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
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Sanctions & settlements professional obligations Journalists Investment management companies Listed companies and issuers AMF Enforcement Committee fines the depositary CACEIS Bank for breaches of its professional obligations
The AMF Enforcement Committee fined CACEIS Bank €3.5 million and issued a warning on 17 December 2025 for breaches of its professional obligations as depositary for seven French-law UCITS funds managed by H2O AM LLP (later transferred to H2O AM Europe). This decision underscores the AMF's strict enforcement of depositary oversight duties, particularly in verifying fund managers' investment monitoring systems, asset valuations, and compliance with prospectus constraints like issuer limits and security ratings. It matters for compliance teams as it highlights personal accountability risks and potential fines for inadequate due diligence in fund depositary roles, signaling heightened scrutiny amid past H2O fund issues.
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What Changed
This is an enforcement action, not a regulatory change; it reinforces existing obligations under French UCITS rules (transposing UCITS Directive V) for depositaries. Key upheld objections include:
Failure to perform sufficient checks on the asset management company's (AMC) systems for monitoring UCITS investment ratios and valuing unlisted securities.
Inadequate verification of investment decision legality, such as compliance with prospectus limits on debt security ratings, derivative types, and
What You Need To Do
- Conduct gap analysis
- Enhance oversight processes
- Training and audits
- Monitor appeals
Key Dates
17 December 2025 - AMF Enforcement Committee decision date: €3.5M fine and warning imposed on CACEIS Bank.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision directly impacts depositaries with €3.5M precedent for oversight failures, amid AMF's pattern of multi-million fines (e.g., €5.67M total in related 2024 case involving CACEIS). It elevates risks for UCITS/AIF depositaries handling non-standard assets,
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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.
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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
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Governance Annual report Executive & other private individuals Journalists Listed companies and issuers The AMF examines the transparency of executive succession plans as part of its 2025 Corporate Governance Report
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Mediation Appointment Institutional Other professionals Executive & other private individuals Retail investors Journalists Investment services providers Investment management companies Listed companies and issuers ...
Asset ManagerBroker DealerWealth 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
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Supervision Asset management Governance Journalists Investment management companies The Autorité des Marchés Financiers publishes the findings of its thematic inspections on governance and role of senior managers at asset management companies
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Sanctions & settlements professional obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines an asset management company and its two managers a total of €1.3 million
The AMF Enforcement Committee fined asset management company Altaroc Partners €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) a total of €1.3 million on 15 September 2025 for breaches of professional obligations, including non-operational investment procedures, inadequate AML/CFT due diligence, deficient marketing materials, and unproven benefits from fee retrocessions to distributors. This decision underscores the AMF's heightened scrutiny on operational controls and senior accountability in asset management, serving as a critical enforcement signal for firms to strengthen procedures amid a pattern of similar sanctions.
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What Changed
This is an enforcement action rather than new legislation, but it reinforces and clarifies existing professional obligations under AMF regulations for asset managers (sociétés de gestion), particularly under the AIFM regime. Key expectations highlighted include:
Operational investment/divestment procedures: Must be fully implemented, with traceability of checks on lender authorizations and compliance with fund policies.
AML/CFT due diligence: Systematic verification required on fund assets and l
What You Need To Do
- Audit procedures immediately
- Enhance AML/CFT systems
- Validate marketing and fees
- Senior manager training
- Mock AMF inspections
Key Dates
15 September 2025 - AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners, Maurice Tchenio, and Patrick de Giovanni.
16 September 2025 - French version of press release published.
Post-15 September 2025 (exact date unspecified) - Appeal lodged by Altaroc Partners, Tchenio, and de Giovanni before the Conseil d’État against decision SAN-2025-09.
Compliance Impact
Urgency: High – This fits a 2025 enforcement trend targeting asset managers' operational deficiencies (e.g., similar fines against Novaxia Investissement on 10 December 2025, M Capital Partners on 31 December 2025, and Eternam on 9 September 2025), signaling AMF's zero-tolerance for non-operational
Asset Manager
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
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Appointment Institutional Isabelle Guezet and Julien Laroche appointed Deputy Directors of the Corporate Finance Division
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MiCA Crypto-assets Innovation Implementation of MiCA: The AMF applies ESMA and EBA Guidelines on the assessment of the suitability of members of the management body
Crypto ExchangeFintech
Supervision Professional certification Asset management Journalists Investment management companies The AMF publishes the findings of its inspections on the verification and assessment of employee knowledge within asset management companies
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Governance Journalists Listed companies and issuers Women on Boards Directive: the AMF is now the competent authority for analysing and monitoring gender balance among the directors of listed companies
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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
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Sanctions & settlements professional obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines Pharnext and its former directors a total of €800,000
The AMF Enforcement Committee fined Pharnext €500,000 and its former directors Daniel Cohen (€200,000) and David Horn Solomon (€100,000) on 20 January 2025 for failing to disclose inside information promptly and disseminating false or misleading information about FDA interactions for a drug candidate. This enforcement action reinforces AMF's strict stance on market abuse rules under EU MAR, highlighting personal liability for directors in listed biotech firms where investor expectations around product approvals are high. Compliance teams should note it as a reminder of timely disclosure obligations, especially amid appeals filed by the parties.
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What Changed
This is not a regulatory change but an enforcement decision applying existing obligations under the Market Abuse Regulation (MAR), specifically:
Article 17 MAR: Requirement to disclose inside information as soon as possible (breached by Pharnext's delays from 10 April 2019 and non-disclosure from 28 October 2020).
Article 12(1)(c) MAR: Prohibition on disseminating false or misleading information that could affect market prices, via press releases and shareholder letters overstating FDA progress.
What You Need To Do
- Review inside information policies
- Audit communications
- Director training
- Monitor appeals
- wide actions mandated beyond general MAR compliance, but proactive gap analysis recommended
Key Dates
10 April 2019 - FDA request for additional study deemed inside information; not disclosed until 30 August 2019.
28 October 2020 - FDA 'non-agreement' on clinical study design deemed inside information; never publicly disclosed.
20 January 2025 - AMF Enforcement Committee decision imposing fines (SAN-2025-01).
23 July 2025 - Paris Court of Appeal dismissed David Horn Solomon's stay of execution application (n°25/05331).
Post-20 January 2025 - Appeal lodged by Pharnext, Cohen, and Solomon to Paris Court of Appeal (ongoing).
Compliance Impact
Urgency: Medium – This is a specific enforcement (not a new rule), but it signals heightened AMF scrutiny on biotech disclosures amid investor sensitivity to approval news; delays in similar cases could trigger investigations/fines up to 15% of turnover or €15M. Matters for listed firms with pipelin
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Strategy Supervision Institutional Executive & other private individuals Journalists Investment services providers Investment management companies Listed companies and issuers The AMF publishes its action and supervisory...
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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
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Institutional Organisational rules Journalists The Autorité des Marchés Financiers (AMF) signs #JamaisSansElles Charter
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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
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Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breaches of their professional obligations
The AMF Enforcement Committee has issued multiple enforcement decisions against financial investment advisors and their management for breaches of professional obligations, with the most recent and significant case involving Carat GP and its directors receiving combined fines of €2.5 million and permanent/extended bans from operating as financial investment advisors. These cases establish critical precedent regarding advisor duties around client disclosure, product authorization, conflict of interest management, and honest/fair conduct—requirements that apply across the entire financial investment advisory sector.
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What Changed
The enforcement decisions clarify and reinforce several core professional obligations for financial investment advisors:
*Transparency and Disclosure Obligations**
Financial investment advisors must inform clients of any remuneration received for their advice and justify improvements to advisory services in return for compensation received. Advisors cannot recommend financial products without first ensuring their marketing is authorized in the relevant jurisdiction.
*Competence and Care Standa
What You Need To Do
- *Immediate Compliance Review
- *Governance and Documentation
- *Training and Culture
- *Regulatory Engagement
Key Dates
19 December 2023 - AMF Enforcement Committee decision against Séquence 13 and Jean-Louis Lehmann (€15,000 fines each; 5-year ban)
11 April 2022 - AMF Enforcement Committee decision against DCT and Didier Maurin (€150,000 and €200,000 fines; 5-year ban)
9 September 2024 - Conseil d'Etat judgment dismissing appeal by DCT and Didier Maurin
24 October 2022 - AMF Enforcement Committee decision against Salzillo Finance and Jean Salzillo (€20,000 and €80,000 fines; 3-year ban)
2 July 2019 - AMF Enforcement Committee decision against Invest Securities and financial advisors (€90,000 to €60,000 fines)
Compliance Impact
Urgency: HIGH
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Appointment AMF activity Journalists Marie Seiller appointed Resources, Operations and Transformation Director at the Autorité des Marchés Financiers
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Appointment AMF activity Retail investors Journalists France Mayer appointed Retail Investor Relations and Protection Director at the Autorité des Marchés Financiers
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Professional certification AMF activity Journalists The Autorité des Marchés Financiers announces the new composition of the Financial Skills Certification Board
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Appointment Sanctions & settlements Journalists Valérie Michel-Amsellem becomes Chair of the AMF Enforcement Committee
This AMF publication announces the appointment of Valérie Michel-Amsellem as the new Chair of the AMF Enforcement Committee, the independent body responsible for imposing sanctions in financial market violations. It matters for compliance professionals because leadership changes in enforcement can signal shifts in sanctioning priorities, rigor, or focus areas, potentially influencing how firms approach risk management and remediation. While no immediate policy changes are introduced, monitoring the new Chair's tenure is essential given the Committee's role in upholding market integrity.
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What Changed
There are no substantive regulatory changes, new requirements, or amendments to the AMF General Regulation outlined in this announcement. The publication solely details an internal governance appointment within the AMF's structure, where the Enforcement Committee maintains its established autonomy for sanction decisions, separate from the AMF Board. This aligns with prior affirmations of the Committee's independence, as upheld in ECHR rulings on its impartiality.
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What You Need To Do
- Review backgrounds of key AMF personnel, including Valérie Michel-Amsellem, for insights into enforcement trends (e
- Enhance internal monitoring of AMF sanction releases (https://www
- Conduct gap analyses on compliance programs for high-risk areas like market abuse, given the Committee's sanction powers up to €100 million or 10x profits
Key Dates
Immediate - Appointment takes effect upon announcement, with no disclosed transition period.
2026 , Enforcement Committee sanction against an asset management company, indicating ongoing enforcement operations.
Compliance Impact
Urgency: Low - This personnel change does not impose new obligations or alter existing rules, posing minimal immediate risk. It matters indirectly for long-term strategy, as the Chair could steer enforcement toward stricter penalties or novel interpretations of obligations (e.g., as analyzed in hist
Asset ManagerBroker DealerBank Appointment Sanctions & settlements Journalists Appointements to the AMF Enforcement Committee
This AMF publication announces the partial renewal of the Enforcement Committee, including four new appointments, two reappointments, and the subsequent election of Valérie Michel-Amsellem as Chair on 28 February 2024. It matters for compliance professionals as changes in committee composition can influence enforcement priorities, sanction severity, and interpretations of financial regulations under AMF jurisdiction.
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What Changed
There are no new regulatory requirements or substantive changes to laws; this is an administrative renewal of the Enforcement Committee's membership. Key developments include: new members Jean-Claude Hassan (Vice-President of the Council of State appointee, also chairs second section), Xavier Samuel (Court of Cassation appointee), Sophie Langlois and Aurélien Soustre (Ministerial appointees); reappointments of Anne Le Lorier and Ute Meyenberg. The committee maintains its structure of 12 independ
Key Dates
13 February 2024 - Ministerial order appointing new and reappointed members.
20 February 2024 - Publication of the ministerial order.
27 February 2024 - Composition published in the Official Journal.
28 February 2024 - First meeting; election of Valérie Michel-Amsellem as Chair and Jean-Claude Hassan as second section Chair.
Compliance Impact
Urgency: low - This personnel change poses minimal immediate risk but signals potential evolution in enforcement tone under new leadership experienced in sanctions and regulation (e.g., Michel-Amsellem's appellate background). It matters longer-term for firms in protracted AMF proceedings, as commit
Asset ManagerBroker DealerBank AMF activity Appointment Journalists Ten new key figures admitted to the Board of the Autorité des Marchés Financiers
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AMF activity Institutional Journalists Astrid Milsan will act as Secretary General of the AMF until 15 April 2024
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Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations
The AMF Enforcement Committee imposed sanctions on SPI (a financial investment advisor) and its director Vincent Rhodes on 9 January 2024 for breaching professional obligations. This case demonstrates the AMF's enforcement priorities regarding advisor conduct standards and establishes precedent for disciplinary action against both firms and individual managers who fail to meet regulatory requirements.
What Changed
The decision does not introduce new regulatory requirements but rather clarifies enforcement of existing professional obligations for financial investment advisors. The case reinforces that advisors must:
Comply with all applicable laws and regulations governing financial investment advisory activities
Maintain professional standards in their dealings with clients and regulators
Ensure their directors and managers operate within regulatory boundaries
The enforcement action reflects the AMF's i
What You Need To Do
- *For Financial Investment Advisors
- *Review compliance frameworks - Audit existing policies and procedures against the professional obligations that triggered this enforcement action
- *Enhance governance controls - Implement systems to ensure directors and senior management comply with regulatory requirements
- *Document compliance - Maintain records demonstrating adherence to professional conduct standards
- *Staff training - Ensure all personnel understand the scope of professional obligations and consequences of breach
Key Dates
9 January 2024 - AMF Enforcement Committee decision imposing sanctions on SPI and Vincent Rhodes
Immediate effect - 2-year temporary ban on both respondents from exercising financial investment advisor activities commenced following the decision
Compliance Impact
Urgency: HIGH
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Sanctions & settlements Disclosure Obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines a former manager of a listed company for failing to disclose inside information as soon as possible and for failing to disclose major shareholdings
The AMF Enforcement Committee imposed a fine on a former manager of a listed company for two violations: failing to disclose inside information to the public as soon as possible under Article 17 of the EU Market Abuse Regulation (MAR), and failing to disclose major shareholdings as required by French regulations. This enforcement action underscores the AMF's strict enforcement of market abuse rules, emphasizing personal accountability for executives in ensuring timely transparency to prevent insider trading risks and maintain market integrity. Compliance teams should review it as a reminder of heightened scrutiny on disclosure delays and threshold crossings.
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What Changed
This is not a regulatory change but an enforcement decision reinforcing existing obligations under MAR and AMF General Regulation:
Inside information disclosure: Issuers must publicly disclose inside information "as soon as possible" per Article 17 MAR, unless specific delay conditions are met (legitimate interest, confidentiality ensured, no public misleading). Delays require post-publication notification to AMF at differepublication@amf-france.org.
Major shareholdings disclosure: Persons cross
What You Need To Do
- Assess information promptly
- Declare major shareholdings immediately upon threshold crossing to issuer/AMF; ensure custodians comply with identity disclosure requests
- Use professional information providers for dissemination to ensure wide, secure EU reach; archive on company website
- Train executives on insider lists, transaction reporting (within 3 days if >€20k/year), and penalties (up to €100m fines, criminal sanctions)
Key Dates
3 trading days - Managers/PDMRs must report securities transactions to issuer and AMF if annual total exceeds €20,000. DEADLINE
10 business days - Custodians must respond to Euroclear France/AMF requests for shareholder identity on threshold crossings. DEADLINE
effective 2016 ) and AMF GR.
Compliance Impact
Urgency: High - This matters due to personal fines on managers, signaling AMF's aggressive enforcement of MAR since 2016, with rebuttable presumptions against executives for insider misconduct unless proven otherwise. Firms face reputational risk, investigations, and cascading liabilities (e.g., €10
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Sanctions & settlements professional obligations Investment advice Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations
The AMF Enforcement Committee imposed a five-year ban on financial investment advisor DCT (formerly Didier Maurin Finance) and its director Didier Maurin from practicing, plus fines of €150,000 on the firm and €200,000 on the director, for recommending unauthorized Samoan AIF investments to 64 clients, failing to manage conflicts of interest (e.g., no conflicts register), and breaching duties of competence, care, and diligence in clients' best interests. This matters as it reinforces AMF's strict enforcement on CIFs (Conseillers en Investissements Financiers) for product authorization checks, conflicts management, and client-centric obligations under MiFID II transposition in France, signaling heightened scrutiny on advisory integrity amid rising sanctions. The Conseil d'Etat upheld the decision on 9 September 2024, dismissing appeals and confirming sanctions.
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What Changed
This is an enforcement decision, not a new regulation, but it clarifies and reinforces existing requirements for CIFs:
Product marketing authorization: CIFs must verify that recommended investments (e.g., AIFs) are authorized for sale in France before advising clients; recommending unauthorized products breaches professional obligations regardless of client outcomes.
Conflicts of interest management: CIFs must maintain an effective conflicts register, identify risks (e.g., personal benefits), an
What You Need To Do
- Immediate audit
- Conflicts policy enhancement
- Training and documentation
- Director accountability
Key Dates
11 April 2022 - AMF Enforcement Committee decision imposing bans and fines.
9 September 2024 - Conseil d'Etat judgment (no. 464877) dismissing appeals, upholding sanctions, and ordering €1,500 costs each to AMF.
Compliance Impact
Urgency: High - This upheld decision (post-2024 appeal) exemplifies AMF's pattern of escalating fines/bans on CIFs for conduct failures (e.g., €2.5M on Carat GP in 2025; €120K-€150K on Capexis upheld 2025), amid 2024-2025 enforcement wave on professional obligations. Matters for CIFs as it heightens
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Asset management Requirements for investment committees and the affiliation of fund managers of asset management companies: the AMF updates its policy
Asset Manager
Governance Periodic & ongoing disclosures Journalists Listed companies and issuers AMF proposes enhanced investor information when evaluating boards of listed companies
Asset ManagerWealth ManagerBank Sanctions & settlements Journalists The AMF Enforcement Committee fines a French tied agent of a Cypriot investment services provider and its manager for breaches of their professional obligations
The AMF Enforcement Committee fined France Safe Media (FSM), a French tied agent of Cypriot provider VPR Safe Financial Group Limited (Alvexo platform), €300,000 and imposed a 10-year ban from tied agent activities and reception/transmission of orders (RTO) services, while its manager Lior Mattouk received a €100,000 fine and similar 10-year ban, for breaches occurring January 2019–September 2021. This decision, dated 10 November 2023 and upheld by Conseil d'Etat on 16 June 2025, underscores AMF's strict enforcement of professional obligations for tied agents marketing high-risk CFDs, emphasizing staff qualifications, client assessments, risk warnings, disclosures, and diligence. It matters for cross-border intermediaries as it highlights personal liability for managers and the finality of sanctions post-appeal, signaling heightened scrutiny on CFD promotion and tied agent compliance in France.
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What Changed
This is an enforcement action, not a new regulation, but it clarifies and reinforces existing requirements under French rules implementing MiFID II for tied agents:
Staff qualifications: Tied agents must verify sales staff have minimum qualifications and knowledge; post-hoc inadequate tests do not suffice.
Client knowledge/experience assessment: Questionnaires must be robust, with appropriate scoring; account managers cannot interfere (e.g., by prompting answer changes).
Promotional communicatio
What You Need To Do
- Conduct gap analysis
- Enhance manager oversight
- Audit CFD marketing
- Training programs
- Cross-border review
Key Dates
10 November 2023 - AMF Enforcement Committee decision SAN-2023-15 imposing fines and bans.
14 November 2023 - French version of press release published.
16 June 2025 - Conseil d'Etat judgment (n° 490826) dismissing appeals by FSM and Mattouk, confirming sanctions and ordering €4,000 costs to AMF.
Compliance Impact
Urgency: High – Though dated (2019–2021 breaches), the 2025 appeal dismissal makes sanctions final, serving as a binding precedent for tied agents amid AMF's ongoing CFD enforcement wave (e.g., parallel fines on providers like CIC banks). It elevates personal risk for managers and signals intensifie
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Marketing Savings protection Retail investors Professional investors Journalists The ACPR and AMF encourage financial institutions to continue their efforts to take account of the vulnerability of ageing clients
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Cooperation AMF Chair Marie-Anne Barbat-Layani meets with ASIC Chair Joseph Longo
BankWealth ManagerAll Firms
Appointment Institutional AMF activity Other professionals Executive & other private individuals Retail investors Fintech Professional investors Journalists Investment services providers Investment management...
Asset ManagerBankBroker Dealer Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness in asset managers, particularly those acting as tied agents, and holds senior managers personally accountable. It matters for compliance as it exemplifies enforcement trends targeting systemic deficiencies, with potential appeals signaling ongoing scrutiny.
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What Changed
This is an enforcement action, not a regulatory change, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and compliant; failure to verify or document renders systems non-operational.
Scope of services: Asset managers (and tied agents) cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing licensed activ
What You Need To Do
- Immediate gap analysis
- Enhance AML/CFT
- Conflicts framework
- Senior manager attestation
- Marketing/retrocessions
Key Dates
31 December 2025 - AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors.
August 2019 - December 2023 - Period of breaches investigated, covering investment services, processes, conflicts, and AML/CFT failures.
08 January 2026 - Public press release date.
Compliance Impact
Urgency: High - This reflects a pattern of 2025 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc Partners 15 Sep 2025; €400k on Eternam 9 Sep 2025), signaling intensified scrutiny post-AIFMD reviews. Matters due to personal liability for managers, appeal risks amplify
Asset Manager
Sanctions & settlements professional obligations Journalists The AMF Enforcement Committee fines the Association Nationale des Conseillers Financiers-CIF for breaches of its professional obligations
The AMF Enforcement Committee fined the Association Nationale des Conseillers Financiers-CIF (ANACOFI-CIF), a professional association approved for investment advisors (CIFs), €250,000 with a warning, and its former president €20,000 with a warning, for breaching professional obligations in membership vetting, controls, archiving, and conflicts of interest management. This decision, dated September 5, 2023, underscores AMF's scrutiny of professional associations' gatekeeping and oversight roles in ensuring CIF compliance. It matters as it signals heightened enforcement against associations failing to uphold regulatory standards, potentially impacting CIF ecosystem integrity and prompting reviews of similar bodies.
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What Changed
This is an enforcement action, not a new regulation, but it reinforces existing obligations under French Monetary and Financial Code (CMF) for approved professional associations like ANACOFI-CIF. Key breaches highlighted include:
Failure to verify quality of CIF membership application dossiers and non-compliance with internal adhesion procedures.
Non-respect of procedures for member controls, sanctions, and proper archiving of control dossiers.
Violation of internal rules on conflicts of interes
What You Need To Do
- Review and strengthen internal procedures for CIF membership vetting, ensuring dossier quality checks align with approved protocols
- Implement robust systems for member controls, sanctions processes, and secure archiving of all dossiers per CMF L
- Update conflicts of interest policies and registers to fully comply with internal rules and CMF obligations, documenting all identifications
- Conduct gap analyses on governance, documentation, and AML/KYC for CIF activities, training staff on operationalizing procedures
- For CIF members
Key Dates
September 5, 2023 - AMF Sanctions Commission decision issued, imposing fines and warnings on ANACOFI-CIF (€250,000) and M. Patrick Galtier (€20,000).
Post-September 5, 2023 - Decision subject to potential recourse (appeal period not specified in public summaries, typically 1 month under AMF procedures).
June 2, 2023 - AMF Sanctions Commission hearing where €500,000 sanction was initially sought (reduced in final decision).
Compliance Impact
Urgency: Medium - This 2023 decision is not imminent but remains highly relevant given ongoing AMF focus on CIF compliance (e.g., 2025 sanctions for similar breaches like archiving and AML failures). It matters for preventing fines, bans, or reputational damage, as AMF targets systemic weaknesses in
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Institutional AMF activity Journalists The AMF pays tribute to Jacques Delmas-Marsalet
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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.
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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
Sanctions & settlements Journalists Investment services providers By two decisions, the AMF Enforcement Committee fines two investment services providers for breaches of their professional obligations
The AMF Enforcement Committee issued two decisions on 19 June 2023 fining Crédit Industriel et Commercial (€1 million) and Banque CIC Sud-Ouest (€250,000) for breaches of professional obligations in investment advisory services, including inadequate suitability assessments, client classification procedures, marketing of unsuitable instruments, and insufficient controls on costs and fees. This matters because it underscores AMF's strict enforcement of MiFID II-derived obligations, signaling heightened scrutiny on operational systems for client protection and potential for substantial fines based on breach duration and scale.
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What Changed
This is an enforcement action rather than new legislation, but it reinforces existing regulatory requirements under French Monetary and Financial Code and MiFID II transposition:
Obligation to implement an effective operational system for assessing investment suitability in advisory services.
Requirement for compliant client classification procedures aligned with regulations.
Duty to market only financial instruments suited to client profiles.
Mandate for effective control systems over investmen
What You Need To Do
- Conduct immediate gap analysis of investment advisory processes against AMF expectations for suitability assessments, client classification, product matching, and control systems
- Enhance traceability and documentation of suitability checks, client categorizations, and cost disclosures to demonstrate operational effectiveness
- Review and strengthen internal procedures for marketing instruments, ensuring alignment with client profiles and regulatory marketing authorizations (cross-reference to similar past cases)
- Implement or audit remedial measures, as considered in fine calculations, including staff training on professional obligations
- Test controls for providing clear cost information to clients, avoiding misleading disclosures
Key Dates
19 June 2023 - AMF Enforcement Committee decisions issued, imposing fines and warnings.
Compliance Impact
Urgency: High – Demonstrates AMF's willingness to impose multimillion-euro fines for systemic operational failures in core client protection areas, with penalties scaled by breach duration, number, and seriousness; firms with advisory services face elevated risk of audits or enforcement if controls
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Sanctions & settlements Asset management Journalists Investment management companies The AMF Enforcement Committee sanctions an asset management company and two of its managers for breaches of their professional obligations
The AMF Enforcement Committee sanctioned asset management company M Capital Partners and its managers Rudy Secco (€70,000 fine) and Stéphanie Minissier (€35,000 fine) with a total firm fine of €200,000 in its decision dated 31 December 2025, for multiple breaches of professional obligations spanning August 2019 to December 2023. This case underscores AMF's strict enforcement on operational compliance, scope of authorized activities, and AML/CFT systems in asset management, serving as a critical reminder for firms to ensure robust, traceable processes and manager accountability. It matters because it highlights personal liability for senior managers and recurring AMF focus on tied agents exceeding permitted services, potentially signaling increased scrutiny in 2026.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces and clarifies existing requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) and AMF rules for asset managers:
Asset management companies (AMCs) acting as tied agents cannot provide placement of financial instruments without a firm commitment basis, as this exceeds the restrictive list of permitted investment services.
Investment allocation processes must be precise, operational, and traceable, w
What You Need To Do
- Review and enhance tied agent activities to ensure no unauthorized investment services like non-firm commitment placements; map against permitted services list
- Audit investment allocation systems for precision, operationality, and traceability; implement verifiable verifications
- Strengthen AML/CFT frameworks
- Update conflicts of interest policies with clear identification, prevention, and management procedures
- Conduct senior manager attestations on personal oversight; perform gap analysis against this and similar cases (e
Key Dates
31 December 2025 - AMF Enforcement Committee decision date; fines imposed on M Capital Partners (€200,000), Rudy Secco (€70,000), and Stéphanie Minissier (€35,000).
August 2019 - December 2023 - Period of breaches investigated.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision directly implicates senior accountability and operational failures in core AMC functions, with fines totaling €305,000 showing AMF's willingness to penalize both firms and individuals. It matters amid a pattern of similar sanctions (e.g., €200k on Eres
Asset Manager
Asset management Governance MiFID II remuneration requirements: the AMF applies the ESMA Guidelines
Asset Manager
Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000, and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025, for multiple breaches spanning August 2019 to December 2023, including unauthorized placement of financial instruments as a tied agent, non-operational investment allocation processes, inadequate compliance with investment procedures, deficient conflicts of interest management, and non-operational AML/CFT systems. This decision underscores AMF's strict enforcement of operational compliance and scope limitations for asset managers, serving as a critical reminder for firms to ensure robust, traceable systems and director accountability. It matters because it highlights personal liability for managers and recurring AMF focus on AML/CFT and procedural deficiencies, potentially signaling increased scrutiny in 2026.
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What Changed
This is an enforcement action, not a regulatory change introducing new rules. It reinforces existing obligations under French financial regulations (e.g., Monetary and Financial Code) for asset management companies (AMCs), particularly:
Strict limits on services: AMCs cannot provide placement of financial instruments without a firm commitment basis, even as tied agents; doing so circumvents authorized investment services.
Operational investment systems: Processes for allocating investments betwe
What You Need To Do
- Audit dual roles
- Enhance investment processes
- Strengthen controls
- Director oversight
- Documentation
Key Dates
31 December 2025 - AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier.
August 2019 - December 2023 - Period of breaches investigated.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision aligns with a pattern of AMF fines on AMCs for AML/CFT, procedural, and operational failures (e.g., €200k on Eres Gestion in 2023 for rebates/investments; warnings/fines on Inter Gestion REIM in 2024 for AML). It matters due to director liability, esca
Asset Manager
Sanctions & settlements Asset management Compliance Anti-money Laundering Executive & other private individuals Investment management companies The AMF Enforcement Committee fines a portfolio asset management company and its manager for breaches of their...
The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000 and its managers Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for multiple breaches of professional obligations from August 2019 to December 2023, including unauthorized investment services as a tied agent, non-operational investment allocation processes, deficient conflict-of-interest management, and inadequate AML/CFT systems. This decision underscores AMF's strict enforcement against operational failures in asset management, particularly for firms balancing portfolio management with tied agent roles, emphasizing personal accountability for managers. Compliance teams must review this for gaps in procedures, as it highlights how imprecise processes and poor traceability lead to substantial sanctions.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) for asset managers:
Asset management companies (sociétés de gestion) are restricted to specific investment services; providing placement of financial instruments without firm commitment (as a tied agent) circumvents these limits and is prohibited.
Investment systems must be operational with precise allocation rules between funds;
What You Need To Do
- Audit investment services scope to ensure no unauthorized placement activities, especially if acting as tied agents; cease and remediate any circumventions
- Enhance investment allocation processes with precise rules, full traceability of verifications, and demonstrable operationality
- Strengthen conflict-of-interest frameworks with identification, prevention, and management protocols, including documentation
- Overhaul AML/CFT systems for effective due diligence on clients, assets, and risks; conduct staff training and test operationality
- Review manager accountability
Key Dates
31 December 2025 - AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier.
August 2019 - December 2023 - Period of breaches investigated, covering unauthorized services, investment process failures, conflicts, and AML/CFT deficiencies.
31 December 2025 (exact deadline unspecified; standard AMF appeals must be lodged promptly, typically within 1 month). DEADLINE
Asset Manager
Appointment AMF activity Institutional Journalists Laure Tertrais is appointed Head of the AMF Chair’s Executive Office with effect from 1 April 2023
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Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines the British company H2O AM LLP and two of its executives at the time of the facts for several breaches of their professional obligations
The AMF Enforcement Committee fined UK asset manager H2O AM LLP €75 million and its executives Bruno Crastes (€15 million, plus a 5-year ban) and Vincent Chailley (€3 million) for breaches in managing French UCITS funds, including ineligible Tennor Group investments, liquidity risks, valuation failures, and non-compliance with investment ratios and counterparty limits. This matters as it underscores AMF's strict enforcement on UCITS eligibility, risk management, and prospectus adherence, with cross-border implications confirmed by the Conseil d'État's dismissal of appeals on 13 June 2025. It signals heightened scrutiny on illiquid, unrated assets and "buy & sell back" transactions for EU asset managers.
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What Changed
This is an enforcement decision, not new rules, but it reinforces existing UCITS requirements under French Monetary and Financial Code and AMF regulations:
UCITS investments must exclude illiquid, unrated securities outside prospectus scopes; liquidity risks must be properly assessed to ensure redemption capabilities.
Debt holdings per issuer capped at 10%; counterparty exposure (e.g., 5% limit) must include all relevant transactions like buy & sell backs.
Reliable valuation information required
What You Need To Do
- Review portfolios
- Enhance due diligence
- Strengthen governance
- Depositary checks
- Training/remediation
Key Dates
30 December 2022 - AMF Enforcement Committee decision SAN-2023-01 imposing fines and sanctions.
7 August 2023 - Conseil d'État rejects preliminary constitutionality question.
13 June 2025 - Conseil d'État dismisses appeals (n. 471548, 471744), upholding sanctions and ordering €3,000 costs to AMF.
June 2025 .
Compliance Impact
Urgency: High - Finalized enforcement (June 2025) with massive fines (€93M total) and bans demonstrates AMF's willingness to pursue personal/executive liability for UCITS breaches, especially cross-border. Matters for firms with illiquid strategies, as it amplifies post-2020 liquidity crisis lessons
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Europe & international Savings protection Marie-Anne Barbat-Layani to chair ESMA's Investor Protection Standing Committee
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Governance Sustainable Finance Executive & other private individuals Journalists Listed companies and issuers Social and environmental responsibility, the focus of the AMF's 2022 report on corporate governance and executive compensation of listed companies
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Sanctions & settlements Investment advice Other professionals Journalists Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee sanctioned financial investment advisor DCT (formerly Didier Maurin Finance) and its manager Didier Maurin with a five-year ban from practicing and fines of €150,000 and €200,000 respectively for recommending unauthorized Samoan AIF shares to 64 clients and failing to identify/manage conflicts of interest, including lacking a conflicts register. This decision, upheld by the Conseil d'Etat on 9 September 2024, underscores AMF's strict enforcement of client-best-interest and conflicts obligations under French regulations. It matters as it provides binding guidance on due diligence for product marketing authorization and conflicts procedures, signaling heightened scrutiny on financial investment advisors (FIAs).
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What Changed
This is an enforcement action, not a regulatory change, but it clarifies and reinforces existing obligations for FIAs under AMF rules:
FIAs must verify marketing authorization of recommended products in France before advising clients; recommending unauthorized AIFs breaches competence, care, diligence, and client-best-interest duties.
FIAs require effective, operational procedures for identifying and managing conflicts of interest, including maintaining a conflicts register; failure to do so is
What You Need To Do
- Immediate review
- Conflicts enhancement
- Policy updates
- Documentation
- assess against AMF Position-Recommendation DOC-2021-05 on FIA obligations (https://www
Key Dates
11 April 2022 - AMF Enforcement Committee issues decision SAN-2022-04, imposing bans and fines.
9 September 2024 - Conseil d'Etat judgment (no. 464877) dismisses appeal, upholds sanctions, and orders €1,500 costs each to AMF.
Compliance Impact
Urgency: Medium - Not critical as no new rules or deadlines, but medium due to upheld precedent reinforcing FIA duties amid AMF's pattern of FIA sanctions (e.g., bans/fines in 2022-2025 cases). Matters for FIAs lacking controls, as breaches lead to personal liability, business bans, and fines scalin
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Appointment Institutional AMF activity Other professionals Executive & other private individuals Fintech Market Infrastructures Post-trade Infrastructures Professional investors Journalists Investment services...
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Markets Periodic & ongoing disclosures The AMF has requested the suspension of ORPEA's financial instruments
On October 24, 2022, France's Autorité des marchés financiers (AMF) suspended all financial instruments (shares, debt securities, and related instruments) issued by ORPEA S.A., a major European care homes operator, pending disclosure of material information under the European Market Abuse Regulation. This enforcement action reflects serious governance and disclosure failures at a publicly listed company facing allegations of operational malpractice and undisclosed financial difficulties.
What Changed
The AMF's suspension order represents a temporary halt to all trading in ORPEA's financial instruments across regulated markets. This is a precautionary measure under Market Abuse Regulation (MAR) protocols designed to protect market integrity when material non-public information exists. The suspension was lifted on October 26, 2022, upon market opening, following ORPEA's disclosure of an amicable conciliation procedure and anticipated asset impairments.
The underlying trigger was ORPEA's failu
What You Need To Do
- *For ORPEA (and comparable listed companies)
- *Immediate disclosure obligations
- *Ongoing periodic updates
- *Governance remediation
- *Creditor communication
Key Dates
October 24, 2022 - AMF requests suspension of ORPEA's financial instruments before market opening
October 26, 2022 - Trading resumes upon market opening following ORPEA's disclosure of conciliation procedure and financial restructuring plan
November 8, 2022 - Q3 2022 revenue announcement (after market close)
November 15, 2022 - ORPEA to present detailed transformation plan to market
December 31, 2022 - Anticipated asset impairment recognition date
Compliance Impact
Urgency: CRITICAL
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Governance Europe & international The AMF encourages French participants to provide feedback to ESMA’s call for evidence on the implementation of the Shareholders Rights Directive (SRD 2)
The AMF publication urges French market participants to submit feedback to ESMA's call for evidence evaluating the implementation of the Shareholder Rights Directive II (SRD II), which aims to enhance long-term shareholder engagement, transparency in voting processes, and issuer-shareholder dialogue across the EU/EEA. This matters for compliance teams as it signals ongoing regulatory scrutiny of SRD II transposition and operational compliance, potentially leading to harmonized amendments that could require process updates in shareholder identification, voting transmission, and engagement disclosures. French firms' input can influence future EU rules, mitigating risks of non-compliance with evolving standards.
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What Changed
This AMF notice itself introduces no new regulatory changes; it promotes participation in ESMA's review of SRD II (Directive (EU) 2017/828), implemented via national laws by June 2019 and effective from September 3, 2020. SRD II's core requirements include: shareholder identification without delay, electronic/machine-readable transmission of voting and meeting information along the intermediary chain, confirmation of vote recording/counting, transparency on institutional investor and asset manag
What You Need To Do
- Submit feedback to ESMA
- Review current compliance
- Enhance processes if needed
- Monitor ESMA/EC outputs
Key Dates
June 10, 2019 - EU Member States' transposition deadline for SRD II into national law (e.g., France via law of May 22, 2019). DEADLINE
September 3, 2020 - SRD II go-live date for operational requirements like shareholder identification and voting processes.
October 3, 2022 - European Commission request to ESMA/EBA for SRD II input, contextualizing ESMA's ongoing review.
of 2026 .)
Compliance Impact
Urgency: Medium - SRD II has been live since 2020, so core compliance is established, but ESMA's review could trigger targeted amendments (e.g., operational standardization), especially for French intermediaries handling cross-border flows. This matters for avoiding supervisory findings in ongoing A
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AMF activity AMF Chair: Proposal to appoint Marie-Anne Barbat-Layani
This AMF publication announces a proposal to appoint Marie-Anne Barbat-Layani as Chair of the AMF, France's financial markets authority responsible for investor protection, market supervision, and regulatory enforcement. It matters for compliance professionals because leadership changes at key regulators like the AMF can signal shifts in enforcement priorities, supervisory focus, or policy directions affecting investment firms, asset managers, and market participants across the EU. While not imposing immediate rules, it warrants monitoring for potential impacts on ongoing consultations and governance expectations.
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What Changed
No specific regulatory changes or new requirements are outlined in this publication, as it solely concerns a leadership appointment proposal rather than substantive rule amendments. The AMF's standard process for such proposals involves board review and government ratification, but no alterations to the General Regulation, policies, or compliance obligations are proposed here.
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What You Need To Do
- binding appointment proposal without compliance obligations
- Monitor AMF website (https
- Review existing AMF relationships and prepare for potential shifts in supervisory engagement
- Update internal governance logs noting key regulator personnel changes
Compliance Impact
Urgency: Low – This is a procedural leadership announcement with no immediate regulatory or operational impacts. It matters for long-term strategic planning, as the new Chair could influence AMF's approach to MiFID II implementation, sustainability integration, or enforcement, but firms face no urge
Asset ManagerBroker DealerBank Sustainable Finance AMF activity Journalists Call for candidates: renewal of the members of the Climate and Sustainable Finance Commission
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AMF activity Appointment Journalists End of the term of office of the AMF chairman and interim chairmanship
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Sanctions & settlements Compliance Journalists Investment services providers The AMF Enforcement Committee fines a depositary for breaches of its professional obligations
The AMF Enforcement Committee fined RBC Investor Services Bank France SA (RBC ISBF) €500,000 plus a warning on 20 July 2022 (published 08 January 2026) for breaches as a UCITS and AIF depositary, including 25 confirmed failures in tiered intervention procedures for investment ratio overruns and deficient monitoring of 14 questionable cash flows over 45 months. This decision underscores AMF's strict enforcement of depositary duties under French regulations implementing UCITS/AIFMD, emphasizing robust controls for ratio compliance, cash flow verification, and documentation. It matters for compliance teams as it provides precedent on what constitutes "irregular and deficient" oversight, potentially increasing scrutiny and fines for similar lapses in depositary functions.
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What Changed
This is an enforcement decision, not a new regulation, but it clarifies and reinforces existing depositary obligations under French UCITS/AIFMD rules (e.g., Articles L. 214-7 et seq. Monetary and Financial Code):
Ratio monitoring and intervention: Depositaries must implement tiered procedures for investment/asset composition ratio breaches (e.g., diversification limits); 25 of 28 alleged anomalies were upheld due to redundant but confirmed procedural failures.
Cash flow oversight: Must identify
What You Need To Do
- Review depositary controls
- Enhance cash flow monitoring
- Conduct gap analysis
- Update policies/procedures
- Appeal if applicable
Key Dates
20 July 2022 - AMF Enforcement Committee decision date imposing €500,000 fine and warning on RBC ISBF.
08 January 2026 - Public news release/publication date of the decision.
Compliance Impact
Urgency: Medium – Recent publication (08 January 2026) signals ongoing AMF focus on depositary failings amid H2O-related probes, but stems from 2022 events with no immediate deadlines. Matters because it sets precedents for fine quantum (€500k) on procedural lapses, reinforces liability for cash/rat
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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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AMF activity Appointment Journalists Grégoire Vuarlot is appointed coordinator of the ACPR and AMF Joint Unit starting 1st July 2022
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Institutional AMF activity Appointment Journalists Appointments to the Legal Affairs Directorate and Enforcement Assistance Directorate of the Autorité des Marchés Financiers
This AMF publication announces internal appointments to its **Legal Affairs Directorate** and **Enforcement Assistance Directorate**, signaling potential enhancements in legal oversight and enforcement capabilities within France's financial markets regulator. Compliance professionals should note this as it may indicate a renewed focus on rigorous enforcement of market rules, though it imposes no direct regulatory changes on firms.
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What Changed
There are no regulatory changes, new requirements, or policy updates in this announcement. It solely details personnel appointments within AMF's internal structure, specifically leadership roles in directorates handling legal affairs (e.g., Maxence Delorme as head of Legal Affairs Directorate) and enforcement assistance (e.g., Amélie du Passage as head of Instruction and Enforcement Assistance Directorate). These directorates support AMF's core functions like investigations, inspections, and san
What You Need To Do
- *No specific actions are required for regulated firms, as this does not introduce obligations
- Review ongoing AMF interactions (e
- Update internal AMF contact lists with confirmed governance details from https://www
- Track AMF news releases for enforcement trends at https://www
Key Dates
13 February 2024 - Ministerial order partially renewing AMF Enforcement Committee.
20 February 2024 - Publication of Enforcement Committee appointments.
27 February 2024 - Composition published in Official Journal.
16 October 2023 - Appointment of Sébastien Raspiller as AMF Secretary General.
Compliance Impact
Urgency: Low. This matters peripherally for firms anticipating AMF enforcement, as new leaders in Legal Affairs and Enforcement Assistance could signal stricter scrutiny or faster processing of cases, similar to past leadership transitions (e.g., Secretary General appointment in 2023). However, abse
Asset ManagerBroker DealerBank Sanctions & settlements Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee fined financial investment advisor Séquence 13 and its director Jean-Louis Lehmann €15,000 each and imposed a five-year ban from acting as financial investment advisors in its decision of 19 December 2023, due to failures in client disclosures, justifying remuneration, operating within regulatory limits, and managing conflicts of interest. This enforcement action underscores the AMF's strict enforcement of professional obligations for investment advisors, with personal liability for managers, serving as a deterrent against conduct breaches that harm client interests. Compliance teams should note this as part of a pattern of similar sanctions, emphasizing robust governance and documentation.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces core professional obligations under AMF rules for financial investment advisors (Conseillers en Investissements Financiers, CIFs), including:
Client information on remuneration: Advisors must disclose any remuneration received for advice and justify service improvements relative to that pay.
Regulatory scope compliance: Firms must operate strictly within authorized activities, avoiding unauthorized product recommendations.
What You Need To Do
- Review and enhance policies
- Training programs
- Client file audits
- Governance checks
- Mock inspections
Key Dates
19 December 2023 - AMF Enforcement Committee decision issued, imposing fines and five-year bans on Séquence 13 and Jean-Louis Lehmann.
Compliance Impact
Urgency: High - This decision highlights escalating AMF scrutiny on CIFs, with fines, bans, and personal accountability in multiple recent cases (2022-2025), signaling increased inspection risk and potential for director bans. It matters because failures in basic conduct rules lead to severe, long-t
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Sanctions & settlements Investment advice Other professionals Executive & other private individuals Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee fined a financial investment advisor (FIA) firm and its manager for multiple breaches of professional obligations, including failure to provide mandatory documents, inadequate risk disclosure, poor KYC practices, misleading information, unauthorized placing activities, and improper third-party marketing mandates. This enforcement action underscores the AMF's strict scrutiny of FIAs, emphasizing due care, conflict management, and adherence to status limits, with fines and bans serving as deterrents. Compliance teams should review it for lessons on documentation, client suitability, and outsourcing controls to avoid similar sanctions.
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What Changed
This is an enforcement decision, not a regulatory change, but it reinforces and clarifies existing FIA obligations under French regulations (e.g., AMF General Regulation). Key requirements highlighted include:
Mandatory delivery of initial contact documents, engagement letters, and written reports to clients.
Clear specification of remuneration terms and comprehensive risk information for recommended products.
Thorough KYC to ensure suitability of advice.
Prohibition on misleading information, s
What You Need To Do
- Conduct Documentation Audit
- Enhance KYC and Suitability Processes
- Strengthen Conflicts Framework
- Review Activity Scope
- Training and Monitoring
Key Dates
24 January 2019 AMF Enforcement Committee decision fining Novactifs Patrimoine €250,000 and CEO €100,000 for breaches from March 2014–July 2016.
11 April 2022 AMF Enforcement Committee decision imposing 5-year bans and fines (€150,000 firm, €200,000 manager) on DCT/Didier Maurin Finance; appeal dismissed by Conseil d'Etat on 9 September 2024.
4 November 2024 AMF fines totaling €5,670,000 on FIA Smart Tréso Conseil, asset managers, and CACEIS Bank for fund marketing/management breaches.
5 November 2025 AMF Enforcement Committee decision fining Carat GP and directors €2.5 million total, with permanent/10-year bans (French release: 6 November 2025).
Compliance Impact
Urgency: Medium. This matters as part of a pattern of escalating AMF enforcement against FIAs (fines up to €2.5M, lifetime bans in recent cases), signaling heightened focus on investor protection and governance amid complex products. Firms should prioritize audits now to preempt inspections, but no
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Sanctions & settlements Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee imposed significant sanctions on DCT (formerly Didier Maurin Finance) and its manager Didier Maurin for recommending unauthorized alternative investment funds to clients and obstructing regulatory investigations. This case exemplifies critical compliance failures in product authorization verification and client suitability assessment, with enforcement upheld by France's highest administrative court in September 2024.
What Changed
This enforcement action clarifies several regulatory obligations for financial investment advisors:
Product Authorization Verification: Financial advisors must verify that recommended investment products are authorized for marketing in France before advising clients, regardless of the product's legitimacy in other jurisdictions.
Client Interest Prioritization: Recommending unauthorized products is inherently contrary to client interests and constitutes a breach of the duty to act with competen
What You Need To Do
- *Immediate compliance measures for financial investment advisors:
- *Product Authorization Audit
- *Pre-Recommendation Due Diligence
- *Client Suitability Documentation
- *Regulatory Cooperation Protocol
Key Dates
11 April 2022 - AMF Enforcement Committee issued original decision imposing five-year ban and fines
18 July 2022 - Conseil d'État suspended enforcement of fines pending appeal
9 September 2024 - Conseil d'État dismissed appeal, upholding all sanctions and ordering payment of €1,500 each to AMF
Compliance Impact
Urgency: HIGH
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Appointment Journalists Investment management companies The AMF announces the appointment of Jessica Reyes as Director of the Asset Management Regulation Division
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Sanctions & settlements Journalists The AMF to call for an amendment of the law on obstructing investigations and inspections
The AMF announced its intention to propose legislative amendments to the French Monetary and Financial Code following a January 28, 2022 Constitutional Council decision that found dual prosecution for obstructing AMF investigations and inspections unconstitutional. The amendment aims to eliminate the possibility of simultaneous administrative and criminal penalties for the same obstruction conduct, while preserving the AMF's enforcement authority.
What Changed
The primary regulatory change addresses a constitutional violation regarding dual prosecution under the ne bis in idem principle:
Current problem: The Monetary and Financial Code previously allowed both administrative sanctions by the AMF Enforcement Committee and criminal prosecution for identical obstruction conduct, violating the constitutional prohibition against double jeopardy.
Proposed solution: Legislative amendments will eliminate the possibility of dual prosecution while maintaining
What You Need To Do
- *For compliance professionals and regulated entities:
- *Review cooperation policies
- *Assess ongoing proceedings
- *Monitor legislative developments
- *Counsel on cooperation
Key Dates
January 28, 2022 - Constitutional Council decision declaring dual prosecution unconstitutional
No specific implementation deadline stated - AMF committed to proposing amendments "as soon as possible"
Current status (as of January 2026) - Amendments appear to be in legislative proposal stage; no effective date yet announced
Compliance Impact
Urgency: MEDIUM
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Sanctions & settlements Journalists The AMF Enforcement Committee fines an issuer's Chief Financial Officer for insider dealing
The AMF Enforcement Committee fined an issuer's Chief Financial Officer (CFO) for insider dealing, highlighting the regulator's aggressive enforcement against market abuse by senior executives. This case underscores the personal liability of insiders who trade on privileged information, reinforcing the need for robust internal controls in listed companies. Compliance teams must prioritize insider trading prevention to mitigate similar sanctions risks.
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What Changed
This enforcement action does not introduce new regulatory changes but exemplifies ongoing application of existing Market Abuse Regulation (MAR) rules under EU Regulation 596/2014 and AMF General Regulations, including Articles 223-9 and 221-3 on inside information disclosure and trading bans. It aligns with AMF Position-Recommendation No 2016-08 on managing inside information, emphasizing black-out periods (e.g., 30 days before annual/interim results) and trading restrictions for Persons Dischar
What You Need To Do
- Maintain insider lists and notify affected persons of trading restrictions; train staff on MAR Article 17 (disclosure) and Article 19 (PDMR dealings)
- Strengthen monitoring of gifts, transactions in derivatives/index products, and whistleblowing mechanisms, as urged in AMF/AFA joint guidance
- Ensure PDMR transaction reporting within 3 trading days via AMF portal
- Conduct regular compliance inspections on insider networks and corruption risks, formalizing prohibitions in codes of ethics
Key Dates
3 trading days - PDMRs must report securities transactions to issuer and AMF. DEADLINE
December 4, 2024 - EU Regulation 2024/2809 amending MAR entered into force.
June 5, 2026 - Certain amendments in sample insider policies apply (e.g., Groupe Casino policy).
June 30, 2026 - AMF General Regulation updates effective.
Compliance Impact
Urgency: High - This demonstrates AMF's focus on holding executives accountable, with fines signaling zero tolerance amid rising "insider networks" linked to organized crime, as noted in AMF's 2024 report and 2025 AMF/AFA warnings. Firms face heightened inspection risks, reputational damage, and per
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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
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