for additional study deemed inside information; not disclosed until 30 August 2019.
28 October 2020 - FDA 'non-agreement' on clinical study design deemed inside information; never publicly disclosed.
20 January 2025 - AMF Enforcement Committee decision imposing fines (SAN-2025-01).
23 July 2025 - Paris Court of Appeal dismissed David Horn Solomon's stay of execution application (n°25/05331).
Post-20 January 2025 - Appeal lodged by Pharnext, Cohen, and Solomon to Paris Court of Appeal (ongoing).
Compliance Impact
Urgency: Medium – This is a specific enforcement (not a new rule), but it signals heightened AMF scrutiny on biotech disclosures amid investor sensitivity to approval news; delays in similar cases could trigger investigations/fines up to 15% of turnover or €15M. Matters for listed firms with pipelin
All Firms
Sanctions & settlements MAR Other professionals Executive & other private individuals Listed companies and issuers The AMF Enforcement Committee fines a US investment fund and its director a total of €10 million for price manipulation during an initial public offering...
The AMF Enforcement Committee fined US-based investment fund EcoR1 Capital €7 million and its director Oleg Nodelman €3 million (total €10 million) on 13 December 2024 for price manipulation via "marking the close" trades on Euronext Paris during Innate Pharma's 2019 Nasdaq IPO, plus reporting failures on 5% ownership thresholds. This case demonstrates AMF's extraterritorial reach over foreign actors impacting French markets and underscores personal liability for executives in market abuse violations under MAR.
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What Changed
This is an enforcement decision, not a regulatory change; it reinforces existing MAR prohibitions on price manipulation (Article 12), specifically "fixing the price at an abnormal or artificial level" through timed sales at market close to influence linked ADS pricing on Nasdaq. It also highlights ongoing scrutiny of reporting obligations under Article L. 233-7 of the French Commercial Code for crossing 5% thresholds in listed companies.
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What You Need To Do
- Implement pre-trade surveillance for "marking the close" patterns, especially around issuer events like IPOs where Euronext closes influence external pricing
- Enhance 5% threshold monitoring with automated alerts and timely filings (4 trading days post-threshold)
- Conduct senior manager training on personal liability under MAR for manipulative orders benefiting the firm (e
- Review cross-border trading policies for French-listed assets, including jurisdiction assessments for non-EU funds
- Perform gap analysis on order timing controls to flag end-of-day volume spikes
Key Dates
October 10-16, 2019 - Five trading sessions during which manipulative "marking the close" sales occurred on Euronext Paris.
2019 (exact dates unspecified) - Instances of failing to report exceeding/falling below 5% ownership thresholds in Innate Pharma.
13 December 2024 - AMF Enforcement Committee decision date imposing fines.
16 December 2024 - French version of press release published.
Compliance Impact
Urgency: Medium - Matters due to AMF's aggressive fines (€10M total) and personal accountability for a US fund/director, signaling heightened cross-border enforcement on Euronext trades. Firms should prioritize surveillance upgrades now, as appeals are possible but do not suspend implications; low i
Hedge FundAsset Manager
Sanctions & settlements Disclosure Obligations Journalists Listed companies and issuers The AMF Enforcement Committee imposes fines totalling €4,150,000 on four legal entities and three natural persons for disseminating false or misleading information, and price manipulation
The AMF Enforcement Committee imposed fines totaling €4,150,000 on December 11, 2024, against Auplata (an issuer), its former CEO Didier Tamagno, statutory auditors RSM Paris and Stéphane Marie (€50,000-€300,000 range), and fund entities European High Growth Opportunities Manco SA, Alpha Blue Ocean Inc., and director Pierre Vannineuse (€1,000,000-€1,500,000 range) for disseminating false or misleading information in press releases and financial statements, plus share price manipulation via unauthorized sales. This decision underscores the AMF's rigorous enforcement of market abuse rules under French financial regulations, serving as a critical reminder for issuers, auditors, and investment managers to ensure transparent disclosure of financing terms and compliance with share disposal commitments, with appeals already lodged at the Paris Court of Appeal.
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What Changed
This is an enforcement action, not a regulatory change; it reinforces existing obligations under AMF rules prohibiting false/misleading information (e.g., omitting key clauses in financing agreements like ODIRNANEs with BSAs, failing to disclose earn-outs or include them in going concern analyses) and price manipulation (e.g., breaching share retention and daily sales volume limits). No new requirements were introduced, but the decision clarifies interpretive application: auditors face liability
What You Need To Do
- Review disclosure practices
- Enhance auditor coordination
- Strengthen trading controls
- Training and policies
- Monitor appeals
Key Dates
11 December 2024 - AMF Enforcement Committee decision issued, imposing fines.
Post-11 December 2024 - Appeals lodged by European High Growth Opportunities Manco SA, Alpha Blue Ocean Inc., Auplata Mining Group AMG, RSM Paris SAS, Stéphane Marie, and Pierre Vannineuse before the Paris Court of Appeal (exact filing date not specified).
Compliance Impact
Urgency: High - Matters due to substantial fines (up to €1.5M per entity), personal liability for executives/auditors, and broad applicability to disclosure/manipulation risks in equity financings; recent timing (2024 decision, ongoing appeals) signals AMF's active enforcement focus, prompting immed
Asset ManagerAll Firms
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines a financial investment advisor, two asset management companies and their directors, and a credit institution a total of €5,670,000
The AMF Enforcement Committee imposed total fines of €5,670,000 on a financial investment advisor (FIA), two asset management companies (AMCs), their directors, and a credit institution for breaches of professional obligations. This enforcement action underscores the AMF's rigorous scrutiny of operational controls, due diligence, and governance in investment services, serving as a critical reminder for firms to maintain robust procedures to avoid similar sanctions. It matters because it highlights personal liability for directors and escalating fines for systemic failures, potentially influencing peer reviews and audit priorities.
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What Changed
This is an enforcement decision, not a regulatory change introducing new rules. It reinforces existing AMF requirements under professional obligations, including:
Implementation of operational procedures for investment/divestment processes, such as verifying lender authorizations.
Systematic anti-money laundering (AML) and counter-terrorism financing (CTF) due diligence on fund assets and liabilities.
Justification of retrocessions (rebates) to distributors, proving enhanced client service quali
What You Need To Do
- Conduct gap analysis of operational procedures for investments/divestments, ensuring lender authorization checks (reference AMF Position-Recommendation DOC-2020-05 on portfolio management)
- Review AML/CTF due diligence frameworks for fund assets/liabilities, aligning with AMF Regulation 2016-01
- Audit retrocession practices to distributors, documenting service quality enhancements (per AMF doctrine on inducements)
- Update marketing materials and advisory processes for compliance with honesty/fairness standards
- Enhance senior manager attestations and training on personal liability under CMF L
Key Dates
2026 ) - AMF Enforcement Committee decision fining €5,670,000 total.
15 September 2025 Altaroc Partners decision (appeal lodged to Conseil d’État).
9 July 2025 MND insider dealing decision (appeal to Paris Court of Appeal).
10 December 2025 Novaxia Investissement decision.
5 November 2025 Carat GP FIA decision.
Compliance Impact
Urgency: High – This signals intensified AMF enforcement on professional obligations in 2025 (multiple similar fines: €1.3M, €1.89M, €0.5M, €2.5M implied, €0.305M, €3.5M), with personal bans and multimillion fines. Matters due to director accountability trends, potential for follow-on audits, and ed
Asset ManagerWealth ManagerBank
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines Sogenial Immobilier and its chairman a total of €180,000
The AMF Enforcement Committee issued a €180,000 combined fine against Sogenial Immobilier (€150,000) and its chairman Jean-Marie Souclier (€30,000) on September 12, 2024, for systematic breaches of professional obligations spanning investment selection, regulatory disclosure, conflict of interest management, and anti-money laundering compliance. This enforcement action demonstrates the AMF's heightened scrutiny of asset managers' operational controls and substantive compliance with fund governance requirements, particularly regarding real estate investment companies (SCPIs).
What Changed
The decision does not introduce new regulatory requirements but rather clarifies enforcement expectations across existing obligations:
Regulatory Documentation Standards: Asset managers must implement documented procedures governing the preparation of all regulatory and marketing materials for alternative investment funds, with particular attention to accurate risk disclosure and asset return reporting.
Investment Due Diligence Standards: A "high standard of diligence" is required when selecti
What You Need To Do
- *Audit Existing Procedures
- *Formalize Investment Selection Process
- *Enhance Conflict of Interest Controls
- *Implement Comprehensive AML/CFT
- *Strengthen Internal Control Functions
Key Dates
September 12, 2024 - AMF Enforcement Committee issued the decision
September 16, 2024 - Public announcement of sanctions
No specified deadline - Appeal period remains open (appeals may be lodged against the decision)
Compliance Impact
Urgency: HIGH
Asset Manager
Sanctions & settlements Disclosure Obligations Journalists AMF Enforcement Committee fines Biosynex, its CEO and several of its directors a total of €930,000
The AMF Enforcement Committee fined Biosynex and four directors (plus their holding companies) a total of €930,000 on 25 July 2024 for breaches including selective disclosure of inside information via a CEO interview, insider trading by selling shares on non-public knowledge of a treasury share sale, and failures to report share transactions to the AMF. This matters as it reinforces AMF's strict enforcement of MAR (Market Abuse Regulation) rules on information dissemination, insider dealing, and PDMR reporting, serving as a precedent for listed companies and executives during high-volatility periods like COVID-19. Appeals by some parties were dismissed as inadmissible by the Paris Court of Appeal on 9 January 2025.
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What Changed
This is an enforcement decision, not a regulatory change; it applies existing requirements under EU MAR (Regulation (EU) No 596/2014, transposed in France) and AMF rules:
Selective disclosure: Issuers must ensure "full and effective" public dissemination of inside information via press releases before any selective sharing (e.g., interviews); partial disclosure to a "restricted audience" (like journalists) without prior release violates this.
Insider trading: Prohibits trading (including selling
What You Need To Do
- Implement pre-approval for executive media interactions: Require scripts/press releases issued simultaneously with interviews to avoid selective disclosure
- Enhance insider lists and trading controls
- Automate transaction reporting
- Conduct MAR training refreshers
- Audit past disclosures
Key Dates
25 July 2024 - AMF Enforcement Committee decision issuing fines.
March-April 2020 - Violation period (interview on 20 March 2020; share sales and unreported transactions).
9 January 2025 - Paris Court of Appeal dismisses appeals by CEO Abensur, CFO Fraenckel, and ALA Financière as inadmissible (case n° 24/16188).
Compliance Impact
Urgency: Medium - Not a new rule but a high-profile enforcement (€930k total: Biosynex €50k; CEO/holding €460k; others €70k-€230k each) highlighting personal liability for executives, with appeals failing. Matters for listed firms as it stresses "full/effective" dissemination and rejects operational
All Firms
Sanctions & settlements Disclosure Obligations Professional investors The AMF Enforcement Committee fines an issuer and two of its former directors at the time of the facts for market manipulation by disseminating false or misleading information. It also fined one of the directors for insider...
The AMF Enforcement Committee imposed fines on an issuer and two former directors for market manipulation via dissemination of false or misleading information, with an additional fine on one director for insider trading violations. This enforcement action underscores the AMF's rigorous enforcement of market abuse rules under the Market Abuse Regulation (MAR), serving as a stark reminder of personal and corporate liability for disclosure failures and privileged information misuse. Compliance teams must prioritize robust controls to mitigate similar risks, as such violations erode market integrity and investor trust.
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What Changed
This is an enforcement decision rather than new legislation, so there are no direct regulatory changes. It reinforces existing obligations under Book VI of the AMF General Regulation on market abuse, including insider dealing and market manipulation, aligned with Regulation (EU) No 596/2014 (MAR). Key principles upheld include prohibitions on disseminating false/misleading information that impacts security prices and trading on inside information, with no novel requirements but heightened emphas
What You Need To Do
- Implement or strengthen disclosure controls to ensure all public information is accurate and non-misleading, with pre-approval for promotional materials submitted to AMF
- Enhance insider lists and training for directors on MAR prohibitions, including trading blackouts before announcements
- Deploy surveillance systems to detect market manipulation signals, with compliance officers mandated to report suspicious transactions to AMF
- Conduct due diligence attestations for prospectuses/public offers, confirming no material omissions
- Review governance for personal liability, including cooperation incentives in investigations per proposed AMF powers
Key Dates
30 June 2026 - End of MiCA transitional period; AMF to fully enforce crypto-asset market abuse under MAR-equivalent rules.
30 June 2026 - AMF General Regulation updates effective, enhancing MAR reporting procedures (e.g., Articles 145-1 to 145-4).
Compliance Impact
Urgency: High - This demonstrates AMF's aggressive stance on market abuse amid rising "insider networks" and organized crime threats, with fines signaling personal risk for directors. It matters because enforcement is intensifying (e.g., web scraping for investigations, expanded sanctions like 10-ye
All Firms
Sanctions & settlements professional obligations Journalists Investment management companies AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness and personal accountability in asset management, serving as a regulatory warning for firms to strengthen internal controls or face escalating sanctions.
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What Changed
This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and fully operational; failure to verify compliance (e.g., loan authorizations) breaches honesty, fairness, and diligence standards.
Scope of services: Asset managers acting as tied agents cannot provide unauthorized services like placing financial instrumen
What You Need To Do
- Conduct gap analysis
- Enhance AML/CFT
- Strengthen governance
- Audit marketing/distribution
- Senior manager certification
Key Dates
31 December 2025 - AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors.
August 2019 - December 2023 - Period of identified breaches (investment services, processes, AML/CFT deficiencies).
08 January 2026 - Public press release publication date.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision, alongside similar fines (e.g., €1.3M on Altaroc Partners in Sep 2025, €400k on Eternam in Sep 2025), signals AMF's intensified scrutiny on asset manager operations post-AIFMD reviews, with personal fines rising (up to €500k+). Non-compliance risks enf
Asset Manager
Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breaches of their professional obligations
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.
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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
Asset ManagerWealth ManagerBroker Dealer
Sanctions & settlements Journalists AMF Enforcement Committee fines one individual and clears two others for insider dealing breaches
The AMF Enforcement Committee sanctioned one individual with a fine for insider dealing violations while acquitting two others in a case involving breaches of market abuse rules under the Market Abuse Regulation (MAR). This decision underscores the AMF's rigorous enforcement of insider trading prohibitions, emphasizing evidence-based liability determinations and serving as a reminder for firms to strengthen insider monitoring and training programs. It matters because it highlights the risks of coordinated insider networks and the importance of robust compliance frameworks to mitigate personal and corporate exposure.
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What Changed
This is an enforcement decision, not a regulatory amendment, so there are no new rules or requirements introduced. It reaffirms existing obligations under MAR Articles 7 (prohibition of insider dealing), 8 (unlawful disclosure of inside information), 10 (public disclosure of inside information), 14 (abuse of inside information), 17 (fair presentation and disclosure), and 19 (PDMR transactions), as well as AMF General Regulations Articles 223-9 and 221-3. Key takeaways include strict trading rest
What You Need To Do
- Review and update insider trading policies to align with AMF Position-Recommendation No
- Implement or strengthen training on MAR prohibitions, insider network risks, and whistleblowing mechanisms, especially for those handling M&A, results announcements, or advisor roles
- Monitor and log gifts, donations, transactions in derivatives/index products, and PDMR dealings; notify insiders of blackouts via Insider Trading Committee
- Enhance surveillance for coordinated trading patterns pre-announcements (e
- For listed firms
Key Dates
Within 3 trading days PDMRs must report securities transactions to issuer and AMF. DEADLINE
30 calendar days prior to annual/interim results publication Statutory blackout period for PDMRs.
15 calendar days prior to quarterly financial info publication Recommended blackout for insiders per AMF guidance.
5 June 2026 Certain amendments in sample insider policies apply (e.g., enhanced disclosures).
Compliance Impact
Urgency: Medium. This reinforces longstanding MAR rules without new mandates, but the acquittal of two individuals signals AMF's focus on provable evidence, reducing overreach risks while heightening scrutiny on networks. It matters amid rising organized crime threats (AMF 2024 report), prompting im
Asset ManagerBankAll Firms
Appointment Sanctions & settlements Journalists Valérie Michel-Amsellem becomes Chair of the AMF Enforcement Committee
This AMF publication announces the appointment of Valérie Michel-Amsellem as the new Chair of the AMF Enforcement Committee, the independent body responsible for imposing sanctions in financial market violations. It matters for compliance professionals because leadership changes in enforcement can signal shifts in sanctioning priorities, rigor, or focus areas, potentially influencing how firms approach risk management and remediation. While no immediate policy changes are introduced, monitoring the new Chair's tenure is essential given the Committee's role in upholding market integrity.
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What Changed
There are no substantive regulatory changes, new requirements, or amendments to the AMF General Regulation outlined in this announcement. The publication solely details an internal governance appointment within the AMF's structure, where the Enforcement Committee maintains its established autonomy for sanction decisions, separate from the AMF Board. This aligns with prior affirmations of the Committee's independence, as upheld in ECHR rulings on its impartiality.
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What You Need To Do
- Review backgrounds of key AMF personnel, including Valérie Michel-Amsellem, for insights into enforcement trends (e
- Enhance internal monitoring of AMF sanction releases (https://www
- Conduct gap analyses on compliance programs for high-risk areas like market abuse, given the Committee's sanction powers up to €100 million or 10x profits
Key Dates
Immediate - Appointment takes effect upon announcement, with no disclosed transition period.
2026 , Enforcement Committee sanction against an asset management company, indicating ongoing enforcement operations.
Compliance Impact
Urgency: Low - This personnel change does not impose new obligations or alter existing rules, posing minimal immediate risk. It matters indirectly for long-term strategy, as the Chair could steer enforcement toward stricter penalties or novel interpretations of obligations (e.g., as analyzed in hist
Asset ManagerBroker DealerBank Appointment Sanctions & settlements Journalists Appointements to the AMF Enforcement Committee
This AMF publication announces the partial renewal of the Enforcement Committee, including four new appointments, two reappointments, and the subsequent election of Valérie Michel-Amsellem as Chair on 28 February 2024. It matters for compliance professionals as changes in committee composition can influence enforcement priorities, sanction severity, and interpretations of financial regulations under AMF jurisdiction.
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What Changed
There are no new regulatory requirements or substantive changes to laws; this is an administrative renewal of the Enforcement Committee's membership. Key developments include: new members Jean-Claude Hassan (Vice-President of the Council of State appointee, also chairs second section), Xavier Samuel (Court of Cassation appointee), Sophie Langlois and Aurélien Soustre (Ministerial appointees); reappointments of Anne Le Lorier and Ute Meyenberg. The committee maintains its structure of 12 independ
Key Dates
13 February 2024 - Ministerial order appointing new and reappointed members.
20 February 2024 - Publication of the ministerial order.
27 February 2024 - Composition published in the Official Journal.
28 February 2024 - First meeting; election of Valérie Michel-Amsellem as Chair and Jean-Claude Hassan as second section Chair.
Compliance Impact
Urgency: low - This personnel change poses minimal immediate risk but signals potential evolution in enforcement tone under new leadership experienced in sanctions and regulation (e.g., Michel-Amsellem's appellate background). It matters longer-term for firms in protracted AMF proceedings, as commit
Asset ManagerBroker DealerBank Sanctions & settlements Journalists The AMF Enforcement Committee clears twelve individuals for insider dealing breaches
All Firms
Sanctions & settlements Disclosure Obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines seven people, four for price manipulation and three for failing to comply with reporting obligations
Broker DealerWealth Manager
Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations
The AMF Enforcement Committee imposed sanctions on SPI (a financial investment advisor) and its director Vincent Rhodes on 9 January 2024 for breaching professional obligations. This case demonstrates the AMF's enforcement priorities regarding advisor conduct standards and establishes precedent for disciplinary action against both firms and individual managers who fail to meet regulatory requirements.
What Changed
The decision does not introduce new regulatory requirements but rather clarifies enforcement of existing professional obligations for financial investment advisors. The case reinforces that advisors must:
Comply with all applicable laws and regulations governing financial investment advisory activities
Maintain professional standards in their dealings with clients and regulators
Ensure their directors and managers operate within regulatory boundaries
The enforcement action reflects the AMF's i
What You Need To Do
- *For Financial Investment Advisors
- *Review compliance frameworks - Audit existing policies and procedures against the professional obligations that triggered this enforcement action
- *Enhance governance controls - Implement systems to ensure directors and senior management comply with regulatory requirements
- *Document compliance - Maintain records demonstrating adherence to professional conduct standards
- *Staff training - Ensure all personnel understand the scope of professional obligations and consequences of breach
Key Dates
9 January 2024 - AMF Enforcement Committee decision imposing sanctions on SPI and Vincent Rhodes
Immediate effect - 2-year temporary ban on both respondents from exercising financial investment advisor activities commenced following the decision
Compliance Impact
Urgency: HIGH
Wealth ManagerBroker DealerAsset Manager
Markets MAR Corporate action Shares Market manipulation identified and reported by the AMF sanctioned by the Paris Tribunal Correctionnel
All Firms
Sanctions & settlements Disclosure Obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines a former manager of a listed company for failing to disclose inside information as soon as possible and for failing to disclose major shareholdings
The AMF Enforcement Committee imposed a fine on a former manager of a listed company for two violations: failing to disclose inside information to the public as soon as possible under Article 17 of the EU Market Abuse Regulation (MAR), and failing to disclose major shareholdings as required by French regulations. This enforcement action underscores the AMF's strict enforcement of market abuse rules, emphasizing personal accountability for executives in ensuring timely transparency to prevent insider trading risks and maintain market integrity. Compliance teams should review it as a reminder of heightened scrutiny on disclosure delays and threshold crossings.
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What Changed
This is not a regulatory change but an enforcement decision reinforcing existing obligations under MAR and AMF General Regulation:
Inside information disclosure: Issuers must publicly disclose inside information "as soon as possible" per Article 17 MAR, unless specific delay conditions are met (legitimate interest, confidentiality ensured, no public misleading). Delays require post-publication notification to AMF at differepublication@amf-france.org.
Major shareholdings disclosure: Persons cross
What You Need To Do
- Assess information promptly
- Declare major shareholdings immediately upon threshold crossing to issuer/AMF; ensure custodians comply with identity disclosure requests
- Use professional information providers for dissemination to ensure wide, secure EU reach; archive on company website
- Train executives on insider lists, transaction reporting (within 3 days if >€20k/year), and penalties (up to €100m fines, criminal sanctions)
Key Dates
3 trading days - Managers/PDMRs must report securities transactions to issuer and AMF if annual total exceeds €20,000. DEADLINE
10 business days - Custodians must respond to Euroclear France/AMF requests for shareholder identity on threshold crossings. DEADLINE
effective 2016 ) and AMF GR.
Compliance Impact
Urgency: High - This matters due to personal fines on managers, signaling AMF's aggressive enforcement of MAR since 2016, with rebuttable presumptions against executives for insider misconduct unless proven otherwise. Firms face reputational risk, investigations, and cascading liabilities (e.g., €10
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Sanctions & settlements professional obligations Investment advice Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations
The AMF Enforcement Committee imposed a five-year ban on financial investment advisor DCT (formerly Didier Maurin Finance) and its director Didier Maurin from practicing, plus fines of €150,000 on the firm and €200,000 on the director, for recommending unauthorized Samoan AIF investments to 64 clients, failing to manage conflicts of interest (e.g., no conflicts register), and breaching duties of competence, care, and diligence in clients' best interests. This matters as it reinforces AMF's strict enforcement on CIFs (Conseillers en Investissements Financiers) for product authorization checks, conflicts management, and client-centric obligations under MiFID II transposition in France, signaling heightened scrutiny on advisory integrity amid rising sanctions. The Conseil d'Etat upheld the decision on 9 September 2024, dismissing appeals and confirming sanctions.
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What Changed
This is an enforcement decision, not a new regulation, but it clarifies and reinforces existing requirements for CIFs:
Product marketing authorization: CIFs must verify that recommended investments (e.g., AIFs) are authorized for sale in France before advising clients; recommending unauthorized products breaches professional obligations regardless of client outcomes.
Conflicts of interest management: CIFs must maintain an effective conflicts register, identify risks (e.g., personal benefits), an
What You Need To Do
- Immediate audit
- Conflicts policy enhancement
- Training and documentation
- Director accountability
Key Dates
11 April 2022 - AMF Enforcement Committee decision imposing bans and fines.
9 September 2024 - Conseil d'Etat judgment (no. 464877) dismissing appeals, upholding sanctions, and ordering €1,500 costs each to AMF.
Compliance Impact
Urgency: High - This upheld decision (post-2024 appeal) exemplifies AMF's pattern of escalating fines/bans on CIFs for conduct failures (e.g., €2.5M on Carat GP in 2025; €120K-€150K on Capexis upheld 2025), amid 2024-2025 enforcement wave on professional obligations. Matters for CIFs as it heightens
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Sanctions & settlements Journalists Listed companies and issuers The AMF Enforcement Committee fines Visiomed and its former directors, Éric Sebban and Olivier Hua, for market manipulation. It also fines Negma Group Ltd for breach of its reporting obligations
The AMF Enforcement Committee imposed fines on Visiomed and its former directors Éric Sebban and Olivier Hua for market manipulation, and on Negma Group Ltd for failing to meet reporting obligations. This enforcement action underscores the AMF's rigorous enforcement of market abuse rules under EU Regulation 596/2014 (MAR), serving as a critical reminder for listed companies, directors, and major shareholders to prioritize compliance with manipulation prohibitions and threshold crossing disclosures. It matters because it demonstrates personal liability for executives and ongoing scrutiny of disclosure failures, potentially influencing enforcement trends in 2026 amid strengthened AMF powers.
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What Changed
This is an enforcement decision rather than new regulatory changes, reinforcing existing requirements under MAR (Regulation (EU) No 596/2014), transposed into AMF's General Regulation (Book VI on market abuse). It highlights prohibitions on market manipulation (e.g., disseminating false or misleading information or engaging in fictitious transactions to influence prices) and mandatory reporting of shareholdings crossing 5% thresholds or changes therein for listed issuers. No novel rules are intr
What You Need To Do
- Conduct internal audits
- Enhance monitoring systems
- Train personnel
- Update policies
- Cooperate with regulators
Key Dates
Immediate - Report suspicious transactions (insider dealing or manipulation) to AMF without delay.
30 June 2026 - End of MiCA transitional period, with AMF focusing on crypto-asset market abuse alignment (indirect relevance via MAR enforcement).
30 June 2026 - AMF General Regulation updates effective, enhancing MAR-related reporting procedures (e.g., Title V on failings reporting).
Compliance Impact
Urgency: High - This action signals intensified personal accountability for executives in market manipulation cases, amid AMF's 2026 focus on market integrity and new tools like expanded data access and injunctions with penalty payments. Firms must act swiftly to fortify controls, as non-compliance
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Sanctions & settlements Journalists The AMF Enforcement Committee fines a French tied agent of a Cypriot investment services provider and its manager for breaches of their professional obligations
The AMF Enforcement Committee fined France Safe Media (FSM), a French tied agent of Cypriot provider VPR Safe Financial Group Limited (Alvexo platform), €300,000 and imposed a 10-year ban from tied agent activities and reception/transmission of orders (RTO) services, while its manager Lior Mattouk received a €100,000 fine and similar 10-year ban, for breaches occurring January 2019–September 2021. This decision, dated 10 November 2023 and upheld by Conseil d'Etat on 16 June 2025, underscores AMF's strict enforcement of professional obligations for tied agents marketing high-risk CFDs, emphasizing staff qualifications, client assessments, risk warnings, disclosures, and diligence. It matters for cross-border intermediaries as it highlights personal liability for managers and the finality of sanctions post-appeal, signaling heightened scrutiny on CFD promotion and tied agent compliance in France.
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What Changed
This is an enforcement action, not a new regulation, but it clarifies and reinforces existing requirements under French rules implementing MiFID II for tied agents:
Staff qualifications: Tied agents must verify sales staff have minimum qualifications and knowledge; post-hoc inadequate tests do not suffice.
Client knowledge/experience assessment: Questionnaires must be robust, with appropriate scoring; account managers cannot interfere (e.g., by prompting answer changes).
Promotional communicatio
What You Need To Do
- Conduct gap analysis
- Enhance manager oversight
- Audit CFD marketing
- Training programs
- Cross-border review
Key Dates
10 November 2023 - AMF Enforcement Committee decision SAN-2023-15 imposing fines and bans.
14 November 2023 - French version of press release published.
16 June 2025 - Conseil d'Etat judgment (n° 490826) dismissing appeals by FSM and Mattouk, confirming sanctions and ordering €4,000 costs to AMF.
Compliance Impact
Urgency: High – Though dated (2019–2021 breaches), the 2025 appeal dismissal makes sanctions final, serving as a binding precedent for tied agents amid AMF's ongoing CFD enforcement wave (e.g., parallel fines on providers like CIC banks). It elevates personal risk for managers and signals intensifie
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Sanctions & settlements Journalists The AMF Enforcement Committee fines two individuals for insider dealing breaches
The AMF Enforcement Committee fined two individuals for insider dealing breaches, highlighting the regulator's focus on prohibiting the use of non-public, price-sensitive information in securities transactions. This enforcement action underscores the AMF's rigorous application of market abuse rules under the Market Abuse Regulation (MAR), serving as a deterrent and educational tool for market participants. Compliance teams should note it as evidence of ongoing scrutiny, with fines reflecting the severity of breaches involving direct trading on inside information.
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What Changed
This is an enforcement decision, not a regulatory change; it reaffirms existing requirements under EU MAR (Regulation (EU) No 596/2014), transposed into French law via the French Monetary and Financial Code. Key principles upheld include: (i) prohibition on using inside information for trading (Article 14 MAR), (ii) assessing breaches via indicators like transaction timing, atypical volume, order placement methods, and implausible justifications, and (iii) liability for both primary insiders and
What You Need To Do
- Enhance surveillance
- Insider list management
- Training programs
- Policies and procedures
- Audit and testing
Key Dates
since 2016 ). Relevant historical dates from this and similar cases:
30 January 2023 Enforcement decision fining 10 parties for Terreïs acquisition insider dealing.
9 July 2021 Decision fining individuals for disclosing/using earnings inside information.
15 May 2024 Fine for using takeover bid information.
9 July 2025 Fines including professional bans for MND-related breaches.
Compliance Impact
Urgency: High – While not a rule change, the AMF's frequent enforcement (multiple 2023-2026 cases with fines up to €1M) signals intensified focus on insider dealing amid M&A and earnings seasons, risking reputational damage, personal liability, and business bans. Firms must prioritize surveillance u
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Sanctions & settlements Journalists Listed companies and issuers The AMF Enforcement Committee fines Rallye and its chief executive officer, Franck Hattab, for market manipulation
The AMF Enforcement Committee sanctioned listed company Rallye and its former CEO Franck Hattab for market manipulation via dissemination of false or misleading information about Rallye's liquidity position on 11 occasions across 14 communications from March 2018 to May 2019, in violation of Articles 12.1(c), 12.4, and 15 of the EU Market Abuse Regulation (MAR). Rallye was fined €25 million and Hattab €1 million due to the repetition of breaches, prior AMF warnings, and potential investor harm from artificially inflated share prices. This case matters as it demonstrates AMF's aggressive enforcement of MAR disclosure rules, holding both issuers and senior executives personally liable for financial communications that misrepresent key risks like liquidity.
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What Changed
This is an enforcement decision, not a regulatory change; it reinforces existing MAR requirements prohibiting dissemination of false or misleading information likely to artificially affect financial instrument prices. Key interpretations include: (i) describing liquidity as "solid" or "very solid" despite dependency on volatile subsidiary (Casino) shares and hidden risks (e.g., €400-600M liquidity shortfall, concealed loans) constitutes manipulation; (ii) issuers are strictly responsible for com
What You Need To Do
- Review historical/current financial communications for liquidity/debt portrayals; ensure they explicitly address dependencies (e
- Enhance governance
- Audit trails
- Monitor appeals
Key Dates
March 8, 2018 - May 15, 2019 - Period of infringing communications (11 occasions, 14 media).
2016 - Prior AMF Deputy Secretary General warning to Rallye on financial communication quality, specifically liquidity risk presentation.
September 2023 (inferred from context) - AMF Enforcement Committee decision imposing fines.
September 18-19, 2023 - Rallye appeals the AMF decision.
Compliance Impact
Urgency: High - Reinforces personal accountability for executives in debt-heavy listed firms, with fines scaled to repetition and centrality of misrepresented risks (liquidity as Rallye's primary exposure). Matters amid ongoing Casino restructuring (€6.4B debt), signaling AMF scrutiny of retail sect
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Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness in asset managers, particularly those acting as tied agents, and holds senior managers personally accountable. It matters for compliance as it exemplifies enforcement trends targeting systemic deficiencies, with potential appeals signaling ongoing scrutiny.
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What Changed
This is an enforcement action, not a regulatory change, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and compliant; failure to verify or document renders systems non-operational.
Scope of services: Asset managers (and tied agents) cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing licensed activ
What You Need To Do
- Immediate gap analysis
- Enhance AML/CFT
- Conflicts framework
- Senior manager attestation
- Marketing/retrocessions
Key Dates
31 December 2025 - AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors.
August 2019 - December 2023 - Period of breaches investigated, covering investment services, processes, conflicts, and AML/CFT failures.
08 January 2026 - Public press release date.
Compliance Impact
Urgency: High - This reflects a pattern of 2025 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc Partners 15 Sep 2025; €400k on Eternam 9 Sep 2025), signaling intensified scrutiny post-AIFMD reviews. Matters due to personal liability for managers, appeal risks amplify
Asset Manager
Sanctions & settlements professional obligations Journalists The AMF Enforcement Committee fines the Association Nationale des Conseillers Financiers-CIF for breaches of its professional obligations
The AMF Enforcement Committee fined the Association Nationale des Conseillers Financiers-CIF (ANACOFI-CIF), a professional association approved for investment advisors (CIFs), €250,000 with a warning, and its former president €20,000 with a warning, for breaching professional obligations in membership vetting, controls, archiving, and conflicts of interest management. This decision, dated September 5, 2023, underscores AMF's scrutiny of professional associations' gatekeeping and oversight roles in ensuring CIF compliance. It matters as it signals heightened enforcement against associations failing to uphold regulatory standards, potentially impacting CIF ecosystem integrity and prompting reviews of similar bodies.
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What Changed
This is an enforcement action, not a new regulation, but it reinforces existing obligations under French Monetary and Financial Code (CMF) for approved professional associations like ANACOFI-CIF. Key breaches highlighted include:
Failure to verify quality of CIF membership application dossiers and non-compliance with internal adhesion procedures.
Non-respect of procedures for member controls, sanctions, and proper archiving of control dossiers.
Violation of internal rules on conflicts of interes
What You Need To Do
- Review and strengthen internal procedures for CIF membership vetting, ensuring dossier quality checks align with approved protocols
- Implement robust systems for member controls, sanctions processes, and secure archiving of all dossiers per CMF L
- Update conflicts of interest policies and registers to fully comply with internal rules and CMF obligations, documenting all identifications
- Conduct gap analyses on governance, documentation, and AML/KYC for CIF activities, training staff on operationalizing procedures
- For CIF members
Key Dates
September 5, 2023 - AMF Sanctions Commission decision issued, imposing fines and warnings on ANACOFI-CIF (€250,000) and M. Patrick Galtier (€20,000).
Post-September 5, 2023 - Decision subject to potential recourse (appeal period not specified in public summaries, typically 1 month under AMF procedures).
June 2, 2023 - AMF Sanctions Commission hearing where €500,000 sanction was initially sought (reduced in final decision).
Compliance Impact
Urgency: Medium - This 2023 decision is not imminent but remains highly relevant given ongoing AMF focus on CIF compliance (e.g., 2025 sanctions for similar breaches like archiving and AML failures). It matters for preventing fines, bans, or reputational damage, as AMF targets systemic weaknesses in
Wealth ManagerAll Firms
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations
The AMF Enforcement Committee fined asset management company Altaroc Partners (formerly Amboise Partners SA) €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 the AMF's strict enforcement on operational controls, governance, and client protection in asset management, serving as a critical warning for firms to ensure robust, documented procedures and senior manager accountability. It matters because it highlights personal liability for executives and reinforces AMF's educational role through sanction explanations, potentially increasing scrutiny on similar firms.
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What Changed
This is an enforcement action, not a regulatory change; it reaffirms and clarifies existing obligations under French financial regulations for asset managers (sociétés de gestion de portefeuille). Key requirements emphasized include:
Implementing operational procedures for investment/divestment processes, including verification of lender authorizations.
Conducting systematic AML/CFT due diligence on fund assets and liabilities.
Proving that fee retrocessions to distributors enhance client servic
What You Need To Do
- Review and document operational procedures for fund investments/divestments, including lender authorization checks
- Enhance AML/CFT systems with systematic due diligence on fund assets/liabilities and risk mapping
- Audit fee retrocession arrangements to demonstrate tangible client service improvements (e
- Validate marketing materials for accuracy and completeness
- Conduct senior manager attestations on compliance oversight; implement training on personal liability
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.
Post-15 September 2025 - Appeal lodged by Altaroc Partners, Tchenio, and de Giovanni before the Conseil d’État against decision SAN-2025-09 (exact date not specified).
Compliance Impact
Urgency: High - This recent (2025) enforcement demonstrates AMF's willingness to impose multimillion-euro fines (€1.3M total) and hold executives personally accountable for systemic failures in core areas like operations, AML, and client disclosure. It matters for immediate risk as appeals are pendi
Asset Manager
MAR Anti-money Laundering Pump-and-dump practice: market manipulation sanctioned by the Paris Tribunal Correctionnel
The Paris Tribunal Correctionnel sanctioned a pump-and-dump market manipulation scheme, where perpetrators artificially inflated small-cap stock prices via social media hype before selling off, violating France's Market Abuse Regulation (MAR). This enforcement action by the AMF underscores aggressive judicial backing for anti-manipulation efforts, signaling heightened scrutiny on coordinated trading schemes, especially in illiquid assets. Compliance teams must prioritize surveillance enhancements to mitigate similar risks amid rising digital promotion tactics.
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What Changed
This is an enforcement decision rather than new legislation, reinforcing existing prohibitions under Regulation (EU) No 596/2014 (MAR) against market manipulation, including pump-and-dump tactics like false information dissemination and artificial price inflation . No novel regulatory requirements are introduced, but it exemplifies AMF's collaboration with courts for criminal sanctions, potentially increasing deterrence through public naming and fines. Related AMF General Regulation updates effe
What You Need To Do
- Enhance market abuse surveillance systems to detect coordinated trading, unusual volume spikes, and social media-driven hype in small-cap/illiquid assets
- Implement staff training on recognizing pump-and-dump indicators, such as group chats luring investors with upside promises
- Review client communications policies to block manipulative promotions; report suspicions under MAR Article L
- For crypto firms, align with "enhanced" DASP registration and MiCA AML/CFT compliance to preempt manipulation sanctions
- Conduct internal audits of trading patterns and escalate to AMF if risks identified
Key Dates
30 December 2024 - MiCA mandatory licensing for CASPs; pre-registered PSANs enter 18-month transition .
30 June 2026 - End of PSAN transitional period; full MiCA authorization required, with AMF oversight on manipulation risks . DEADLINE
Compliance Impact
Urgency: High - This case demonstrates swift judicial enforcement (Tribunal Correctionnel conviction), amplifying personal liability for individuals in manipulation schemes and pressuring firms to bolster pre-trade/post-trade surveillance. It matters amid MiCA deadlines, as unlicensed crypto operato
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Sanctions & settlements Journalists Investment services providers By two decisions, the AMF Enforcement Committee fines two investment services providers for breaches of their professional obligations
The AMF Enforcement Committee issued two decisions on 19 June 2023 fining Crédit Industriel et Commercial (€1 million) and Banque CIC Sud-Ouest (€250,000) for breaches of professional obligations in investment advisory services, including inadequate suitability assessments, client classification procedures, marketing of unsuitable instruments, and insufficient controls on costs and fees. This matters because it underscores AMF's strict enforcement of MiFID II-derived obligations, signaling heightened scrutiny on operational systems for client protection and potential for substantial fines based on breach duration and scale.
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What Changed
This is an enforcement action rather than new legislation, but it reinforces existing regulatory requirements under French Monetary and Financial Code and MiFID II transposition:
Obligation to implement an effective operational system for assessing investment suitability in advisory services.
Requirement for compliant client classification procedures aligned with regulations.
Duty to market only financial instruments suited to client profiles.
Mandate for effective control systems over investmen
What You Need To Do
- Conduct immediate gap analysis of investment advisory processes against AMF expectations for suitability assessments, client classification, product matching, and control systems
- Enhance traceability and documentation of suitability checks, client categorizations, and cost disclosures to demonstrate operational effectiveness
- Review and strengthen internal procedures for marketing instruments, ensuring alignment with client profiles and regulatory marketing authorizations (cross-reference to similar past cases)
- Implement or audit remedial measures, as considered in fine calculations, including staff training on professional obligations
- Test controls for providing clear cost information to clients, avoiding misleading disclosures
Key Dates
19 June 2023 - AMF Enforcement Committee decisions issued, imposing fines and warnings.
Compliance Impact
Urgency: High – Demonstrates AMF's willingness to impose multimillion-euro fines for systemic operational failures in core client protection areas, with penalties scaled by breach duration, number, and seriousness; firms with advisory services face elevated risk of audits or enforcement if controls
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Sanctions & settlements Asset management Journalists Investment management companies The AMF Enforcement Committee sanctions an asset management company and two of its managers for breaches of their professional obligations
The AMF Enforcement Committee sanctioned asset management company M Capital Partners and its managers Rudy Secco (€70,000 fine) and Stéphanie Minissier (€35,000 fine) with a total firm fine of €200,000 in its decision dated 31 December 2025, for multiple breaches of professional obligations spanning August 2019 to December 2023. This case underscores AMF's strict enforcement on operational compliance, scope of authorized activities, and AML/CFT systems in asset management, serving as a critical reminder for firms to ensure robust, traceable processes and manager accountability. It matters because it highlights personal liability for senior managers and recurring AMF focus on tied agents exceeding permitted services, potentially signaling increased scrutiny in 2026.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces and clarifies existing requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) and AMF rules for asset managers:
Asset management companies (AMCs) acting as tied agents cannot provide placement of financial instruments without a firm commitment basis, as this exceeds the restrictive list of permitted investment services.
Investment allocation processes must be precise, operational, and traceable, w
What You Need To Do
- Review and enhance tied agent activities to ensure no unauthorized investment services like non-firm commitment placements; map against permitted services list
- Audit investment allocation systems for precision, operationality, and traceability; implement verifiable verifications
- Strengthen AML/CFT frameworks
- Update conflicts of interest policies with clear identification, prevention, and management procedures
- Conduct senior manager attestations on personal oversight; perform gap analysis against this and similar cases (e
Key Dates
31 December 2025 - AMF Enforcement Committee decision date; fines imposed on M Capital Partners (€200,000), Rudy Secco (€70,000), and Stéphanie Minissier (€35,000).
August 2019 - December 2023 - Period of breaches investigated.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision directly implicates senior accountability and operational failures in core AMC functions, with fines totaling €305,000 showing AMF's willingness to penalize both firms and individuals. It matters amid a pattern of similar sanctions (e.g., €200k on Eres
Asset Manager
Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000, and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025, for multiple breaches spanning August 2019 to December 2023, including unauthorized placement of financial instruments as a tied agent, non-operational investment allocation processes, inadequate compliance with investment procedures, deficient conflicts of interest management, and non-operational AML/CFT systems. This decision underscores AMF's strict enforcement of operational compliance and scope limitations for asset managers, serving as a critical reminder for firms to ensure robust, traceable systems and director accountability. It matters because it highlights personal liability for managers and recurring AMF focus on AML/CFT and procedural deficiencies, potentially signaling increased scrutiny in 2026.
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What Changed
This is an enforcement action, not a regulatory change introducing new rules. It reinforces existing obligations under French financial regulations (e.g., Monetary and Financial Code) for asset management companies (AMCs), particularly:
Strict limits on services: AMCs cannot provide placement of financial instruments without a firm commitment basis, even as tied agents; doing so circumvents authorized investment services.
Operational investment systems: Processes for allocating investments betwe
What You Need To Do
- Audit dual roles
- Enhance investment processes
- Strengthen controls
- Director oversight
- Documentation
Key Dates
31 December 2025 - AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier.
August 2019 - December 2023 - Period of breaches investigated.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision aligns with a pattern of AMF fines on AMCs for AML/CFT, procedural, and operational failures (e.g., €200k on Eres Gestion in 2023 for rebates/investments; warnings/fines on Inter Gestion REIM in 2024 for AML). It matters due to director liability, esca
Asset Manager
Sanctions & settlements Asset management Compliance Anti-money Laundering Executive & other private individuals Investment management companies The AMF Enforcement Committee fines a portfolio asset management company and its manager for breaches of their...
The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000 and its managers Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for multiple breaches of professional obligations from August 2019 to December 2023, including unauthorized investment services as a tied agent, non-operational investment allocation processes, deficient conflict-of-interest management, and inadequate AML/CFT systems. This decision underscores AMF's strict enforcement against operational failures in asset management, particularly for firms balancing portfolio management with tied agent roles, emphasizing personal accountability for managers. Compliance teams must review this for gaps in procedures, as it highlights how imprecise processes and poor traceability lead to substantial sanctions.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) for asset managers:
Asset management companies (sociétés de gestion) are restricted to specific investment services; providing placement of financial instruments without firm commitment (as a tied agent) circumvents these limits and is prohibited.
Investment systems must be operational with precise allocation rules between funds;
What You Need To Do
- Audit investment services scope to ensure no unauthorized placement activities, especially if acting as tied agents; cease and remediate any circumventions
- Enhance investment allocation processes with precise rules, full traceability of verifications, and demonstrable operationality
- Strengthen conflict-of-interest frameworks with identification, prevention, and management protocols, including documentation
- Overhaul AML/CFT systems for effective due diligence on clients, assets, and risks; conduct staff training and test operationality
- Review manager accountability
Key Dates
31 December 2025 - AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier.
August 2019 - December 2023 - Period of breaches investigated, covering unauthorized services, investment process failures, conflicts, and AML/CFT deficiencies.
31 December 2025 (exact deadline unspecified; standard AMF appeals must be lodged promptly, typically within 1 month). DEADLINE
Asset Manager
Sanctions & settlements Journalists The AMF Enforcement Committee fines the head of consolidation of a listed company for insider dealing
The AMF Enforcement Committee fined the head of consolidation at a listed company for insider dealing, highlighting the regulator's aggressive enforcement against misuse of privileged information by senior finance personnel. This case underscores the personal liability of executives with routine access to inside information and reinforces the need for robust internal controls in listed entities. Compliance teams should prioritize this as a reminder of heightened scrutiny on insider networks and trading restrictions.
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What Changed
This is an enforcement decision, not a regulatory change, but it aligns with ongoing Market Abuse Regulation (MAR) requirements under EU rules transposed in France, including Article 17 prohibitions on insider dealing. No new requirements are introduced; it exemplifies application of existing rules like black-out periods (30 days before annual/interim results, 15 days for quarterly) and trading bans for insiders, as recommended by AMF Position-Recommendation No 2016-08. Recent EU Regulation 2024
What You Need To Do
- Enhance insider lists and training
- Implement/enforce black-out periods
- Strengthen policies on gifts/invitations and whistleblowing: Formalize in codes of ethics; monitor for corruption risks in information sharing
- Monitor and report transactions
- Conduct risk assessments
Key Dates
December 4, 2024 - EU Regulation 2024/2809 enters into force , amending MAR on inside information and disclosures.
June 5, 2026 - Certain amendments to insider trading policies apply (e.g., in Groupe Casino policy).
June 30, 2026 - AMF General Regulation updates take effect , covering prospectuses and admissions.
Within 3 trading days - PDMRs must report transactions to issuer and AMF.
Compliance Impact
Urgency: High – This demonstrates AMF's focus on executive accountability in insider dealing, amid rising "insider networks" concerns noted in 2024/2025 reports, with joint AMF/AFA warnings amplifying detection risks. Firms face fines, reputational damage, and procedural enhancements under strengthe
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Sanctions & settlements professional obligations Investment advice Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor for breaches of its professional obligations
The AMF Enforcement Committee fined financial investment advisor Capexis €120,000 on 15 February 2023 for breaches including receiving prohibited payments from client loan repayments and failing to disclose commissions from SCPI usufruct subscriptions, with the Conseil d'Etat later increasing the fine to €150,000 on 3 March 2025. This enforcement action underscores AMF's strict oversight of **financial investment advisors (Conseillers en Investissements Financiers - CIFs)** on professional obligations like payment restrictions and transparency. It matters for compliance as it highlights personal liability risks and the educational role of such decisions in clarifying regulations.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces existing requirements under French financial regulations for CIFs:
Prohibition on non-remunerative payments: CIFs cannot receive payments beyond fees for advisory services, such as loan repayments from clients.
Commission disclosure: CIFs must inform clients of the nature, amount, or calculation method of any commissions received in connection with investment advice, e.g., from SCPI usufruct arrangements.
No aggravating fac
What You Need To Do
- Review payment structures
- Enhance disclosure policies
- Conduct gap analysis
- Training and monitoring
- Prepare for inspections
Key Dates
15 February 2023 - AMF Enforcement Committee decision imposing €120,000 fine on Capexis.
3 March 2025 - Conseil d'Etat judgment increasing fine to €150,000, overturning some findings, and ordering publication on AMF website.
Compliance Impact
Urgency: High - This matters due to escalating fines (e.g., €120k to €150k on appeal), permanent/temporary bans in parallel cases, and director liability up to €2m. Recent 2024-2025 enforcements signal AMF's intensified focus on CIF misconduct amid fund scandals, risking reputational damage and oper
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Sanctions & settlements Journalists The AMF Enforcement Committee fines three legal entities and eight individuals for insider dealing breaches and failure to maintain and update insider lists
The AMF Enforcement Committee imposed fines totaling over €3 million on three legal entities and eight individuals in its 30 January 2023 decision for insider dealing in Terreïs shares based on two pieces of inside information, and for Terreïs's failure to maintain and update its insider list. This case matters because it exemplifies AMF's rigorous enforcement of market abuse rules under the Market Abuse Regulation (MAR), highlighting indicators like atypical trading timing, order placement methods, and information transmission channels that trigger sanctions, serving as a deterrent and educational tool for compliance programs.
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What Changed
This enforcement decision does not introduce new regulatory changes or requirements; it applies existing obligations under French market abuse rules aligned with EU MAR (Regulation (EU) No 596/2014). Key reaffirmed requirements include: prohibiting the use, disclosure, or recommendation of inside information for trading; maintaining and regularly updating insider lists with details of persons having access to inside information; and ensuring issuers like Terreïs promptly detect and prevent breac
What You Need To Do
- Review and strengthen insider list management
- Enhance market abuse surveillance
- Conduct insider trading risk assessments
- Update compliance training and policies
Key Dates
30 January 2023 - AMF Enforcement Committee decision date, imposing fines for insider dealing and insider list failures.
Compliance Impact
Urgency: Medium - This 2023 decision reinforces longstanding MAR rules without new mandates, but its detailed analysis of enforcement indicators demands immediate policy reviews to mitigate fines up to €1M+ per breach. It matters for firms handling listed securities, as AMF prioritizes educational e
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Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines the British company H2O AM LLP and two of its executives at the time of the facts for several breaches of their professional obligations
The AMF Enforcement Committee fined UK asset manager H2O AM LLP €75 million and its executives Bruno Crastes (€15 million, plus a 5-year ban) and Vincent Chailley (€3 million) for breaches in managing French UCITS funds, including ineligible Tennor Group investments, liquidity risks, valuation failures, and non-compliance with investment ratios and counterparty limits. This matters as it underscores AMF's strict enforcement on UCITS eligibility, risk management, and prospectus adherence, with cross-border implications confirmed by the Conseil d'État's dismissal of appeals on 13 June 2025. It signals heightened scrutiny on illiquid, unrated assets and "buy & sell back" transactions for EU asset managers.
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What Changed
This is an enforcement decision, not new rules, but it reinforces existing UCITS requirements under French Monetary and Financial Code and AMF regulations:
UCITS investments must exclude illiquid, unrated securities outside prospectus scopes; liquidity risks must be properly assessed to ensure redemption capabilities.
Debt holdings per issuer capped at 10%; counterparty exposure (e.g., 5% limit) must include all relevant transactions like buy & sell backs.
Reliable valuation information required
What You Need To Do
- Review portfolios
- Enhance due diligence
- Strengthen governance
- Depositary checks
- Training/remediation
Key Dates
30 December 2022 - AMF Enforcement Committee decision SAN-2023-01 imposing fines and sanctions.
7 August 2023 - Conseil d'État rejects preliminary constitutionality question.
13 June 2025 - Conseil d'État dismisses appeals (n. 471548, 471744), upholding sanctions and ordering €3,000 costs to AMF.
June 2025 .
Compliance Impact
Urgency: High - Finalized enforcement (June 2025) with massive fines (€93M total) and bans demonstrates AMF's willingness to pursue personal/executive liability for UCITS breaches, especially cross-border. Matters for firms with illiquid strategies, as it amplifies post-2020 liquidity crisis lessons
Asset ManagerAll Firms
Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
The AMF Enforcement Committee imposed a €150,000 fine on **Inocap Gestion**, a portfolio asset management company, for multiple operational and compliance failures between 2022 and the enforcement decision date. This case demonstrates the AMF's enforcement priorities around liquidity risk management, market abuse detection systems, and anti-money laundering (AML/CFT) procedures—critical control areas that asset managers must operationalize effectively to avoid substantial penalties.
What Changed
The decision does not introduce new regulatory requirements but rather clarifies enforcement expectations for existing obligations:
Liquidity Risk Management: Asset managers must establish procedures that are both adequate in design and operational in practice, not merely documented
Market Abuse Detection Systems: Surveillance systems must specify conditions for participation in market surveys and establish clear consequences for non-compliance
AML/CFT Procedures: Risk mapping and client onboar
What You Need To Do
- assessments across these areas
- *Liquidity Risk Management
- *Market Abuse Detection
- *AML/CFT Compliance
- *Compliance Monitoring
Key Dates
21 December 2022 - Enforcement Committee decision date against Inocap Gestion
No specific implementation deadline stated - The decision addresses historical breaches; however, firms should immediately remediate similar deficiencies
Compliance Impact
Urgency: HIGH
Asset ManagerWealth Manager
Sanctions & settlements Investment advice Other professionals Journalists Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee sanctioned financial investment advisor DCT (formerly Didier Maurin Finance) and its manager Didier Maurin with a five-year ban from practicing and fines of €150,000 and €200,000 respectively for recommending unauthorized Samoan AIF shares to 64 clients and failing to identify/manage conflicts of interest, including lacking a conflicts register. This decision, upheld by the Conseil d'Etat on 9 September 2024, underscores AMF's strict enforcement of client-best-interest and conflicts obligations under French regulations. It matters as it provides binding guidance on due diligence for product marketing authorization and conflicts procedures, signaling heightened scrutiny on financial investment advisors (FIAs).
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What Changed
This is an enforcement action, not a regulatory change, but it clarifies and reinforces existing obligations for FIAs under AMF rules:
FIAs must verify marketing authorization of recommended products in France before advising clients; recommending unauthorized AIFs breaches competence, care, diligence, and client-best-interest duties.
FIAs require effective, operational procedures for identifying and managing conflicts of interest, including maintaining a conflicts register; failure to do so is
What You Need To Do
- Immediate review
- Conflicts enhancement
- Policy updates
- Documentation
- assess against AMF Position-Recommendation DOC-2021-05 on FIA obligations (https://www
Key Dates
11 April 2022 - AMF Enforcement Committee issues decision SAN-2022-04, imposing bans and fines.
9 September 2024 - Conseil d'Etat judgment (no. 464877) dismisses appeal, upholds sanctions, and orders €1,500 costs each to AMF.
Compliance Impact
Urgency: Medium - Not critical as no new rules or deadlines, but medium due to upheld precedent reinforcing FIA duties amid AMF's pattern of FIA sanctions (e.g., bans/fines in 2022-2025 cases). Matters for FIAs lacking controls, as breaches lead to personal liability, business bans, and fines scalin
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Markets Periodic & ongoing disclosures The AMF has requested the suspension of ORPEA's financial instruments
On October 24, 2022, France's Autorité des marchés financiers (AMF) suspended all financial instruments (shares, debt securities, and related instruments) issued by ORPEA S.A., a major European care homes operator, pending disclosure of material information under the European Market Abuse Regulation. This enforcement action reflects serious governance and disclosure failures at a publicly listed company facing allegations of operational malpractice and undisclosed financial difficulties.
What Changed
The AMF's suspension order represents a temporary halt to all trading in ORPEA's financial instruments across regulated markets. This is a precautionary measure under Market Abuse Regulation (MAR) protocols designed to protect market integrity when material non-public information exists. The suspension was lifted on October 26, 2022, upon market opening, following ORPEA's disclosure of an amicable conciliation procedure and anticipated asset impairments.
The underlying trigger was ORPEA's failu
What You Need To Do
- *For ORPEA (and comparable listed companies)
- *Immediate disclosure obligations
- *Ongoing periodic updates
- *Governance remediation
- *Creditor communication
Key Dates
October 24, 2022 - AMF requests suspension of ORPEA's financial instruments before market opening
October 26, 2022 - Trading resumes upon market opening following ORPEA's disclosure of conciliation procedure and financial restructuring plan
November 8, 2022 - Q3 2022 revenue announcement (after market close)
November 15, 2022 - ORPEA to present detailed transformation plan to market
December 31, 2022 - Anticipated asset impairment recognition date
Compliance Impact
Urgency: CRITICAL
All Firms
Investment services Savings protection Europe & international Retail investors Investment services providers The AMF informs the public of the partial suspension by the CySEC of VPR Safe Financial Group Limited’s authorisation to operate in France
The AMF publication notifies the public of CySEC's August 3, 2022, decision to partially suspend VPR Safe Financial Group Limited's (operating as Alvexo) authorization to provide investment services in France, prompted by AMF findings of regulatory violations including misleading marketing, inadequate client suitability assessments, and poor tied agent oversight. This cross-border enforcement highlights escalating EU supervisory cooperation under MiFID II, serving as a warning for firms using tied agents in France. It matters for compliance as it underscores risks of AMF referrals leading to home-state suspensions, with subsequent developments including suspension revocation and full license withdrawal by September 2025.
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What Changed
This is an enforcement action rather than new rules, imposing specific prohibitions on VPR Safe Financial Group Limited in France:
Ban on accepting new French clients or entering business relationships with them.
Prohibition on advertising or marketing investment services to current or potential French clients, directly or via tied agent France Safe Media.
Restriction on receiving new deposits from existing French clients, except to cover initial margins for open positions upon explicit client r
What You Need To Do
- For VPR/Alvexo (during suspension)
- Ongoing for similar firms
- Client protection
Key Dates
August 3, 2022 - CySEC issues partial suspension decision based on AMF findings, effective immediately for French operations.
~October 4, 2022 - Two-month deadline for VPR to remediate compliance issues (from suspension date). DEADLINE
Post-August 22, 2022 (exact date unspecified) - CySEC revokes partial suspension after demonstrated compliance. DEADLINE
September 29, 2025 - CySEC fully withdraws VPR's CIF authorization pursuant to the firm's renunciation.
October 13, 2025 - CySEC publicly announces license withdrawal.
Compliance Impact
Urgency: Low (as of January 2026). The 2022 suspension is historical, resolved via revocation and superseded by full license withdrawal in 2025, posing no ongoing restrictions. It matters as a precedent for AMF-CySEC coordination on retail misconduct (e.g., CFD marketing, tied agents), urging firms
Broker DealerFintech
Sanctions & settlements Compliance Journalists Investment services providers The AMF Enforcement Committee fines a depositary for breaches of its professional obligations
The AMF Enforcement Committee fined RBC Investor Services Bank France SA (RBC ISBF) €500,000 plus a warning on 20 July 2022 (published 08 January 2026) for breaches as a UCITS and AIF depositary, including 25 confirmed failures in tiered intervention procedures for investment ratio overruns and deficient monitoring of 14 questionable cash flows over 45 months. This decision underscores AMF's strict enforcement of depositary duties under French regulations implementing UCITS/AIFMD, emphasizing robust controls for ratio compliance, cash flow verification, and documentation. It matters for compliance teams as it provides precedent on what constitutes "irregular and deficient" oversight, potentially increasing scrutiny and fines for similar lapses in depositary functions.
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What Changed
This is an enforcement decision, not a new regulation, but it clarifies and reinforces existing depositary obligations under French UCITS/AIFMD rules (e.g., Articles L. 214-7 et seq. Monetary and Financial Code):
Ratio monitoring and intervention: Depositaries must implement tiered procedures for investment/asset composition ratio breaches (e.g., diversification limits); 25 of 28 alleged anomalies were upheld due to redundant but confirmed procedural failures.
Cash flow oversight: Must identify
What You Need To Do
- Review depositary controls
- Enhance cash flow monitoring
- Conduct gap analysis
- Update policies/procedures
- Appeal if applicable
Key Dates
20 July 2022 - AMF Enforcement Committee decision date imposing €500,000 fine and warning on RBC ISBF.
08 January 2026 - Public news release/publication date of the decision.
Compliance Impact
Urgency: Medium – Recent publication (08 January 2026) signals ongoing AMF focus on depositary failings amid H2O-related probes, but stems from 2022 events with no immediate deadlines. Matters because it sets precedents for fine quantum (€500k) on procedural lapses, reinforces liability for cash/rat
Asset ManagerBankWealth Manager
Sanctions & settlements Journalists The AMF Enforcement Committee fines one natural person and five legal entities, including a management company, for failing to comply with several reporting obligations in relation to a concerted action carried out in the context of a takeover bid and, in the case of the...
The AMF Enforcement Committee imposed fines on one natural person and five legal entities, including an investment management company, for failing to comply with multiple reporting obligations related to a concerted action during a partial takeover bid.[User Query]. This enforcement action underscores the AMF's strict enforcement of transparency rules in takeover scenarios, serving as a critical reminder for market participants to adhere to disclosure timelines to avoid significant financial penalties and reputational damage.
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What Changed
This is not a regulatory change or new requirement but an enforcement decision highlighting existing obligations under French financial markets law, particularly those governing concerted actions (actions concertées) and reporting in takeover bids. Key requirements reinforced include:
Timely disclosure of positions and intentions when parties act in concert, as per AMF regulations on major holdings and takeover bids (e.g., Article L. 233-10 of the French Commercial Code and AMF General Regulatio
What You Need To Do
- Review and enhance internal procedures for monitoring share positions, identifying concerted actions, and automating AMF filings
- Train front-office and compliance teams on takeover bid disclosures, including documentation of coordination (e
- Implement pre-trade alerts for threshold breaches and conduct periodic audits of historical filings
- For management companies
Key Dates
Within 4 trading days - Declaration of crossing major holding thresholds or intent to continue acquisitions (AMF Form DOC-2005-01).
Immediate (same day) - Notification of concerted action agreements in takeover contexts.
Within 10 trading days - Detailed position reports post-crossing.
in 2025 (e.g., 16 July 2025 for inside information breaches).
Compliance Impact
Urgency: High - This matters due to the AMF Enforcement Committee's pattern of fining reporting failures (e.g., €1.89M in July 2025 for late disclosures, €1.7M in June 2025 for shareholder breaches), signaling intensified scrutiny on M&A transparency amid volatile markets. Non-compliance risks fines
Asset ManagerAll Firms
Sanctions & settlements Journalists The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
The AMF Enforcement Committee fined an unnamed portfolio asset management company €400,000 for multiple breaches of professional obligations, including non-operational investment/divestment procedures, inadequate conflict of interest management with group service providers, lack of transparency on distributor fee retrocessions, deficient client categorization, and weak AML/CFT due diligence. This enforcement action, mirroring recent similar cases against firms like Novaxia Investissement and Eternam, underscores the AMF's heightened scrutiny on operational robustness and transparency in asset management, serving as a critical reminder for firms to ensure procedures are fully implemented and documented to avoid personal liability for executives.
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What Changed
This is an enforcement decision rather than new legislation, but it reinforces and clarifies existing regulatory requirements under AMF professional obligations for portfolio asset managers (sociétés de gestion de portefeuille). Key emphases include:
Investment/divestment processes must be fully operational, with traceability of compliance checks against fund policies and formalized due diligence before allocations.
Effective conflicts of interest policies are mandatory when using group service
What You Need To Do
- Audit internal procedures
- Enhance conflict and transparency controls
- Strengthen AML/CFT and client categorization
- Senior manager accountability
- Mock AMF inspections
Key Dates
9 September 2025 - AMF Enforcement Committee decision fining Eternam €400,000 (similar case on marketing, club deals, conflicts, valuation, AML/CFT).
10 December 2025 - AMF Enforcement Committee decision fining Novaxia Investissement €400,000 and director €100,000 (investment processes, group providers, distributor fees, client categorization, AML/CFT).
31 December 2025 - AMF Enforcement Committee decision fining M Capital Partners €200,000 and directors €70,000/€35,000 (investment systems, conflicts, AML/CFT).
Compliance Impact
Urgency: High - Recent cluster of identical fines (€200k-€500k total per case) in late 2025 signals AMF's enforcement priority on operational deficiencies in asset management, with personal sanctions escalating risks for leadership. Firms with similar setups (group providers, AIFs/club deals) face i
Asset Manager
Institutional AMF activity Appointment Journalists Appointments to the Legal Affairs Directorate and Enforcement Assistance Directorate of the Autorité des Marchés Financiers
This AMF publication announces internal appointments to its **Legal Affairs Directorate** and **Enforcement Assistance Directorate**, signaling potential enhancements in legal oversight and enforcement capabilities within France's financial markets regulator. Compliance professionals should note this as it may indicate a renewed focus on rigorous enforcement of market rules, though it imposes no direct regulatory changes on firms.
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What Changed
There are no regulatory changes, new requirements, or policy updates in this announcement. It solely details personnel appointments within AMF's internal structure, specifically leadership roles in directorates handling legal affairs (e.g., Maxence Delorme as head of Legal Affairs Directorate) and enforcement assistance (e.g., Amélie du Passage as head of Instruction and Enforcement Assistance Directorate). These directorates support AMF's core functions like investigations, inspections, and san
What You Need To Do
- *No specific actions are required for regulated firms, as this does not introduce obligations
- Review ongoing AMF interactions (e
- Update internal AMF contact lists with confirmed governance details from https://www
- Track AMF news releases for enforcement trends at https://www
Key Dates
13 February 2024 - Ministerial order partially renewing AMF Enforcement Committee.
20 February 2024 - Publication of Enforcement Committee appointments.
27 February 2024 - Composition published in Official Journal.
16 October 2023 - Appointment of Sébastien Raspiller as AMF Secretary General.
Compliance Impact
Urgency: Low. This matters peripherally for firms anticipating AMF enforcement, as new leaders in Legal Affairs and Enforcement Assistance could signal stricter scrutiny or faster processing of cases, similar to past leadership transitions (e.g., Secretary General appointment in 2023). However, abse
Asset ManagerBroker DealerBank Sanctions & settlements Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee fined financial investment advisor Séquence 13 and its director Jean-Louis Lehmann €15,000 each and imposed a five-year ban from acting as financial investment advisors in its decision of 19 December 2023, due to failures in client disclosures, justifying remuneration, operating within regulatory limits, and managing conflicts of interest. This enforcement action underscores the AMF's strict enforcement of professional obligations for investment advisors, with personal liability for managers, serving as a deterrent against conduct breaches that harm client interests. Compliance teams should note this as part of a pattern of similar sanctions, emphasizing robust governance and documentation.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces core professional obligations under AMF rules for financial investment advisors (Conseillers en Investissements Financiers, CIFs), including:
Client information on remuneration: Advisors must disclose any remuneration received for advice and justify service improvements relative to that pay.
Regulatory scope compliance: Firms must operate strictly within authorized activities, avoiding unauthorized product recommendations.
What You Need To Do
- Review and enhance policies
- Training programs
- Client file audits
- Governance checks
- Mock inspections
Key Dates
19 December 2023 - AMF Enforcement Committee decision issued, imposing fines and five-year bans on Séquence 13 and Jean-Louis Lehmann.
Compliance Impact
Urgency: High - This decision highlights escalating AMF scrutiny on CIFs, with fines, bans, and personal accountability in multiple recent cases (2022-2025), signaling increased inspection risk and potential for director bans. It matters because failures in basic conduct rules lead to severe, long-t
Wealth ManagerAll Firms
Sanctions & settlements Journalists The AMF Enforcement Committee fines a Dutch trading firm and three Dutch traders for price manipulation
The AMF Enforcement Committee fined a Dutch trading firm and three Dutch traders for price manipulation on French markets, demonstrating the regulator's cross-border enforcement reach against market abuse. This case underscores AMF's aggressive stance on manipulative trading practices, serving as a deterrent for international firms and individuals active in EU-linked markets. Compliance teams should note it as evidence of heightened scrutiny on trading desks handling correlated instruments.
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What Changed
This is an enforcement action, not a regulatory change; it reinforces existing prohibitions under the Market Abuse Regulation (MAR, Regulation (EU) No 596/2014) against price manipulation, including fixing prices at abnormal or artificial levels through deceptive trades. It aligns with prior AMF decisions, such as the €20 million fine on Morgan Stanley for similar OAT/OLO manipulations via futures positioning (decision dated 4 December 2019). No new requirements are introduced, but it highlights
What You Need To Do
- Enhance surveillance
- Trader training
- Internal controls
- Compliance reviews
Key Dates
4 December 2019 ; EcoR1: 13 December 2024; SMCP: 10 June 2025).
30 June 2026 .
16 September 2025 .
Compliance Impact
Urgency: High – This signals AMF's expanding cross-jurisdictional enforcement (Dutch firm/traders), with fines on firms and individuals, amid proposed powers enhancements (e.g., penalty payments, communication on probes). Firms face personal accountability risks and market reputation damage; non-EU
Broker Dealer
Sanctions & settlements Investment advice Other professionals Executive & other private individuals Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee fined a financial investment advisor (FIA) firm and its manager for multiple breaches of professional obligations, including failure to provide mandatory documents, inadequate risk disclosure, poor KYC practices, misleading information, unauthorized placing activities, and improper third-party marketing mandates. This enforcement action underscores the AMF's strict scrutiny of FIAs, emphasizing due care, conflict management, and adherence to status limits, with fines and bans serving as deterrents. Compliance teams should review it for lessons on documentation, client suitability, and outsourcing controls to avoid similar sanctions.
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What Changed
This is an enforcement decision, not a regulatory change, but it reinforces and clarifies existing FIA obligations under French regulations (e.g., AMF General Regulation). Key requirements highlighted include:
Mandatory delivery of initial contact documents, engagement letters, and written reports to clients.
Clear specification of remuneration terms and comprehensive risk information for recommended products.
Thorough KYC to ensure suitability of advice.
Prohibition on misleading information, s
What You Need To Do
- Conduct Documentation Audit
- Enhance KYC and Suitability Processes
- Strengthen Conflicts Framework
- Review Activity Scope
- Training and Monitoring
Key Dates
24 January 2019 AMF Enforcement Committee decision fining Novactifs Patrimoine €250,000 and CEO €100,000 for breaches from March 2014–July 2016.
11 April 2022 AMF Enforcement Committee decision imposing 5-year bans and fines (€150,000 firm, €200,000 manager) on DCT/Didier Maurin Finance; appeal dismissed by Conseil d'Etat on 9 September 2024.
4 November 2024 AMF fines totaling €5,670,000 on FIA Smart Tréso Conseil, asset managers, and CACEIS Bank for fund marketing/management breaches.
5 November 2025 AMF Enforcement Committee decision fining Carat GP and directors €2.5 million total, with permanent/10-year bans (French release: 6 November 2025).
Compliance Impact
Urgency: Medium. This matters as part of a pattern of escalating AMF enforcement against FIAs (fines up to €2.5M, lifetime bans in recent cases), signaling heightened focus on investor protection and governance amid complex products. Firms should prioritize audits now to preempt inspections, but no
Wealth ManagerAsset ManagerAll Firms
Sanctions & settlements Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee imposed significant sanctions on DCT (formerly Didier Maurin Finance) and its manager Didier Maurin for recommending unauthorized alternative investment funds to clients and obstructing regulatory investigations. This case exemplifies critical compliance failures in product authorization verification and client suitability assessment, with enforcement upheld by France's highest administrative court in September 2024.
What Changed
This enforcement action clarifies several regulatory obligations for financial investment advisors:
Product Authorization Verification: Financial advisors must verify that recommended investment products are authorized for marketing in France before advising clients, regardless of the product's legitimacy in other jurisdictions.
Client Interest Prioritization: Recommending unauthorized products is inherently contrary to client interests and constitutes a breach of the duty to act with competen
What You Need To Do
- *Immediate compliance measures for financial investment advisors:
- *Product Authorization Audit
- *Pre-Recommendation Due Diligence
- *Client Suitability Documentation
- *Regulatory Cooperation Protocol
Key Dates
11 April 2022 - AMF Enforcement Committee issued original decision imposing five-year ban and fines
18 July 2022 - Conseil d'État suspended enforcement of fines pending appeal
9 September 2024 - Conseil d'État dismissed appeal, upholding all sanctions and ordering payment of €1,500 each to AMF
Compliance Impact
Urgency: HIGH
Asset ManagerWealth Manager
Sanctions & settlements Journalists The AMF Enforcement Committee fines a biotech company for failing to disclose inside information as soon as possible, and one of its co-founders and one of its shareholders for unlawful disclosure or use of inside information
The AMF Enforcement Committee sanctioned a biotech company for delaying disclosure of inside information, and fined a co-founder and shareholder for unlawfully disclosing or using it, violating EU Market Abuse Regulation (MAR) obligations under Articles 7, 10, and 17. This case underscores the AMF's strict enforcement of timely public disclosure and insider handling, highlighting risks of personal liability for executives and shareholders in listed biotech firms. Compliance teams must prioritize robust information barrier procedures and insider list management to mitigate similar penalties.
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What Changed
This enforcement action does not introduce new regulations but reinforces existing MAR requirements transposed into AMF General Regulation (e.g., Article 315-1), including:
Immediate public disclosure: Issuers must disclose inside information "as soon as possible" under MAR Article 17, unless three conditions for delay are met (legitimate interest, confidentiality ensured, no public misleading).
Prohibition on unlawful disclosure/use: Persons with inside information cannot disclose it except per
What You Need To Do
- Assess information promptly
- Implement controls
- Maintain insider lists
- Train personnel
- Archive disclosures
Key Dates
As soon as possible - Disclose inside information publicly, or immediately if confidentiality breached during delay.
Immediately after publication - Notify AMF (differepublication@amf-france.org) of any delayed inside information post-publication.
Within 3 trading days - Managers/directors report securities transactions to issuer and AMF.
Within 10 business days - Custodians respond to Euroclear France/AMF requests for shareholder identity disclosures.
Compliance Impact
Urgency: High - This demonstrates AMF's willingness to impose personal and corporate fines for disclosure failures, particularly in volatile sectors like biotech where trial data qualifies as inside information. Firms risk market disruption, reputational damage, and escalating penalties (e.g., hundr
All Firms
Sanctions & settlements Executive & other private individuals Journalists Listed companies and issuers The AMF Enforcement Committee sanctions a media company and its director for making investment recommendations without mentioning conflicts of interest and for price manipulation
The AMF Enforcement Committee sanctioned a media company and its director for issuing investment recommendations without disclosing conflicts of interest and engaging in price manipulation, highlighting the regulator's strict enforcement against market abuse and transparency failures. This case underscores the AMF's focus on protecting investors from misleading practices by non-traditional actors like media outlets, with penalties serving as a deterrent amid rising digital fraud. Compliance teams must prioritize conflict disclosures and surveillance to avoid similar actions, as it reinforces ongoing AMF priorities in conduct and market integrity.
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What Changed
This enforcement decision does not introduce new regulations but reaffirms and clarifies existing requirements under AMF rules and EU Market Abuse Regulation (MAR):
Mandatory conflict of interest disclosure: Investment recommendations must explicitly mention any conflicts, such as financial stakes or relationships influencing the advice, to ensure clear, non-misleading information.
Prohibition on price manipulation: Practices artificially influencing security prices, including through coordinate
What You Need To Do
- Conduct conflict of interest audits
- Enhance surveillance for market abuse
- Update compliance policies
- Training programs
- Inducement reviews
Compliance Impact
Urgency: High - This matters due to the AMF's escalating enforcement (e.g., record 12 sanction decisions in 2024 affecting 60 entities, €26.5M fines), targeting non-authorized actors like media amid digital fraud surges (181 sites shut down in 2024). Media and advisory firms face director-level liab
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Sanctions & settlements Journalists The AMF to call for an amendment of the law on obstructing investigations and inspections
The AMF announced its intention to propose legislative amendments to the French Monetary and Financial Code following a January 28, 2022 Constitutional Council decision that found dual prosecution for obstructing AMF investigations and inspections unconstitutional. The amendment aims to eliminate the possibility of simultaneous administrative and criminal penalties for the same obstruction conduct, while preserving the AMF's enforcement authority.
What Changed
The primary regulatory change addresses a constitutional violation regarding dual prosecution under the ne bis in idem principle:
Current problem: The Monetary and Financial Code previously allowed both administrative sanctions by the AMF Enforcement Committee and criminal prosecution for identical obstruction conduct, violating the constitutional prohibition against double jeopardy.
Proposed solution: Legislative amendments will eliminate the possibility of dual prosecution while maintaining
What You Need To Do
- *For compliance professionals and regulated entities:
- *Review cooperation policies
- *Assess ongoing proceedings
- *Monitor legislative developments
- *Counsel on cooperation
Key Dates
January 28, 2022 - Constitutional Council decision declaring dual prosecution unconstitutional
No specific implementation deadline stated - AMF committed to proposing amendments "as soon as possible"
Current status (as of January 2026) - Amendments appear to be in legislative proposal stage; no effective date yet announced
Compliance Impact
Urgency: MEDIUM
Asset ManagerBroker DealerAll Firms
Sanctions & settlements Journalists The AMF Enforcement Committee fines an issuer's Chief Financial Officer for insider dealing
The AMF Enforcement Committee fined an issuer's Chief Financial Officer (CFO) for insider dealing, highlighting the regulator's aggressive enforcement against market abuse by senior executives. This case underscores the personal liability of insiders who trade on privileged information, reinforcing the need for robust internal controls in listed companies. Compliance teams must prioritize insider trading prevention to mitigate similar sanctions risks.
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What Changed
This enforcement action does not introduce new regulatory changes but exemplifies ongoing application of existing Market Abuse Regulation (MAR) rules under EU Regulation 596/2014 and AMF General Regulations, including Articles 223-9 and 221-3 on inside information disclosure and trading bans. It aligns with AMF Position-Recommendation No 2016-08 on managing inside information, emphasizing black-out periods (e.g., 30 days before annual/interim results) and trading restrictions for Persons Dischar
What You Need To Do
- Maintain insider lists and notify affected persons of trading restrictions; train staff on MAR Article 17 (disclosure) and Article 19 (PDMR dealings)
- Strengthen monitoring of gifts, transactions in derivatives/index products, and whistleblowing mechanisms, as urged in AMF/AFA joint guidance
- Ensure PDMR transaction reporting within 3 trading days via AMF portal
- Conduct regular compliance inspections on insider networks and corruption risks, formalizing prohibitions in codes of ethics
Key Dates
3 trading days - PDMRs must report securities transactions to issuer and AMF. DEADLINE
December 4, 2024 - EU Regulation 2024/2809 amending MAR entered into force.
June 5, 2026 - Certain amendments in sample insider policies apply (e.g., Groupe Casino policy).
June 30, 2026 - AMF General Regulation updates effective.
Compliance Impact
Urgency: High - This demonstrates AMF's focus on holding executives accountable, with fines signaling zero tolerance amid rising "insider networks" linked to organized crime, as noted in AMF's 2024 report and 2025 AMF/AFA warnings. Firms face heightened inspection risks, reputational damage, and per
All Firms
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.
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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 managem
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 20
Asset Manager