Sanctions & settlements professional obligations Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor and its directors for breaches of their professional obligations
The AMF Enforcement Committee sanctioned financial investment advisor Kerdiz Finance et Conseil with a €300,000 fine and its directors Anthony Finck and Marc Peuvrier with €75,000 fines each, plus a 5-year ban on advisory activities, for multiple breaches of professional obligations from 2020-2023. This case underscores AMF's strict enforcement against unauthorized product marketing, conflict of interest mismanagement, product governance failures, and AML shortcomings, serving as a warning for advisors to prioritize client best interests and regulatory compliance. It matters because it highlights personal liability for directors and escalating penalties for systemic procedural lapses.
What Changed
- This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French financial advisor rules (e.g., derived from MiFID II and AIFMD implementations):
- Accurate representation: Advisors must not misrepresent authorization status or claim unapproved services like investment services provision.[Source URL:...
- Conflict of interest management: Procedures must identify and mitigate risks from commercial/ownership ties (e.g., to Vivat Multitalent group), beyond mere shareholding disclosures.
- Product governance: Collect and review product information to ensure investor protection; verify asset managers/depositaries for securities.
- Marketing limits: Prohibit advising prohibited securities (e.g., Multitalent AG bonds without French authorization) or high-risk offers like Guyane Agricole exceeding initial contributions.
Suggested Considerations
- Immediate review: Audit marketing materials, website, and client communications for accurate authorization claims; cease any unapproved representations.
- Enhance procedures: Update conflict of interest policies to fully identify/mitigate risks from promoter ties; implement robust product governance collecting issuer details (e.g., asset managers, depositaries, marketing eligibility in France).
- Product due diligence: For all recommended securities/offers, verify French marketing authorization (e.g., AMF registration, prospectus, AIFMD passport); document high-risk features like loss exceeding contributions.
- AML/CFT strengthening: Ensure full compliance with due diligence and inspector cooperation; conduct gap analysis against AMF guidelines.
- Training and governance: Train directors/staff on personal liability; test procedures via internal audits.
Key Dates
28 June 2023; Period of breaches investigated
Date of AMF Enforcement Committee decision imposing fines and 5-year ban
Compliance Impact
Urgency: High – This demonstrates AMF's pattern of heavy fines (€300k+ firm, €75k personal) and long bans (5 years) for procedural failures, with director accountability. It matters amid rising enforcement on unauthorized AIF/alternative product marketing (see related cases), risking similar sanctions for non-EU promotions; firms should prioritize audits now to preempt inspections.
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Wealth ManagerAll Firms
Anti-money Laundering Asset management The AMF invites financial market participants to AMLA’s consultations on three draft AML/CFT implementing standards
The AMF is urging financial market participants, especially in asset management and related sectors, to engage in AMLA's public consultations on three draft Regulatory Technical Standards (RTS) under the new EU AML/CFT package, covering customer due diligence (CDD), identification of business relationships/transactions, and enforcement measures. These RTS aim to provide harmonized, proportionate implementation guidance, significantly impacting CDD processes and supervisory consistency across the EU, with underlying rules applying from 10 July 2027.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
What Changed
- - CDD RTS: Builds on EBA's prior draft with AMLA refinements for legal clarity, proportionality, and risk adaptation; specifies information/sources for identity verification of natural persons/legal...
- Business Relationships/Occasional/Linked Transactions RTS: Defines criteria under AMLR Article 19(9) to harmonize identification, ensuring consistent EU-wide application beyond basic...
- Enforcement RTS (Pecuniary Sanctions/Administrative Measures): Under AMLD6 Article 53(10), standardizes supervisor assessment/categorization of breaches for proportionate, effective, dissuasive...
Suggested Considerations
- Gap analysis and preparation: Assess current CDD/business identification/enforcement processes against drafts; identify changes for remote onboarding, PEPs, sectoral measures (e.g., asset manager Article 17 scenarios), and sanctions screening; set milestones for policy/system updates by July 2027.
- Engage hearings: Attend 24 March 2026 public hearing for CDD/business RTS.
- Monitor post-consultation: Track AMLA/EC adoption (expected Q1 2026 for some related RTS) and national implementations (e.g., CSSF data reporting).
Key Dates
- Consultations opened by AMLA on three draft RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
- Consultation closes on RTS for pecuniary sanctions/administrative measures
- Online public hearing on CDD and business relationships RTS
- Consultations close on CDD RTS and business relationships/linked transactions RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
- AMLA submits final draft RTS to European Commission for adoption
Compliance Impact
Urgency: High - These RTS operationalize core AMLR/AMLD6 mandates with July 2027 applicability, demanding immediate consultation input to influence final rules and 18-month lead time for system/process overhauls (e.g., CDD verification sources, harmonized transaction linking). Failure to engage risks non-compliant frameworks amid AMLA's push for EU-wide consistency, elevated direct supervision risks, and stricter enforcement; asset managers face acute challenges from intermediary distribution rules.[Source URL:...
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Asset ManagerCrypto ExchangeAll Firms
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.
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.
- 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/liabilities.
These align with prior AMF expectations for "honest, fair, and professional" conduct with skill, care, and...
Suggested Considerations
- Conduct immediate gap analysis of investment processes for operationality, traceability, and precision in allocation rules.
- Enhance AML/CFT systems: Update risk mapping, procedures, and due diligence on fund assets/liabilities; ensure systematic application.
- Review conflict of interest frameworks for identification, prevention, and management; document controls rigorously.
- Senior managers: Demonstrate personal oversight via governance records to mitigate attribution of firm breaches.
- Audit marketing materials, fee retrocessions, and valuation procedures (e.g., for real estate or experts) against AMF standards.
Key Dates
December 2023; - Period of breaches investigated
- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors
- Public news release date for the decision
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; immediate audits are essential pre-audit cycles, especially with appeals highlighting ongoing litigation risk.
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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.
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 completeness and documentation,...
Suggested Considerations
- Review and enhance investment/divestment procedures: Ensure completeness, traceability of all compliance checks (e.g., alignment with fund policies), and formalized pre-allocation due diligence; test for operationality via internal audits.
- Document all processes rigorously: Maintain evidence of checks and due diligence to demonstrate skill, care, and diligence in line with authorization conditions.
- Conduct gap analysis against AMF expectations: Cross-reference with similar cases (e.g., operational procedures, AML/CFT); remediate deficiencies promptly.
- Senior manager training: Reinforce personal accountability for firm compliance; update governance frameworks.
- Appeal monitoring: If similarly positioned, prepare for potential appeals to Conseil d’État.
Key Dates
- AMF Enforcement Committee decision date imposing fines; appeals possible (no specific deadline stated, but typically within 2 months to Conseil d’État)
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 reputational damage; immediate procedure audits are essential to mitigate exposure, especially pre-authorization renewals or fund launches.
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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.
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...
- 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 receiving client funds in personal accounts.
- Annual training for directors and diligent cooperation with AMF inspections.
Suggested Considerations
- Audit documentation: Ensure all investment advice is fully documented and compliant; implement traceability for proposals.
- Strengthen governance: Deploy systems to detect/prevent conflicts, especially manager-led undocumented investments; enforce annual director training.
- Enhance AML/CFT: Prohibit personal receipt of client funds; conduct KYC and transaction monitoring.
- Improve inspection readiness: Train staff for diligent, honest cooperation with AMF; maintain secure archives.
- Senior manager reviews: Assess personal compliance liabilities; update senior managers regime policies.
Key Dates
- Relevant period of breaches for Carat GP
- AMF Enforcement Committee decision issued, imposing fines and bans
- French version of press release published
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 enforcement, as breaches spanned years and AMF emphasizes educational deterrence through decisions.
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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.
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),...
- 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 liabilities; non-operational procedures or risk mapping constitute breaches.
- Marketing and fee retrocessions: Materials must be accurate; firms must prove retrocessions enhance client service quality.
- Senior manager accountability: Breaches attributable to responsible managers, emphasizing personal liability for oversight failures.
No explicit regulatory changes, but the decision aligns with AMF's...
Suggested Considerations
- Audit procedures immediately: Review and document operational status of investment/divestment processes, ensuring traceability of lender checks, fund policy compliance, and AML/CFT due diligence on assets/liabilities.
- Enhance AML/CFT systems: Formalize risk mapping, procedures, and systematic investor/transaction due diligence; test for operational effectiveness.
- Validate marketing and fees: Audit fund materials for accuracy; gather evidence that fee retrocessions to distributors improve client services (e.g., via service level agreements or performance metrics).
- Senior manager training: Conduct gap analysis on personal accountability; update governance frameworks to mitigate attribution of firm breaches.
- Mock AMF inspections: Simulate Enforcement Committee reviews, focusing on procedure formalization, independent valuers (if applicable), and conflict systems.
Key Dates
- AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners, Maurice Tchenio, and Patrick de Giovanni
- French version of press release published
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 controls and AML gaps amid EU AIFMD reviews. Non-compliance risks personal fines up to €500,000+ for managers, reputational damage, and authorization challenges; proactive remediation is essential as appeals (like this one) do not suspend obligations.
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before acting. Full disclaimer.
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.
BankWealth ManagerFintech
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.
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.
- 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.
- Maintaining operational procedures for valuing real estate assets, including formalizing independent valuer work.
- Adhering to programs of activity for selecting, evaluating, overseeing, and periodically assessing external experts.
Suggested Considerations
- Conduct immediate gap analysis of investment procedures, marketing materials, conflict of interest policies, valuation processes, external expert oversight, and AML/CFT systems to ensure they are operational, documented, and traceable.
- 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: Document personal oversight of compliance; train on attribution of breaches.
Key Dates
- 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). It matters because AMF increasingly attributes breaches to individuals, escalating personal liability, and emphasizes "operational" procedures over mere documentation—firms with AIFs/club deals face elevated scrutiny amid rising enforcement volume.
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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.
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...
- Risk Assessment for Direct Supervision (Article 12(7) AMLAR): Two-stage selection for AMLA direct oversight of high-risk cross-border firms (operating in ≥6 Member States, meeting...
- CDD Updates: Risk-based approach for new customers from July 2027; five-year transition for existing customers, prioritizing high-risk.
- Pecuniary Sanctions RTS (Article 53(10) AMLD6): Structured classification of breaches, proportionate sanctions, and enforcement for serious/repeated/systematic infringements to ensure uniformity...
Suggested Considerations
- Participate in EBA consultation: Submit feedback on draft RTS via EBA channels, focusing on risk indicators, data frequency, and feasibility; AMF encourages French firms to act promptly.
- Conduct compliance gap analysis: Review current AML frameworks against proposed indicators (inherent risk, controls, residual risk); prioritize high-risk customers/products.
- Enhance systems: Invest in regtech for automated risk scoring, transaction monitoring, and data reporting to supervisors; update governance, policies, and CDD processes.
- Prepare for AMLA supervision: For cross-border firms, model group-wide risk profiles; develop remediation plans for breaches.
- Ongoing monitoring: Implement annual risk reviews and ad-hoc reassessments for business changes.
Key Dates
EBA consultation launch; on draft RTS for AML/CFT standards (ongoing as of analysis)
EBA hands over AML/CFT mandates, tools (e.g., EuReCa database), and functions to AMLA; ; existing EBA guidelines remain until replaced
New AMLD6/AMLR rules apply directly; , including CDD for new customers and start of phased compliance
AMLA begins direct supervision; of selected high-risk entities
Full CDD compliance; for existing customers (five-year transition from 2027)
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 scrutiny for large firms. Matters due to shift to uniform EU standards, ending national discretion and increasing reporting burdens—firms acting now can influence outcomes and future-proof via tech/governance investments.
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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.
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 quality.
- Honest, fair, and diligent business conduct with requisite skill and care, extending to marketing materials and advisory services.
No new requirements; emphasis on enforcement of MiFID II-aligned...
Suggested Considerations
- 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.621-15-1.
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 educational role of Enforcement Committee decisions in clarifying regulations—non-compliance risks reputational damage and capital outflows.
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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...
- Investment Due Diligence Standards: A "high standard of diligence" is required when selecting investments, with formal investment procedures that must be consistently followed and documented.
- Conflict of Interest Management: Specific controls must address conflicts in asset allocation decisions, with documented decision-making processes that demonstrate conflict mitigation.
- AML/CFT Implementation: Anti-money laundering and combating the financing of terrorism procedures must be applied comprehensively to both fund-level investments and individual client subscriptions,...
Suggested Considerations
- *Audit Existing Procedures: Review and document all procedures governing regulatory and marketing materials for alternative investment funds, ensuring they address risk disclosure accuracy and asset return reporting requirements.
- *Formalize Investment Selection Process: Document and implement investment selection procedures that demonstrate application of "high standard of diligence," including documented investment committee decisions, due diligence checklists, and approval workflows.
- *Enhance Conflict of Interest Controls: Map all potential conflicts in asset allocation decisions and implement specific controls (e.g., segregation of duties, documented approvals, independent review) for each identified conflict scenario.
- *Implement Comprehensive AML/CFT: Extend AML/CFT procedures to cover both fund-level investments and individual client subscriptions, with documented customer due diligence, beneficial ownership verification, and transaction monitoring.
- *Strengthen Internal Control Functions: Establish or enhance internal audit/compliance functions with documented monitoring controls covering investments, conflicts of interest, and AML/CFT, with regular reporting to management and governance bodies.
Key Dates
- AMF Enforcement Committee issued the decision
- Public announcement of sanctions
- Appeal period remains open (appeals may be lodged against the decision)
Compliance Impact
Urgency: HIGH
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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.
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...
- Scope of services: Asset managers acting as tied agents cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing permitted investment services.
- Conflicts of interest: Systems must effectively identify, prevent, and manage conflicts.
- AML/CFT due diligence: Procedures, risk mapping, and due diligence on fund assets/liabilities must be operational and systematic.
Suggested Considerations
- Conduct gap analysis: Immediately review investment processes, allocation rules, and traceability against AMF standards; verify authorization of lending entities and service scopes.
- Enhance AML/CFT: Update procedures, risk mappings, and due diligence on fund assets/liabilities; ensure operational effectiveness with documented evidence.
- Strengthen governance: Implement robust conflicts of interest systems; formalize senior manager oversight with personal accountability training.
- Audit marketing/distribution: For tied agents or retrocessions, document service quality enhancements to clients.
- Senior manager certification: Directors must attest to compliance in annual reporting; prepare for AMF inspections by maintaining verifiable records.
Key Dates
December 2023; - Period of identified breaches (investment services, processes, AML/CFT deficiencies)
- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors
- 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 enforcement, reputational damage, and appeals delays; act within 3-6 months to align before potential audits.
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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.
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.
Suggested Considerations
- Monitor and engage: Participate in AMF's ongoing DeFi discussions and tokenization consultations for asset managers; no mandatory actions from this summary alone.
- MiCA compliance: DASPs must apply for CASP licenses or leverage exemptions (e.g., notify AMF with operational/AML details if regulated entities); ensure AML/CTF alignment with EBA/TFR "Travel Rule" extensions.
- Assess decentralization: DeFi protocols should evaluate if they qualify as "sufficiently decentralized" to evade DASP rules; traditional firms notify AMF before crypto services.
- Update policies: Incorporate AMF clarifications on DASP transitions (DOC-2019-23/24 updates) and prepare for 2026 priorities like DORA cybersecurity.
Key Dates
- AMF publishes initial Discussion Paper on DeFi regulatory challenges
- AMF publishes summary of responses to DeFi Discussion Paper
- MiCA enters force for CASPs
- End of MiCA transitional period for DASPs; full CASP licensing required
- EU AMLR ("single rulebook") comes into effect, standardizing crypto due diligence
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 competitiveness in France's innovation-friendly regime, especially with AMF's 2026 focus on MiCA convergence and tokenization.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
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 activities.
- Conflicts of interest: Robust identification, prevention, and management systems are mandatory.
- AML/CFT: Due diligence on fund assets/liabilities must be systematic and operational, with effective risk mapping and procedures.
Suggested Considerations
- Immediate gap analysis: Review investment procedures for precision, traceability, and operationality; verify authorization of lending entities and service scopes (e.g., no unauthorized placement services).
- Enhance AML/CFT: Implement operational risk mapping, systematic due diligence on fund assets/liabilities, and evidence of effectiveness.
- Conflicts framework: Formalize identification/prevention processes, especially in multi-role firms (asset manager + tied agent).
- Senior manager attestation: Document personal oversight; conduct training on attribution of breaches.
- Marketing/retrocessions: Ensure traceability and proof of client benefit (cross-reference with similar findings).
Key Dates
December 2023; - Period of breaches investigated, covering investment services, processes, conflicts, and AML/CFT failures
- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors
- 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 amplifying precedent, and applicability to hybrid models; non-compliance risks fines scaling to €1M+ and reputational damage.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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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 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.
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).
- 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 service quality.
- Ensuring marketing materials are accurate and compliant.
These align with ongoing AMF expectations for "honest, fair, professional" conduct with requisite skill, care, and diligence.
Suggested Considerations
- 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.g., via evidence of enhanced distribution quality).
- Validate marketing materials for accuracy and completeness.
- Conduct senior manager attestations on compliance oversight; implement training on personal liability.
Key Dates
- AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners and managers
- French version of press release published
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 pending but do not suspend obligations; firms with similar setups face elevated audit risk, especially amid AMF's pattern of targeting asset managers (e.g., 5+ cases in 2024-2025).
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
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 effective 30/06/2026 integrate MAR references and strengthen reporting of failings .
Suggested Considerations
- 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.634-1 procedures .
- 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
- MiCA mandatory licensing for CASPs; pre-registered PSANs enter 18-month transition
- End of PSAN transitional period; full MiCA authorization required, with AMF oversight on manipulation risks
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 operators risk exclusion post-2026, with pump-and-dump flagged as a key abuse vector . Non-compliance invites AMF inspections, fines, and reputational damage in a litigious environment.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
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 code, and governance.
- Adopting IOSCO recommendations: identify responsible persons (developers, DAOs), enforce risk management, disclosures, conflict-of-interest mitigation, and applicable laws.
Suggested Considerations
- Submit feedback (past deadline): Stakeholders could contribute by September 30, 2023, to innovation@amf-france.org.
- Monitor developments: Track AMF/ACPR follow-ups, including smart contract certification discussions.
- Conduct internal assessments: Analyze DeFi exposures using IOSCO criteria—identify responsible persons, risks (operational, AML/CTF), interconnections with TradFi, and ensure disclosures/conflict management.
- Enhance compliance programs: Prepare for proportionate rules on governance, cybersecurity, solvency, transparency; align with "same risk, same regulation" for DeFi-like activities.
- Engage stakeholders: Participate in AMF ecosystem dialogues at French/EU/international levels.
Key Dates
- AMF publishes initial discussion paper on DeFi regulatory issues
- Deadline for stakeholder contributions to the discussion paper
- 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-driven financial crime and market abuse, potentially triggering enforcement of existing laws; firms risk non-compliance if unprepared for "same risk, same regulation" application, especially with AMF's international push.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
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.
- 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...
- Investment allocation processes must be precise, operational, and traceable, with demonstrated compliance to investment procedures.
- Firms must maintain effective systems for conflicts of interest identification/prevention, AML/CFT (including adequate due diligence), and overall operational controls.
These align with patterns in...
Suggested Considerations
- 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: ensure due diligence is adequate, systems are operational, and staff training is regular.
- 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.g., Eres Gestion, Inter Gestion).
Key Dates
December 2023; - Period of breaches investigated
- AMF Enforcement Committee decision date; fines imposed on M Capital Partners (€200,000), Rudy Secco (€70,000), and Stéphanie Minissier (€35,000)
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 in 2023 for procedures/investor info; warnings/fines on Inter Gestion in 2024 for AML), indicating heightened 2026 enforcement risk; non-compliant firms risk fines, reputational damage, and manager bans, especially if dually registered.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
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...
- 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 between funds must be precise, with full traceability of verifications.
- Conflicts of interest: Firms must identify, prevent, and manage conflicts effectively.
- AML/CFT: Systems must be fully operational, with adequate due diligence (e.g., client identification, PEP screening).
Suggested Considerations
- Audit dual roles: Review tied agent activities to ensure no unauthorized placement services; cease any circumvention of AMC service restrictions.
- Enhance investment processes: Implement precise, operational rules for fund investment allocation, with full traceability of due diligence and verifications.
- Strengthen controls: Update conflicts of interest frameworks, AML/CFT systems (including due diligence, training, and risk assessments), and compliance monitoring to ensure operational effectiveness.
- Director oversight: Responsible managers must demonstrate active supervision; conduct gap analyses attributing breaches to governance failures.
- Documentation: Maintain auditable records for all procedures; test systems for operationality via internal audits.
Key Dates
December 2023; - Period of breaches investigated
- AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier
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, escalating fines (up to €200k+), and AMF's educational role in clarifying regulations, risking similar actions for non-compliant firms in 2026 amid AIFMD 2.0 focus.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
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...
- Investment systems must be operational with precise allocation rules between funds; lack of traceability in verifications violates due diligence obligations.
- Firms must maintain effective conflict-of-interest identification, prevention, and management processes.
- AML/CFT systems require operational due diligence, including adequate client and asset verification; deficiencies here trigger sanctions.
These align with prior AMF positions but clarify enforcement...
Suggested Considerations
- 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: responsible managers should self-assess oversight of compliance functions.
Key Dates
December 2023; - Period of breaches investigated, covering unauthorized services, investment process failures, conflicts, and AML/CFT deficiencies
- AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset Manager
Asset management Anti-money Laundering Anti-money laundering and combating the financing of terrorism: the AMF applies the guidelines of the European Banking Authority
Asset ManagerBankWealth Manager
Asset management Anti-money Laundering Money Laundering and Terrorist Financing: update of the COLB’s National Risk Assessment
Asset ManagerWealth Manager
Warning Warning Savings protection The AMF warns the public about calls from fraudsters claiming to help recover funds
BankWealth 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 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 onboarding procedures must be sufficiently detailed to identify and assess money laundering risks, including beneficial owner identification and...
- Compliance Function: The compliance and internal control officer must actively centralize and monitor information on market abuse across the organization
Suggested Considerations
- assessments across these areas:
- *Liquidity Risk Management: Review procedures for adequacy and operational effectiveness; ensure they address fund-specific liquidity profiles and stress scenarios
- *Market Abuse Detection: Audit surveillance systems to confirm they specify participation conditions in market surveys and document consequences for violations
- *AML/CFT Compliance: Enhance risk mapping to capture money laundering typologies; strengthen client onboarding procedures to verify beneficial owners and screen for PEPs
- *Compliance Monitoring: Establish centralized processes for the compliance officer to aggregate and review market abuse information across all business lines
Key Dates
- Enforcement Committee decision date against Inocap Gestion
- The decision addresses historical breaches; however, firms should immediately remediate similar deficiencies
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerWealth Manager
Crypto-assets Anti-money Laundering Supervision Journalists Investment services providers AMF and ACPR announce the withdrawal of BYKEPS SAS’s registration as a DASP
Crypto Exchange
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.
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...
- 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 providers, with comprehensive, accurate investor disclosures on related remuneration.
- Full transparency required on retrocessions of management fees to distributors, including justification of added value.
- Robust client categorization and AML/CFT systems, including operational procedures, risk mapping, and adequate due diligence on fund assets/liabilities.
No explicit regulatory changes, but these...
Suggested Considerations
- Audit internal procedures: Immediately review investment/divestment, valuation, and allocation processes for operational status, completeness, traceability, and documentation of due diligence.
- Enhance conflict and transparency controls: Implement/test effective conflicts of interest policies for group providers/distributors; update investor disclosures on fees/retrocessions with clear justifications.
- Strengthen AML/CFT and client categorization: Validate risk mapping, procedures, and due diligence; ensure formalization of independent valuer work and external expert oversight.
- Senior manager accountability: Conduct gap analysis attributing responsibilities; train executives on personal liability risks.
- Mock AMF inspections: Simulate Enforcement Committee reviews, focusing on evidence of procedure adherence.
Key Dates
- AMF Enforcement Committee decision fining Eternam €400,000 (similar case on marketing, club deals, conflicts, valuation, AML/CFT)
- AMF Enforcement Committee decision fining Novaxia Investissement €400,000 and director €100,000 (investment processes, group providers, distributor fees, client categorization, AML/CFT)
- 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 imminent inspection risk; non-compliance could trigger fines, reputational damage, and appeals processes.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset Manager
Anti-money Laundering Asset management The AMF and TRACFIN sign a new cooperation protocol
Asset ManagerBankWealth Manager
Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company for several breaches of its professional obligations
The AMF Enforcement Committee fined asset management company Altaroc Partners €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) on 15 September 2025 for multiple breaches of professional obligations, including lack of operational procedures for fund investments/divestments, inadequate AML/CFT due diligence, unproven benefits of fee retrocessions to distributors, and shortcomings in marketing materials. This decision underscores AMF's focus on operational controls, due diligence, and transparency in asset management, serving as a key enforcement precedent that highlights personal liability for senior managers. Compliance teams must review it to strengthen internal procedures and governance amid rising AMF scrutiny on these issues.
What Changed
- This is an enforcement action, not a regulatory change introducing new rules; it enforces existing obligations under French financial regulations for asset management companies (sociétés de gestion...
- Absence of operational procedures for investment/divestment processes, failing to verify lender authorizations, breaching duties to act honestly, fairly, professionally, with skill, care, and...
- Inability to demonstrate that retrocessed management fees to distributors improved client services.
- Failure to systematically perform AML/CFT due diligence on fund assets and liabilities.
- Shortcomings in fund marketing materials, lacking clear, accurate information.
These align with ongoing AMF expectations for robust internal systems, as seen in similar cases emphasizing operational...
Suggested Considerations
- Implement and document operational procedures for all investment/divestment processes, including third-party authorization checks (e.g., lenders).
- 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: Demonstrate oversight of compliance functions; conduct gap analyses attributing breaches.
Key Dates
- AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners and managers
- French version of press release published
Compliance Impact
Urgency: High - This recent (2025) decision signals intensified AMF enforcement on core operational failures in asset management, with total fines of €1.3 million and personal accountability, amid a pattern of similar actions (e.g., M Capital Partners €305,000 in Dec 2025, Eternam €400,000 in Sep 2025). It matters because AMF uses such rulings educationally to clarify expectations, increasing audit risks and penalties for non-compliance; firms without robust procedures face immediate exposure, especially with appeals not suspending applicability.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset Manager
Asset management Anti-money Laundering Money laundering and terrorist financing: the AMF applies EBA guidelines on risk factors
Asset ManagerBankWealth Manager
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
Asset ManagerWealth ManagerBank
Warning Savings protection The AMF announces the referral of two investigation files on “boiler room marketing” to the National Financial Prosecutor’s Office
BankWealth ManagerBroker Dealer
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
BankWealth ManagerAll Firms
Warning Savings protection The Autorité des marchés financiers calls on retail investors to exercise the greatest vigilance in usurpation cases
BankWealth ManagerFintech
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
BankWealth ManagerFintech