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
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
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
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
Warning Identity theft The Autorité des marchés financiers (AMF) is warning professionals about the extensive fraudulent and malicious use of its name engaging people into running a malicious computer program.
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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
MAR Financial disclosures & corporate financing Shares The AMF and the AFA call for vigilance of the risk of private corruption by criminal networks of natural persons with access to inside information
BankAsset ManagerBroker Dealer
Anti-money Laundering Asset management Crypto-assets Anti-money laundering and countering the financing of terrorism: the AMF applies the guidelines of the European Banking Authority on restrictive measures for crypto-asset service providers
Crypto ExchangeBankAsset Manager
Anti-money Laundering Asset management AMF invites financial market participants to take part in the EBA consultation on draft AML/CFT implementing standards
The AMF is urging French financial market participants to engage in the EBA's consultation launched on March 6, 2025, on draft Regulatory Technical Standards (RTS) for AML/CFT implementing standards under AMLD6 and AMLR, focusing on harmonized risk assessment methodologies for supervisors and obliged entities. This matters because it signals a shift to uniform EU-wide AML/CFT supervision via AMLA (post-EBA handover on January 1, 2026), requiring firms to adapt to standardized risk indicators, data reporting, and enforcement, with new CDD rules applying from July 2027. Participation ensures firms influence final standards amid the transition to a single EU AML rulebook.
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What Changed
The draft RTS propose harmonized methodologies for AML/CFT supervision, including:
Risk Assessment of Obliged Entities (Article 40(2) AMLD6): A three-step process with indicators for inherent risk (customers, products/services, geography, distribution channels), control effectiveness (governance, policies, procedures, group supervision), and residual risk; annual reviews and ad-hoc reassessments; standardized scoring for consistent EU supervision.
Risk Assessment for Direct Supervision (Article
What You Need To Do
- Participate in EBA consultation
- Conduct compliance gap analysis
- Enhance systems
- Prepare for AMLA supervision
- Ongoing monitoring
Key Dates
March 6, 2025 - EBA consultation launch on draft RTS for AML/CFT standards (ongoing as of analysis).
January 1, 2026 - EBA hands over AML/CFT mandates, tools (e.g., EuReCa database), and functions to AMLA ; existing EBA guidelines remain until replaced.
July 10, 2027 - New AMLD6/AMLR rules apply directly , including CDD for new customers and start of phased compliance. DEADLINE
By July 2032 - Full CDD compliance for existing customers (five-year transition from 2027).
2028 - AMLA begins direct supervision of selected high-risk entities.
Compliance Impact
Urgency: High – While not yet final, the consultation shapes binding RTS under the new AMLA-led regime post-January 2026 handover, with direct rules from July 2027 requiring system upgrades and data readiness; delays risk non-compliance with harmonized supervision, higher sanctions, and AMLA scrutin
Asset ManagerBankAll Firms
Savings protection Financial Scams Crypto-assets Retail investors Journalists The authorities are taking action to combat the massive phenomenon of financial scams catching out an increasing number of individuals
BankFintechCrypto Exchange Asset management Anti-money Laundering Crypto-assets Combating money laundering and terrorist financing: the AMF applies the guidelines issued by the European Banking Authority regarding certain transfers of crypto-assets
Asset ManagerBankCrypto Exchange
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
Warning Savings protection Warning Forex and binary options Crypto-assets The AMF reminds retail investors to be extremely vigilant regarding Immediate Connect's fraudulent investment offer
Crypto ExchangeFintechAll 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
Crypto-assets Innovation The AMF publishes the summary of responses received to its Discussion Paper on Decentralised Finance
The Autorité des Marchés Financiers (AMF) has published a summary of stakeholder responses to its June 2023 Discussion Paper on Decentralised Finance (DeFi), analyzing regulatory challenges posed by automated, decentralized crypto-asset activities. This matters for compliance professionals as it signals the AMF's ongoing commitment to developing a balanced DeFi framework amid MiCA's implementation, potentially shaping future supervision of decentralized protocols while emphasizing investor protection and innovation.
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What Changed
No immediate regulatory changes or new requirements are introduced; this is a non-binding summary of consultation feedback from July 2024, intended to inform future discussions rather than enact rules. It highlights stakeholder views on DeFi's challenges, such as decentralization's impact on traditional oversight, with the AMF planning continued ecosystem engagement to outline proportionate responses. Related updates include clarifications on DASP transitions to MiCA CASP licensing (e.g., abolit
What You Need To Do
- Monitor and engage
- MiCA compliance
- Assess decentralization
- Update policies
Key Dates
June 2023 - AMF publishes initial Discussion Paper on DeFi regulatory challenges.
July 2024 - AMF publishes summary of responses to DeFi Discussion Paper.
December 30, 2024 - MiCA enters force for CASPs.
June 30, 2026 - End of MiCA transitional period for DASPs; full CASP licensing required. DEADLINE
July 2027 - EU AMLR ("single rulebook") comes into effect, standardizing crypto due diligence. DEADLINE
Compliance Impact
Urgency: Medium - This consultation summary does not impose new obligations but underscores evolving DeFi scrutiny within MiCA's firm deadlines (e.g., June 2026 transition end), making it critical for crypto firms to align now to avoid sanctions like DASP withdrawals. It matters for maintaining comp
Crypto ExchangeFintechAsset Manager
Asset management Anti-money Laundering Money laundering and terrorist financing: the AMF publishes its sectoral risk analysis
Asset ManagerWealth Manager
Asset management Anti-money Laundering Combatting money laundering and terrorist financing: AMF applies two sets of European Banking Authority guidelines
Asset ManagerBankWealth Manager
Warning Savings protection Financial Scams Warning The AMF warns the public about fraudulent press advertisements proposing investments in car parks with electric charging points
BankWealth ManagerFintech
Warning Identity theft Savings protection Warning The Autorité des marchés financiers (AMF) is warning professionals about the extensive fraudulent and malicious use of its name, with links to various websites that could trick people into running a malicious computer program
BankWealth ManagerFintech
Warning Warning Savings protection Forex and binary options Crypto-assets The AMF and the Paris Public Prosecutor's Office urge retail investors to be extremely vigilant regarding Immediate Connect's fraudulent investment offer in crypto-assets
Crypto ExchangeAll Firms
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 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
Anti-money Laundering Asset management Anti-money laundering and combating the financing of terrorism: the AMF applies the guidelines of the European Banking Authority
Asset ManagerBankWealth 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
Broker DealerCrypto ExchangeAll Firms
Crypto-assets Innovation Fintech Journalists The AMF publishes a discussion paper on Decentralised Finance (DeFi)
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, published a discussion paper on June 19, 2023, outlining preliminary thoughts on regulatory challenges posed by Decentralised Finance (DeFi) activities on crypto-assets, inviting stakeholder feedback by September 30, 2023. A summary of responses was released on July 10, 2024, highlighting key themes like defining DeFi, distinguishing protocol types, and applying a "same activity, same risk, same regulation" principle. This matters for compliance professionals as it signals AMF's intent to develop proportionate DeFi oversight, balancing innovation with investor protection, AML/CTF risks, and market integrity amid evolving EU frameworks like MiCA.
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What Changed
This is a discussion paper and consultation, not binding legislation, so no immediate regulatory changes or requirements are imposed. Key discussion points include:
Defining DeFi based on decentralization criteria (e.g., automation, network architecture, governance, lack of single points of failure).
Distinguishing permissioned vs. permissionless protocols and public vs. private blockchains.
Regulatory approaches to smart contracts (e.g., certification, varying responsibilities), open-source cod
What You Need To Do
- Submit feedback (past deadline)
- Monitor developments
- Conduct internal assessments
- Enhance compliance programs
- Engage stakeholders
Key Dates
June 19, 2023 - AMF publishes initial discussion paper on DeFi regulatory issues.
September 30, 2023 - Deadline for stakeholder contributions to the discussion paper. DEADLINE
July 10, 2024 - AMF publishes summary of responses to the discussion paper.
Compliance Impact
Urgency: Medium – This is non-binding consultation feedback without hard deadlines or rules, but it previews AMF's regulatory trajectory toward DeFi oversight, including AML/CTF enforcement and investor safeguards, amid MiCA rollout. It matters because DeFi's growth amplifies risks like pseudonymity
FintechCrypto ExchangeAll Firms
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
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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
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Crypto-assets Anti-money Laundering Supervision Journalists Investment services providers AMF and ACPR announce the withdrawal of BYKEPS SAS’s registration as a DASP
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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
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Anti-money Laundering Asset management The AMF and TRACFIN sign a new cooperation protocol
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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
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Warning Savings protection Warning Financial Scams The AMF, AFG, ASPIM, France Invest, Anacofi, Cie CIF, CNCGP and CNCIF warn the public against an upsurge in the theft of names of authorised market players
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Warning Covid-19 Savings protection Financial Scams The AMF and the ACPR warn the public of the risks of scams in the context of the coronavirus epidemic
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Warning Savings protection The Autorité des marchés financiers calls on retail investors to exercise the greatest vigilance in usurpation cases
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Warning Savings protection Warning The Autorité des marchés financiers warns the public about cases of the fraudulent use of its name and contact details by a certain Stéphane Delaplace
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