Warning Savings protection Miscellaneous assets Warning The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
Why this matters
This warning from the AMF relates to companies offering unauthorized investment products, which poses risks to consumers and requires regulatory action.
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
AI Analysis
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.
Key dates
3 trading days Deadline
- Managers/PDMRs must report securities transactions to issuer and AMF if annual total exceeds €20,000
10 business days Deadline
- Custodians must respond to Euroclear France/AMF requests for shareholder identity on threshold crossings
Suggested considerations
Implement/maintain information barriers per Article 315-1 AMF GR: Identify inside info holders, physically separate entities, prohibit unauthorized disclosure (notify compliance officer for exceptions), and log cross-entity assistance.
Assess information promptly: Disclose inside info "as soon as possible" or delay only if all three MAR conditions met; notify AMF post-delay.
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).
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,...
Major shareholdings disclosure: Persons crossing legal or statutory thresholds in listed companies must declare to the issuer and AMF promptly, based on Article L.
Supporting rules include Article 315-1 AMF GR mandating "information barriers" (walls) for investment firms to control inside information circulation, prohibiting unauthorized disclosure except under...
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., €10-100m fines, 2-year imprisonment). Review disclosure protocols now to avoid similar sanctions, especially amid ESMA/AMF focus on timely transparency.
Long term investment Collective investments Shares Retail investors Journalists Equity investment: intentions on the rise again, driven by young people
Why this matters
This regulatory update discusses a rise in equity investment intentions, particularly among young people. This is relevant for investment management firms, wealth managers, and broker-dealers that serve retail investors.
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
AI Analysis
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.
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
Suggested considerations
Immediate audit: Review client portfolios for unauthorized products (e.g., non-EU AIFs); cease recommendations and notify/remediate affected clients.
Conflicts policy enhancement: Implement/maintain a conflicts of interest register; map all potential conflicts (e.g., personal investments, commissions); test procedures annually with scenarios.
Training and documentation: Mandatory staff training on product authorization checks (e.g., via AMF registers); document all advice with diligence evidence; update compliance manuals per AMF DOC-2017-15.
Monitoring: Enhance pre-approval workflows for recommendations; report material breaches to AMF under Article L.621-18 of Monetary and Financial Code.
Director accountability: Senior managers must evidence personal oversight of compliance.
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...
Conflicts of interest management: CIFs must maintain an effective conflicts register, identify risks (e.g., personal benefits), and implement operational procedures; absence or failure constitutes a...
No aggravating factor for incomplete disclosures on unauthorized products absent specific rules, but core diligence duty remains absolute.
These align with AMF Position-Recommendation DOC-2017-15 on...
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 personal liability for directors, risks business bans, and underscores client-best-interest primacy; non-EU product exposure amplifies fines in cross-border contexts.
Supervision Asset management Journalists Investment management companies The AMF publishes summary of third thematic inspection of asset management companies' cybersecurity systems
Why this matters
This regulatory update from the AMF focuses on the cybersecurity systems of asset management companies, which is relevant for investment management and wealth management firms. The topics covered include operational resilience and technology/cyber risk, which are high priority areas for these types of firms.
Asset management UCIT Collective investments The AMF updates its policy on disclosures by collective investment schemes incorporating non-financial methods
Why this matters
This regulatory update from the AMF focuses on disclosure requirements for collective investment schemes that incorporate non-financial methods, which is relevant for asset managers and wealth managers.
Asset management Changes to CIU authorisation and declaration processes
Why this matters
This regulatory update from the AMF relates to changes in the authorization and declaration processes for Collective Investment Undertakings (CIUs), which are relevant for asset managers.
Asset management Requirements for investment committees and the affiliation of fund managers of asset management companies: the AMF updates its policy
Why this matters
This regulatory update from the AMF (French financial markets authority) focuses on requirements for investment committees and the affiliation of fund managers at asset management companies. It is relevant for asset managers and impacts their governance and licensing/authorization.
Governance Periodic & ongoing disclosures Journalists Listed companies and issuers AMF proposes enhanced investor information when evaluating boards of listed companies
Why this matters
This regulatory update from the AMF proposes enhanced investor information requirements for evaluating the boards of listed companies. This impacts capital markets, wealth management, and investment management firms that are subject to these disclosure rules.
Markets Institutional Market Infrastructures Post-trade Infrastructures Professional investors Journalists Investment services providers Investment management companies Listed companies and issuers The AMF presents...
Why this matters
This regulatory update from the AMF (Autorité des Marchés Financiers) announces the presentation of the 2023 Young Researcher Award to Sylvain Carré. This is an informational update relevant to investment management firms, capital markets participants, and listed companies as it recognizes research contributions in...
Sanctions & settlements Journalists Listed companies and issuers The AMF Enforcement Committee fines Visiomed and its former directors, Éric Sebban and Olivier Hua, for market manipulation. It also fines Negma Group Ltd for breach of its reporting obligations
AI Analysis
The AMF Enforcement Committee imposed fines on Visiomed and its former directors Éric Sebban and Olivier Hua for market manipulation, and on Negma Group Ltd for failing to meet reporting obligations. This enforcement action underscores the AMF's rigorous enforcement of market abuse rules under EU Regulation 596/2014 (MAR), serving as a critical reminder for listed companies, directors, and major shareholders to prioritize compliance with manipulation prohibitions and threshold crossing disclosures. It matters because it demonstrates personal liability for executives and ongoing scrutiny of disclosure failures, potentially influencing enforcement trends in 2026 amid strengthened AMF powers.
Key dates
30 June 2026
- End of MiCA transitional period, with AMF focusing on crypto-asset market abuse alignment (indirect relevance via MAR enforcement)
30 June 2026
- AMF General Regulation updates effective, enhancing MAR-related reporting procedures (e.g., Title V on failings reporting)
Immediate
- Report suspicious transactions (insider dealing or manipulation) to AMF without delay
Suggested considerations
Conduct internal audits: Review past and current communications, trading patterns, and disclosures for manipulation risks or unreported positions.
Enhance monitoring systems: Implement surveillance for market abuse, including automated tools for detecting unusual trading or information dissemination.
Train personnel: Educate directors, compliance teams, and traders on MAR prohibitions and reporting thresholds; report suspicions via AMF forms.
Update policies: Ensure prompt filing of threshold declarations (e.g., within 4 trading days for >5% holdings) and consistency with prospectus rules.
Cooperate with regulators: Prepare for AMF investigations, leveraging potential penalty reductions for early cooperation as per emerging powers.
What changed
This is an enforcement decision rather than new regulatory changes, reinforcing existing requirements under MAR (Regulation (EU) No 596/2014), transposed into AMF's General Regulation (Book VI on market abuse). It highlights prohibitions on market manipulation (e.g., disseminating false or misleading information or engaging in fictitious transactions to influence prices) and mandatory reporting of shareholdings crossing 5% thresholds or changes therein for listed issuers.
Compliance impact
Urgency: High - This action signals intensified personal accountability for executives in market manipulation cases, amid AMF's 2026 focus on market integrity and new tools like expanded data access and injunctions with penalty payments. Firms must act swiftly to fortify controls, as non-compliance risks substantial fines, reputational damage, and bans, especially with AMF's observed rise in "insider networks" and enforcement expansions.
Asset management UCIT The AMF releases a research paper on French bond funds' flow-performance relationship
Why this matters
This regulatory update from the AMF (French financial markets regulator) focuses on research related to the flow-performance relationship of French bond funds, which is relevant for investment management firms, banks, and broker-dealers operating in the French capital markets.
Warning Warning Savings protection Forex and binary options Crypto-assets The AMF and the Paris Public Prosecutor's Office urge retail investors to be extremely vigilant regarding Immediate Connect's fraudulent investment offer in crypto-assets
Why this matters
This is a warning from the AMF and Paris Public Prosecutor's Office about a fraudulent crypto investment offer, which is relevant for crypto firms and all investors. It covers consumer protection and AML/financial crime concerns.
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
AI Analysis
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.
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
Suggested considerations
Conduct gap analysis: Review staff training/qualification records, client assessment processes (questionnaires, scoring, non-interference controls), promotional materials for risk warnings, and disclosure scripts for tied agent status.
Enhance manager oversight: Implement personal accountability frameworks aligning with senior managers' regimes; document diligence/audit trails.
Audit CFD marketing: Ensure all ads comply with CFD retail restrictions (e.g., limited-risk accounts only); test client knowledge processes for robustness.
Training programs: Roll out mandatory training on MiFID II tied agent rules, with pre-hire testing and ongoing monitoring.
Cross-border review: Non-EU principals (e.g., CySEC-licensed) should audit French tied agents for alignment with host-state rules.
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 communications: CFD ads must include prominent risk warnings; bans on promoting non-limited-risk CFD accounts must be followed; banners lacking warnings violate rules.
Status disclosure: Clients/potential clients must be informed of tied agent status and principal's identity upon first contact.
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 intensified audits on client protection in high-risk products, critical for France-facing FX/CFD firms to avoid €100k–€400k fines and 10-year bans, especially post-MiFID II retail curbs.
Sanctions & settlements Journalists The AMF Enforcement Committee fines two individuals for insider dealing breaches
AI Analysis
The AMF Enforcement Committee fined two individuals for insider dealing breaches, highlighting the regulator's focus on prohibiting the use of non-public, price-sensitive information in securities transactions. This enforcement action underscores the AMF's rigorous application of market abuse rules under the Market Abuse Regulation (MAR), serving as a deterrent and educational tool for market participants. Compliance teams should note it as evidence of ongoing scrutiny, with fines reflecting the severity of breaches involving direct trading on inside information.
Suggested considerations
Enhance surveillance: Implement real-time transaction monitoring for atypical patterns (e.g., timing near announcements, high conviction trades), using tools to flag urgency or unusual order methods.
Insider list management: Issuers must diligently maintain/update lists under Article 18 MAR, with PDMR disclosures within 3 business days of transactions.
Training programs: Mandatory annual training on MAR definitions (inside information as precise, non-public data likely to significantly affect prices), disclosure prohibitions, and whistleblower reporting.
Policies and procedures: Update insider trading policies to cover inducement/recommendation chains (e.g., family/partner risks); conduct pre-clearance for PDMR trades.
Audit and testing: Perform annual compliance audits on insider handling, with remediation for gaps; prepare for AMF investigations by documenting justifications for suspicious trades.
What changed
This is an enforcement decision, not a regulatory change; it reaffirms existing requirements under EU MAR (Regulation (EU) No 596/2014), transposed into French law via the French Monetary and Financial Code. Key principles upheld include: (i) prohibition on using inside information for trading (Article 14 MAR), (ii) assessing breaches via indicators like transaction timing, atypical volume, order placement methods, and implausible justifications, and (iii) liability for both primary insiders and those receiving information through plausible channels.
Compliance impact
Urgency: High – While not a rule change, the AMF's frequent enforcement (multiple 2023-2026 cases with fines up to €1M) signals intensified focus on insider dealing amid M&A and earnings seasons, risking reputational damage, personal liability, and business bans. Firms must prioritize surveillance upgrades to mitigate civil/criminal risks, especially with strengthened AMF powers proposed in 2025 legislation.
Long term investment Risk and Trend Mapping Retail investors Professional investors Journalists Investment management companies Listed companies and issuers Gamification tends to increase investment risk-taking, according to behavioural...
Why this matters
This regulatory update discusses the impact of gamification on investment risk-taking behavior, which is relevant for investment management firms, wealth managers, and broker-dealers that serve retail investors.
Sustainable Finance Periodic & ongoing disclosures Journalists Investment services providers Investment management companies Listed companies and issuers The AMF publishes a second educational report on taxonomy reporting by listed companies
Why this matters
This regulatory update from the AMF (French financial markets authority) relates to taxonomy reporting requirements for listed companies, which is relevant for investment management firms and listed companies.
Long term investment Equity Journalists Investment services providers Investment management companies Listed companies and issuers An OECD study for the AMF profiles new French retail investors
Why this matters
This regulatory update profiles new French retail investors, which is relevant for investment management firms, wealth managers, and broker-dealers that serve this client segment. The topics covered include consumer protection, reporting and disclosure, and licensing requirements.
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
Why this matters
This regulatory update from the ACPR and AMF encourages financial institutions to consider the vulnerability of aging clients, which impacts consumer protection, operational resilience, and governance. It is relevant for banks, wealth managers, and the broader financial industry.
Cooperation Fintech Market Infrastructures Post-trade Infrastructures Professional investors Journalists Investment services providers Investment management companies Listed companies and issuers The AMF and the US...
Why this matters
This regulatory update involves a memorandum of understanding (MOU) between the AMF and the US CFTC for the supervision of certain cross-border firms, which is relevant for capital markets, investment management, and firms operating in both jurisdictions.
Asset management Pan-European Personal Pension Products: the AMF complies with EIOPA guidelines
Why this matters
This regulatory update from the AMF relates to the compliance of Pan-European Personal Pension Products with EIOPA guidelines, which is relevant for investment managers and insurance firms offering these products.
Asset management Loans originated by AIFs: the AMF amends its guidelines on reporting requirements
Why this matters
This regulatory update from the AMF (French financial regulator) amends reporting requirements for alternative investment funds (AIFs) that originate loans. This impacts asset managers and banks involved in loan origination activities, requiring changes to their reporting and compliance processes.
Supervision Asset management Compliance Journalists Investment management companies Regulatory reporting by asset management companies: the AMF calls for greater diligence
Why this matters
This regulatory update from the AMF focuses on reporting and compliance requirements for asset management companies, indicating a medium level of urgency for this sector.
Cooperation AMF Chair Marie-Anne Barbat-Layani meets with ASIC Chair Joseph Longo
Why this matters
This regulatory update discusses a meeting between the chairs of the AMF and ASIC, the financial regulators of France and Australia respectively. This indicates cooperation and dialogue between regulators, which is relevant for firms operating in the banking, investment management, and wealth management sectors across...
Fees Savings protection Other professionals Retail investors Journalists Investment services providers The AMF ensures that retail investors are properly informed on fees of financial products
Why this matters
This regulatory update from the AMF focuses on ensuring retail investors are properly informed about the fees of financial products, which impacts investment management firms, wealth managers, and banks that offer these products.
Appointment Institutional AMF activity Other professionals Executive & other private individuals Retail investors Fintech Professional investors Journalists Investment services providers Investment management...
Why this matters
This regulatory update announces the appointment of a new Secretary General at the AMF, the French financial markets regulator. This is an institutional change that impacts various financial firms under AMF's supervision, including asset managers, banks, brokers, and wealth managers.
Warning Warning Savings protection Miscellaneous assets The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
Why this matters
This warning from the AMF relates to unauthorized firms offering atypical investments, which poses risks to consumers and requires regulatory action.
Warning Warning Savings protection Forex and binary options The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Why this matters
This warning from the AMF and ACPR is targeted at entities offering unauthorized Forex and crypto-asset derivative investments in France, which poses risks to consumers and requires regulatory action.
Asset management Investment advice Regime applicable to financial investment advisers: update of Position-Recommendation DOC-2006-23
Why this matters
This regulatory update from the AMF relates to the regime applicable to financial investment advisers, which impacts asset managers and wealth managers. It covers consumer protection and licensing/authorization requirements.
Asset management MIFID Financial services providers MiFID II product governance requirements: the AMF applies the updated ESMA guidelines
Why this matters
This regulatory update from the AMF applies updated ESMA guidelines on MiFID II product governance requirements, which are relevant for investment management firms, broker-dealers, and banks that offer financial products to consumers. The update covers consumer protection, licensing, and reporting obligations.
MiCA Crypto-assets Innovation Markets in crypto-assets: publication of the MiCA regulation
Why this matters
This regulatory update on the publication of the MiCA regulation is highly relevant for firms operating in the crypto-assets and digital assets space, as well as capital markets and payments firms that interact with crypto-assets.
Innovation Markets Decentralised Finance (DeFi): IOSCO publishes its consultation report
AI Analysis
The AMF publication announces IOSCO's consultation report on Decentralised Finance (DeFi), highlighting ongoing global efforts to regulate DeFi activities under IOSCO's 2023 policy recommendations. This matters for compliance professionals as it signals intensifying scrutiny on DeFi platforms for investor protection, market integrity, and financial stability risks, potentially leading to harmonized rules that bridge traditional finance and crypto assets. Firms involved in DeFi must monitor this to align with emerging "same risk, same rule" standards across jurisdictions.
Key dates
31 July 2025
- Cut-off date for assessing Participating Jurisdictions' regulatory frameworks in IOSCO's Thematic Review
October 16, 2025
- Publication date of FSB and IOSCO reports assessing crypto-asset and stablecoin implementation, including DeFi elements
2 February 2026 Deadline
- IOSCO consultation comment deadline on related reports (e.g., FMIs’ management of general business risks)
6 February 2026 Deadline
- CPMI-IOSCO consultation comment deadline on FMIs’ general business risks guidance, relevant to DeFi infrastructure
Suggested considerations
Review and comment: Submit feedback on IOSCO consultations by early February 2026 to influence final guidance on DeFi risks.
Gap analysis: Assess current operations against IOSCO's 10 Assessed Recommendations (e.g., market integrity, investor protection, cross-border cooperation) and FSB frameworks, noting reforms underway.
Enhance compliance: Implement AML mechanisms for DeFi (e.g., on-chain identity attestations), improve cybersecurity, business continuity, and enforcement powers for CASPs.
Monitor cross-border: Leverage IOSCO MMoU for cooperation and prepare for global CASP supervision.
Pilot participation: Explore EU DLT Pilot Regime or similar sandboxes for compliant DeFi activities.
What changed
No immediate binding regulatory changes are introduced, as this is a consultation report tied to IOSCO's 2023 DeFi Recommendations and a 2025 Thematic Review assessing implementation progress. Key focuses include enhanced regulatory cooperation (Recommendation 11), addressing gaps in enforcement for Crypto Asset Service Providers (CASPs), and applying CDA Policy Recommendations to DeFi for risks like financial stability, investor protection, and market integrity. Progress is noted in legal frameworks, but challenges persist in cross-border cooperation and enforcement beyond CASPs.
Compliance impact
Urgency: High – While not yet binding, the report underscores incomplete global implementation (e.g., enforcement gaps, regulatory arbitrage risks), with IOSCO/FSB calling for swift action amid 2025-2026 reviews. This matters as DeFi's growth amplifies systemic risks, prompting "same risk, same rule" enforcement; firms risk non-compliance fines, operational restrictions, or lost innovation opportunities without proactive alignment.
Sanctions & settlements Journalists Listed companies and issuers The AMF Enforcement Committee fines Rallye and its chief executive officer, Franck Hattab, for market manipulation
AI Analysis
The AMF Enforcement Committee sanctioned listed company Rallye and its former CEO Franck Hattab for market manipulation via dissemination of false or misleading information about Rallye's liquidity position on 11 occasions across 14 communications from March 2018 to May 2019, in violation of Articles 12.1(c), 12.4, and 15 of the EU Market Abuse Regulation (MAR). Rallye was fined €25 million and Hattab €1 million due to the repetition of breaches, prior AMF warnings, and potential investor harm from artificially inflated share prices. This case matters as it demonstrates AMF's aggressive enforcement of MAR disclosure rules, holding both issuers and senior executives personally liable for financial communications that misrepresent key risks like liquidity.
Key dates
September 18
19, 2023; - Rallye appeals the AMF decision
2016
- Prior AMF Deputy Secretary General warning to Rallye on financial communication quality, specifically liquidity risk presentation
March 8, 2018
May 15, 2019; - Period of infringing communications (11 occasions, 14 media)
September 2023
(inferred from context) - AMF Enforcement Committee decision imposing fines
Suggested considerations
Review historical/current financial communications for liquidity/debt portrayals; ensure they explicitly address dependencies (e.g., on subsidiary performance) and avoid unqualified positives like "solid liquidity" amid volatility.
Enhance governance: Implement pre-approval processes for CEO/issuer statements on material risks; document awareness of true risk profiles.
Training: Senior managers regime-style programs on MAR personal liability for misleading info, emphasizing repetition risks.
Audit trails: Maintain evidence of internal deliberations on disclosures to defend against "knew or should have known" findings.
Monitor appeals: Track Rallye's challenge, as outcomes may clarify MAR scope (e.g., https://www.marketscreener.com/insider/FRANCK-HATTAB-A1NUTV/ for updates).
What changed
This is an enforcement decision, not a regulatory change; it reinforces existing MAR requirements prohibiting dissemination of false or misleading information likely to artificially affect financial instrument prices. Key interpretations include: (i) describing liquidity as "solid" or "very solid" despite dependency on volatile subsidiary (Casino) shares and hidden risks (e.g., €400-600M liquidity shortfall, concealed loans) constitutes manipulation; (ii) issuers are strictly responsible for communications by representatives like CEOs; (iii) repetition across multiple media (e.g.,...
Compliance impact
Urgency: High - Reinforces personal accountability for executives in debt-heavy listed firms, with fines scaled to repetition and centrality of misrepresented risks (liquidity as Rallye's primary exposure). Matters amid ongoing Casino restructuring (€6.4B debt), signaling AMF scrutiny of retail sector holdings; non-EU firms cross-listed or dealing in French markets face similar MAR exposure via EU-wide rules.
Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
AI Analysis
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.
Key dates
August 2019
December 2023; - Period of breaches investigated, covering investment services, processes, conflicts, and AML/CFT failures
31 December 2025
- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors
08 January 2026
- Public press release date
Suggested considerations
Immediate gap analysis: Review investment procedures for precision, traceability, and operationality; verify authorization of lending entities and service scopes (e.g., no unauthorized placement services).
Enhance AML/CFT: Implement operational risk mapping, systematic due diligence on fund assets/liabilities, and evidence of effectiveness.
Conflicts framework: Formalize identification/prevention processes, especially in multi-role firms (asset manager + tied agent).
Senior manager attestation: Document personal oversight; conduct training on attribution of breaches.
Marketing/retrocessions: Ensure traceability and proof of client benefit (cross-reference with similar findings).
What changed
This is an enforcement action, not a regulatory change, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and compliant; failure to verify or document renders systems non-operational.
Scope of services: Asset managers (and tied agents) cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing licensed activities.
Conflicts of interest: Robust identification, prevention, and management systems are mandatory.
AML/CFT: Due diligence on fund assets/liabilities must be systematic and operational, with effective risk mapping and procedures.
Compliance impact
Urgency: High - This reflects a pattern of 2025 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc Partners 15 Sep 2025; €400k on Eternam 9 Sep 2025), signaling intensified scrutiny post-AIFMD reviews. Matters due to personal liability for managers, appeal risks amplifying precedent, and applicability to hybrid models; non-compliance risks fines scaling to €1M+ and reputational damage.
Sanctions & settlements professional obligations Journalists The AMF Enforcement Committee fines the Association Nationale des Conseillers Financiers-CIF for breaches of its professional obligations
AI Analysis
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.
Key dates
June 2, 2023
- AMF Sanctions Commission hearing where €500,000 sanction was initially sought (reduced in final decision)
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)
Suggested considerations
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.541-8 requirements.
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: Verify personal compliance with association standards to mitigate contagion risks from association sanctions.
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.
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 interest management.
No new requirements were introduced; the case reiterates enforcement of CMF Articles L.541-8 and L.541-8-1 on documentation,...
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 associations and CIFs, amplifying risks for non-compliant entities in a post-MiFID II enforcement environment.
Savings protection Cooperation Crypto-assets Retail investors Fintech Journalists The AMF and the ARPP launch the Responsible Influence Certificate in Finance
Why this matters
This regulatory update announces the launch of a new 'Responsible Influence Certificate in Finance' by the AMF and ARPP, which is likely to impact asset managers, fintechs, and crypto firms that engage in influencer marketing or other forms of digital promotion to retail investors.
Investment services Investment service: amendment of the French definition of reception and transmission of orders
Why this matters
This regulatory update amends the French definition of reception and transmission of orders, which is a core investment service. This impacts investment managers, brokers, and wealth managers who provide this service. The changes relate to authorization, reporting, and consumer protection requirements.
Fixed income Markets Financial services providers The AMF publishes a study on the margins applied by brokers in the French bond market
Why this matters
This regulatory update from the AMF (French financial markets regulator) focuses on the margins applied by brokers in the French bond market, which is relevant for capital markets participants and banks operating in this space. The topics covered include market abuse/surveillance and reporting/disclosure requirements.
Institutional AMF activity Journalists The AMF pays tribute to Jacques Delmas-Marsalet
Why this matters
This regulatory update from the AMF (Autorité des Marchés Financiers) pays tribute to Jacques Delmas-Marsalet, which is likely related to his role and contributions in the financial services industry, particularly in the banking, investment management, and wealth management sectors.
MiCA Crypto-assets Regulatory developments Digital assets: the AMF amends its General Regulation and its policy on DASP in light of enhanced registration and the MiCA Regulation
Why this matters
This regulatory update from the AMF amends its General Regulation and policy on digital asset service providers (DASPs) in light of the upcoming MiCA Regulation. It is relevant for crypto exchanges and fintech firms operating in the digital asset space, as it covers changes to authorization and licensing requirements...
Asset management The Autorité des Marchés Financiers (AMF) announces withdrawal of the authorisation of the portfolio asset management company Quantology Capital Management as of 30 June 2023
Why this matters
This regulatory update from the AMF announces the withdrawal of authorization for the portfolio asset management company Quantology Capital Management, which is relevant for investment management firms and their licensing/authorization status.
Collective investments Asset management The AMF updates its policy on the information to be provided by collective investment schemes incorporating non-financial approaches
Why this matters
This regulatory update from the AMF focuses on the information requirements for collective investment schemes that incorporate non-financial approaches, such as ESG factors.
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations
AI Analysis
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.
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)
Suggested considerations
Review and document operational procedures for fund investments/divestments, including lender authorization checks.
Enhance AML/CFT systems with systematic due diligence on fund assets/liabilities and risk mapping.
Audit fee retrocession arrangements to demonstrate tangible client service improvements (e.g., via evidence of enhanced distribution quality).
Validate marketing materials for accuracy and completeness.
Conduct senior manager attestations on compliance oversight; implement training on personal liability.
What changed
This is an enforcement action, not a regulatory change; it reaffirms and clarifies existing obligations under French financial regulations for asset managers (sociétés de gestion de portefeuille).
Implementing operational procedures for investment/divestment processes, including verification of lender authorizations.
Conducting systematic AML/CFT due diligence on fund assets and liabilities.
Proving that fee retrocessions to distributors enhance client service quality.
Ensuring marketing materials are accurate and compliant.
These align with ongoing AMF expectations for "honest, fair, professional" conduct with requisite skill, care, and diligence.
Compliance impact
Urgency: High - This recent (2025) enforcement demonstrates AMF's willingness to impose multimillion-euro fines (€1.3M total) and hold executives personally accountable for systemic failures in core areas like operations, AML, and client disclosure. It matters for immediate risk as appeals are pending but do not suspend obligations; firms with similar setups face elevated audit risk, especially amid AMF's pattern of targeting asset managers (e.g., 5+ cases in 2024-2025).
Crypto-assets Innovation Market infrastructures Post-trading infrastructures Market infrastuctures on blockchain technology: adaptation of the French securities laws
Why this matters
This regulatory update from the AMF (French financial regulator) relates to the adaptation of French securities laws to accommodate blockchain-based market infrastructures. This is relevant for banks, fintechs, and crypto exchanges operating in the French capital markets and crypto asset space.
Anti-money Laundering Asset management Anti-money laundering and combating the financing of terrorism: the AMF applies the guidelines of the European Banking Authority
Why this matters
This regulatory update from the AMF applies guidelines from the European Banking Authority related to anti-money laundering and combating the financing of terrorism, which is relevant for banking, investment management, and wealth management firms.
Regulatory developments Post-trading infrastructures Market infrastructures Central counterparties’ recovery and resolution: AMF complies with ESMA guidelines
Why this matters
This regulatory update from the AMF relates to central counterparties' recovery and resolution, which is relevant for capital markets, investment management, and wealth management firms that interact with central counterparties.
Long term investment Equity Retail investors Journalists Close to 40% of new equity investors are under 35
Why this matters
This regulatory update discusses trends in equity investing, particularly the growing participation of younger investors. This information is relevant for investment managers, wealth managers, and broker-dealers who serve retail investors.
Crypto-assets Digital assets: the AMF amends its policy on DASPs to clarify the transition to "enhanced" DASP registration
Why this matters
This regulatory update from the AMF (Autorité des Marchés Financiers) in France amends its policy on Digital Asset Service Providers (DASPs) to clarify the transition to an 'enhanced' DASP registration regime.
Professional certification Sustainable Finance The AMF updates its instructions on AMF certification and the sustainable finance module
Why this matters
This regulatory update from the AMF relates to changes in certification requirements and a new sustainable finance module, which is relevant for investment managers, wealth managers, and the broader financial industry.
Long term investment Sustainable Finance Collective investments Retail investors Journalists Sustainable investment: growing interest among French people, especially the youngest
Why this matters
This regulatory update discusses growing interest in sustainable investment among French people, especially the younger generation. This is relevant for investment managers, wealth managers, and the broader financial industry as it indicates increasing demand for sustainable investment products and services.
Innovation Savings protection AMF activity The AMF reinforces the visibility of its blacklists through Open Data
Why this matters
This regulatory update from the AMF (French financial markets authority) relates to the reinforcement of the visibility of its blacklists through open data. This impacts firms in the banking, investment management and wealth management sectors, particularly around consumer protection, reporting requirements and...
Periodic & ongoing disclosures Sustainable Finance Regulatory developments The AMF responds to the European Commission’s public consultation on the draft European sustainability reporting standards
AI Analysis
The AMF's response to the European Commission's public consultation advocates for simplified European Sustainability Reporting Standards (ESRS) under the CSRD, emphasizing retained quality in climate reporting, interoperability with ISSB standards, and proportionality while opposing overly complex materiality assessments. This matters for compliance professionals as it signals upcoming ESRS revisions that could reduce reporting burdens but maintain investor-focused disclosures, influencing 2026-2028 sustainability statements for listed firms and financial institutions. https://www.amf-france.org/en/news-publications/news/amf-responds-european-commissions-public-consultation-draft-european-sustainability-reporting
Key dates
July 31, 2025
EFRAG submits simplified ESRS draft for consultation. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
EFRAG presents technical advice to European Commission. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
Voluntary use of simplified standards possible if legislative timeline allows. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european ; https://www.amf-france.org/en/news-publications/depth/csrd-sustainability-reporting
Suggested considerations
Review and refresh double materiality assessments using "gross" impacts, specifying risks/opportunities per topic.
Retain "net-zero" definitions in climate plans if used; prepare quantitative climate financial effects data (Option 1).
Evaluate "undue costs" reliefs for non-climate metrics, documenting with time-bound justifications.
Monitor EFRAG/EC updates post-November 2025; test voluntary simplified ESRS in 2026 cycles.
What changed
- Simplified ESRS Structure: EFRAG's draft reduces mandatory datapoints by 57-71% and ESRS length by 55%, focusing on materiality, fair presentation, and quantitative data while streamlining double...
Materiality Assessment: AMF opposes assessing impact materiality post-mitigation (prefers "gross" approach for relevance and consistency) but supports specifying impacts, risks, or opportunities per...
Climate Reporting: AMF regrets removal of "net-zero" target definition (requiring 90-95% gross GHG reduction trajectory) and seeks harmonization for financial actors; supports Option 1 for...
Reporting Reliefs: Introduces "undue costs or efforts" exemptions (e.g., for metrics except Scope 3 GHG), with AMF recommending time-bound limits; further simplification proposed for social metrics...
Interoperability: AMF stresses alignment with ISSB, accepting some EU-specific divergences for simplification.
Compliance impact
Urgency: Medium – Revisions offer relief (e.g., 57%+ datapoint cuts) but require proactive preparation for voluntary 2026 use and mandatory 2027/2028; critical for 2025 reporters under current ESRS/"quick fix" to avoid enforcement. Matters due to AMF/ESMA supervision ramp-up, investor demands for comparable climate data, and ISSB alignment risks if divergences grow.
Risk and Trend Mapping Markets Europe & international Asset management Other professionals Market Infrastructures Journalists Investment services providers Investment management companies Listed companies and issuers ...
Why this matters
This regulatory update from the AMF covers a range of topics related to investment management, capital markets, and asset management. It includes information on risk and trend mapping, as well as issues around ESG, market abuse, and reporting and disclosure.
Warning Warning Savings protection Forex and binary options The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Why this matters
This warning from the AMF and ACPR relates to unauthorized entities offering investments in Forex and crypto-asset derivatives in France, which poses risks to consumers and requires regulatory action.
Warning Warning Savings protection Miscellaneous assets The AMF warns the public against companies proposing atypical investments without being authorised to do so
Why this matters
This warning from the AMF is directed at companies offering atypical investments without proper authorization, which poses risks to consumers and requires prompt action by regulators.
MAR Anti-money Laundering Pump-and-dump practice: market manipulation sanctioned by the Paris Tribunal Correctionnel
AI Analysis
The Paris Tribunal Correctionnel sanctioned a pump-and-dump market manipulation scheme, where perpetrators artificially inflated small-cap stock prices via social media hype before selling off, violating France's Market Abuse Regulation (MAR). This enforcement action by the AMF underscores aggressive judicial backing for anti-manipulation efforts, signaling heightened scrutiny on coordinated trading schemes, especially in illiquid assets. Compliance teams must prioritize surveillance enhancements to mitigate similar risks amid rising digital promotion tactics.
Key dates
30 December 2024
- MiCA mandatory licensing for CASPs; pre-registered PSANs enter 18-month transition
30 June 2026 Deadline
- End of PSAN transitional period; full MiCA authorization required, with AMF oversight on manipulation risks
Suggested considerations
Enhance market abuse surveillance systems to detect coordinated trading, unusual volume spikes, and social media-driven hype in small-cap/illiquid assets.
Implement staff training on recognizing pump-and-dump indicators, such as group chats luring investors with upside promises .
Review client communications policies to block manipulative promotions; report suspicions under MAR Article L.634-1 procedures .
For crypto firms, align with "enhanced" DASP registration and MiCA AML/CFT compliance to preempt manipulation sanctions .
Conduct internal audits of trading patterns and escalate to AMF if risks identified.
What changed
This is an enforcement decision rather than new legislation, reinforcing existing prohibitions under Regulation (EU) No 596/2014 (MAR) against market manipulation, including pump-and-dump tactics like false information dissemination and artificial price inflation . No novel regulatory requirements are introduced, but it exemplifies AMF's collaboration with courts for criminal sanctions, potentially increasing deterrence through public naming and fines. Related AMF General Regulation updates effective 30/06/2026 integrate MAR references and strengthen reporting of failings .
Compliance impact
Urgency: High - This case demonstrates swift judicial enforcement (Tribunal Correctionnel conviction), amplifying personal liability for individuals in manipulation schemes and pressuring firms to bolster pre-trade/post-trade surveillance. It matters amid MiCA deadlines, as unlicensed crypto operators risk exclusion post-2026, with pump-and-dump flagged as a key abuse vector . Non-compliance invites AMF inspections, fines, and reputational damage in a litigious environment.
Supervision Asset management Journalists Investment management companies The AMF examines the systems for valuation of the less liquid assets of UCITS and AIFs
Why this matters
This regulatory update from the AMF examines the valuation systems for less liquid assets held by UCITS and AIFs, which are relevant for investment management and wealth management firms. It touches on prudential and operational resilience considerations around asset valuation.
Annual report Savings protection Marketing Financial products Retail investors Journalists The ACPR and AMF Joint Unit for Insurance, Banking and Retail Investment publishes its 2022 annual report
Why this matters
This regulatory update covers the annual report from the joint unit of the French financial regulators ACPR and AMF, which oversees insurance, banking, and retail investment.
Annual report Institutional Strategy AMF activity Retail investors Post-trade Infrastructures Journalists Investment management companies Listed companies and issuers Impact 2027: six main strategic guidelines for...
Why this matters
This regulatory update from the AMF covers strategic guidelines for 2023-2027 that impact investment management companies, wealth managers, and banks. The key focus areas are consumer protection, ESG/sustainability, and reporting/disclosure requirements.
Warning Warning Savings protection Forex and binary options Crypto-assets The AMF warns the public about the fraudulent investment offers in Forex and crypto-assets by Immediate Connect
Why this matters
This regulatory update from the AMF warns the public about fraudulent investment offers in Forex and crypto-assets by the firm Immediate Connect. This falls under the banking/credit and crypto/digital assets sectors, with implications for consumer protection and authorization/licensing requirements for crypto firms...
Sanctions & settlements Journalists Investment services providers By two decisions, the AMF Enforcement Committee fines two investment services providers for breaches of their professional obligations
AI Analysis
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.
Key dates
19 June 2023
- AMF Enforcement Committee decisions issued, imposing fines and warnings
Suggested considerations
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.
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 investment advisory activities.
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 are deficient.
Periodic & ongoing disclosures Sustainable Finance The AMF supports issuers in implementing new sustainability reporting obligations
Why this matters
This regulatory update from the AMF focuses on new sustainability reporting obligations for issuers, which is relevant for asset managers, banks, and other financial firms more broadly.
Crypto-assets Innovation Fintech Journalists The AMF publishes a discussion paper on Decentralised Finance (DeFi)
AI Analysis
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, published a discussion paper on June 19, 2023, outlining preliminary thoughts on regulatory challenges posed by Decentralised Finance (DeFi) activities on crypto-assets, inviting stakeholder feedback by September 30, 2023. A summary of responses was released on July 10, 2024, highlighting key themes like defining DeFi, distinguishing protocol types, and applying a "same activity, same risk, same regulation" principle. This matters for compliance professionals as it signals AMF's intent to develop proportionate DeFi oversight, balancing innovation with investor protection, AML/CTF risks, and market integrity amid evolving EU frameworks like MiCA.
Key dates
June 19, 2023
- AMF publishes initial discussion paper on DeFi regulatory issues
September 30, 2023 Deadline
- Deadline for stakeholder contributions to the discussion paper
July 10, 2024
- AMF publishes summary of responses to the discussion paper
Suggested considerations
Submit feedback (past deadline): Stakeholders could contribute by September 30, 2023, to innovation@amf-france.org.
Monitor developments: Track AMF/ACPR follow-ups, including smart contract certification discussions.
Conduct internal assessments: Analyze DeFi exposures using IOSCO criteria—identify responsible persons, risks (operational, AML/CTF), interconnections with TradFi, and ensure disclosures/conflict management.
Enhance compliance programs: Prepare for proportionate rules on governance, cybersecurity, solvency, transparency; align with "same risk, same regulation" for DeFi-like activities.
Engage stakeholders: Participate in AMF ecosystem dialogues at French/EU/international levels.
What changed
This is a discussion paper and consultation, not binding legislation, so no immediate regulatory changes or requirements are imposed. Key discussion points include:
Defining DeFi based on decentralization criteria (e.g., automation, network architecture, governance, lack of single points of failure).
Distinguishing permissioned vs. permissionless protocols and public vs. private blockchains.
Regulatory approaches to smart contracts (e.g., certification, varying responsibilities), open-source code, and governance.
Urgency: Medium – This is non-binding consultation feedback without hard deadlines or rules, but it previews AMF's regulatory trajectory toward DeFi oversight, including AML/CTF enforcement and investor safeguards, amid MiCA rollout. It matters because DeFi's growth amplifies risks like pseudonymity-driven financial crime and market abuse, potentially triggering enforcement of existing laws; firms risk non-compliance if unprepared for "same risk, same regulation" application, especially with AMF's international push.
Financial services providers Asset management Marketing European Crowdfunding Services Providers: the AMF publishes a position on marketing communications
Why this matters
This regulatory update from the AMF (French financial regulator) is focused on marketing communications for European Crowdfunding Service Providers, which are relevant for asset managers, broker-dealers, and fintech firms operating in the crowdfunding space.
Investment advice MIFID Asset management MiFID II suitability assessment: the AMF applies the updated ESMA guidelines
Why this matters
This regulatory update from the AMF applies the updated ESMA guidelines on suitability assessments under MiFID II, which is relevant for investment firms providing investment advice and portfolio management services.
Asset management Employee savings funds: the AMF amends its policy on the simplified integration of liquidity management tools
Why this matters
This regulatory update from the AMF (French financial markets authority) amends its policy on the simplified integration of liquidity management tools for employee savings funds, which are investment vehicles for employee retirement savings.
Supervision Asset management Sustainable Finance Journalists Investment management companies The AMF publishes a summary on the internal processes that aim to ensure compliance with non-financial contractual commitments by asset management companies of ESG/SRI funds
Why this matters
This regulatory update from the AMF (French financial markets authority) focuses on the internal processes that asset management companies must have in place to ensure compliance with the non-financial commitments of their ESG/SRI funds.
Mediation Annual report Retail investors Journalists Investment services providers Investment management companies Listed companies and issuers The AMF Ombudsman publishes her 2022 Annual Report
Why this matters
This regulatory update from the AMF Ombudsman covers topics related to investment services, investment management, and listed companies. It is an informational annual report, so the urgency is low.
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
AI Analysis
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.
Key dates
August 2019
December 2023; - Period of breaches investigated
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)
Suggested considerations
Review and enhance tied agent activities to ensure no unauthorized investment services like non-firm commitment placements; map against permitted services list.
Audit investment allocation systems for precision, operationality, and traceability; implement verifiable verifications.
Strengthen AML/CFT frameworks: ensure due diligence is adequate, systems are operational, and staff training is regular.
Update conflicts of interest policies with clear identification, prevention, and management procedures.
Conduct senior manager attestations on personal oversight; perform gap analysis against this and similar cases (e.g., Eres Gestion, Inter Gestion).
What changed
This is an enforcement decision, not a new regulation, but it reinforces and clarifies existing requirements under French Monetary and Financial Code (e.g., Article L.
Asset management companies (AMCs) acting as tied agents cannot provide placement of financial instruments without a firm commitment basis, as this exceeds the restrictive list of permitted investment...
Investment allocation processes must be precise, operational, and traceable, with demonstrated compliance to investment procedures.
Firms must maintain effective systems for conflicts of interest identification/prevention, AML/CFT (including adequate due diligence), and overall operational controls.
These align with patterns in...
Compliance impact
Urgency: High - This recent (Dec 2025) decision directly implicates senior accountability and operational failures in core AMC functions, with fines totaling €305,000 showing AMF's willingness to penalize both firms and individuals. It matters amid a pattern of similar sanctions (e.g., €200k on Eres in 2023 for procedures/investor info; warnings/fines on Inter Gestion in 2024 for AML), indicating heightened 2026 enforcement risk; non-compliant firms risk fines, reputational damage, and manager bans, especially if dually registered.
Regulatory developments Post-trading infrastructures Market infrastructures Central counterparties’ recovery plan: AMF complies with ESMA guidelines on recovery plan indicators and scenarios
Why this matters
This regulatory update from the AMF relates to central counterparties' recovery plans, which is relevant for capital markets, post-trading, and market infrastructure firms. It covers prudential and operational resilience topics that are important for banks, broker-dealers, and other financial firms.
Asset management Governance MiFID II remuneration requirements: the AMF applies the ESMA Guidelines
Why this matters
This regulatory update from the AMF applies the ESMA Guidelines on MiFID II remuneration requirements, which are relevant for asset managers. It covers prudential and governance aspects related to remuneration policies and practices.
Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
AI Analysis
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.
Key dates
August 2019
December 2023; - Period of breaches investigated
31 December 2025
- AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier
Suggested considerations
Audit dual roles: Review tied agent activities to ensure no unauthorized placement services; cease any circumvention of AMC service restrictions.
Enhance investment processes: Implement precise, operational rules for fund investment allocation, with full traceability of due diligence and verifications.
Strengthen controls: Update conflicts of interest frameworks, AML/CFT systems (including due diligence, training, and risk assessments), and compliance monitoring to ensure operational effectiveness.
Director oversight: Responsible managers must demonstrate active supervision; conduct gap analyses attributing breaches to governance failures.
Documentation: Maintain auditable records for all procedures; test systems for operationality via internal audits.
What changed
This is an enforcement action, not a regulatory change introducing new rules. It reinforces existing obligations under French financial regulations (e.g., Monetary and Financial Code) for asset...
Strict limits on services: AMCs cannot provide placement of financial instruments without a firm commitment basis, even as tied agents; doing so circumvents authorized investment services.
Operational investment systems: Processes for allocating investments between funds must be precise, with full traceability of verifications.
Conflicts of interest: Firms must identify, prevent, and manage conflicts effectively.
AML/CFT: Systems must be fully operational, with adequate due diligence (e.g., client identification, PEP screening).
Compliance impact
Urgency: High - This recent (Dec 2025) decision aligns with a pattern of AMF fines on AMCs for AML/CFT, procedural, and operational failures (e.g., €200k on Eres Gestion in 2023 for rebates/investments; warnings/fines on Inter Gestion REIM in 2024 for AML). It matters due to director liability, escalating fines (up to €200k+), and AMF's educational role in clarifying regulations, risking similar actions for non-compliant firms in 2026 amid AIFMD 2.0 focus.
Asset management Sustainable Finance Organisational rules Reporting under Article 29 of the Energy-Climate Law: the AMF updates its policy on how to prepare and submit reports
Why this matters
This regulatory update from the AMF relates to reporting requirements under Article 29 of the Energy-Climate Law, which impacts investment management and wealth management firms. The update provides guidance on how to prepare and submit these reports, which is relevant for ESG and sustainability reporting.
Innovation Markets Derivatives or structured products The AMF revises position limits applicable to agricultural commodity derivatives
Why this matters
This regulatory update from the AMF revises position limits applicable to agricultural commodity derivatives, which is relevant for capital markets participants and firms trading these products. It touches on market abuse and surveillance topics.
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...
AI Analysis
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.
Key dates
August 2019
December 2023; - Period of breaches investigated, covering unauthorized services, investment process failures, conflicts, and AML/CFT deficiencies
31 December 2025
- AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier
Suggested considerations
Audit investment services scope to ensure no unauthorized placement activities, especially if acting as tied agents; cease and remediate any circumventions.
Enhance investment allocation processes with precise rules, full traceability of verifications, and demonstrable operationality.
Strengthen conflict-of-interest frameworks with identification, prevention, and management protocols, including documentation.
Overhaul AML/CFT systems for effective due diligence on clients, assets, and risks; conduct staff training and test operationality.
Review manager accountability: responsible managers should self-assess oversight of compliance functions.
What changed
This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) for asset managers:
Asset management companies (sociétés de gestion) are restricted to specific investment services; providing placement of financial instruments without firm commitment (as a tied agent) circumvents...
Investment systems must be operational with precise allocation rules between funds; lack of traceability in verifications violates due diligence obligations.
Firms must maintain effective conflict-of-interest identification, prevention, and management processes.
AML/CFT systems require operational due diligence, including adequate client and asset verification; deficiencies here trigger sanctions.
These align with prior AMF positions but clarify enforcement...
Savings protection Equity Savings Plan Shares Long term investment Retail investors Journalists Investment services providers Listed companies and issuers Equity savings plans : the AMF working group proposes avenues for...
Why this matters
This regulatory update from the AMF (Autorité des Marchés Financiers) in France focuses on proposed improvements to equity savings plans, which are investment products targeted at retail investors.
Supervision MIFID Financial services providers Other professionals Journalists Investment services providers Provision of market data: the AMF conducts a series of SPOT inspections and identifies shortcomings in compliance with requirements
Why this matters
The regulatory update indicates that the AMF conducted inspections and identified shortcomings in compliance with market data requirements, which impacts investment management firms, broker-dealers, and wealth managers that provide market data services. This requires medium urgency attention to ensure compliance.
MiCA Crypto-assets Innovation Crypto-asset markets: the MiCA regulation adopted by the European Parliament
Why this matters
This regulatory update on the MiCA regulation adopted by the European Parliament is highly relevant for crypto-asset firms and fintechs, as it introduces new authorization and licensing requirements, consumer protection measures, and market abuse rules for crypto-asset markets.
Asset management The Autorité des Marchés Financiers (AMF) has withdrawn the authorisation of the portfolio asset management company Quantology Capital Management
Why this matters
This regulatory update from the AMF involves the withdrawal of authorization for a portfolio asset management company, which is relevant to the investment management and capital markets sectors. The key topics are authorization/licensing and prudential/capital requirements for asset managers.
Long term investment Equity Savings Plan Retail investors Journalists Slight recovery of retail investor activity in the stock market
Why this matters
This regulatory update discusses a slight recovery in retail investor activity in the stock market, which is relevant for asset managers, broker-dealers, and wealth managers that serve retail clients. The topics covered include consumer protection, market abuse, and reporting/disclosure requirements.
Financial disclosures & corporate financing The AMF makes available to listed companies the English version of its recommendations and the results of its examination work of the financial statements
Why this matters
This regulatory update from the AMF provides English versions of its recommendations and examination work related to the financial statements of listed companies.
MMF Asset management Regulatory developments The AMF complies with the ESMA guidelines on updating stress test scenarios in accordance with Article 28 of the Money Market Fund Regulation for 2023
Why this matters
This regulatory update is relevant for asset managers of money market funds, as it covers compliance with ESMA guidelines on stress test scenarios under the Money Market Fund Regulation. This impacts the prudential and reporting requirements for these firms.
Warning Warning Savings protection Forex and binary options The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Why this matters
This warning from the AMF and ACPR is directed at entities offering unauthorized Forex and crypto-asset derivative investments in France, which poses risks to consumers and requires regulatory action.
Appointment AMF activity Institutional Journalists Laure Tertrais is appointed Head of the AMF Chair’s Executive Office with effect from 1 April 2023
Why this matters
This is an announcement of a new appointment at the AMF, the French financial markets regulator. It is informational in nature and does not require immediate action from firms.
Collective investments Shares The AMF presents its proposals to improve the readability of financial product fees in European law
AI Analysis
The Autorité des Marchés Financiers (AMF, France's financial markets authority) has proposed a new table for presenting subscription fees on financial instruments and an accompanying glossary to enhance investor readability and comparability, developed in collaboration with the Financial Sector Consultative Committee (FSCC) as input to the European Commission's Retail Investment Strategy. This matters because it targets reconciling MiFID 2 and PRIIPs disclosure requirements, which currently hinder clear fee communication, potentially influencing future EU-level amendments to improve retail investor protection without imposing new obligations.
Suggested considerations
Monitor and Respond: Review the proposed table and draft glossary (available in French); consider submitting feedback via FSCC or directly to European Commission consultations on Retail Investment Strategy.
Internal Review: Assess current MiFID 2/PRIIPs fee disclosures for compatibility with the proposed format; prepare for potential regulatory evolution by mapping existing presentations to the new table.
Testing and Training: Evaluate glossary integration into client communications; conduct internal consumer testing aligned with AMF tools if adopting early.
No immediate obligations, as this is a non-binding proposal requiring EU law changes.
What changed
- Alternative Fee Presentation Table: A proposed redesigned table for displaying costs associated with subscribing to financial instruments, emphasizing investor understanding rather than adding a...
Glossary of Terms: A harmonized glossary defining key fee types, tested with non-professional investors using AMF consumer testing tools, to standardize terminology across professionals and aid...
No changes to fee calculation methodologies; focus is solely on presentation and terminology.
Compliance impact
Urgency: Medium – This is a consultative proposal without firm deadlines or binding rules, but it signals likely EU-level shifts in fee disclosure under MiFID 2/PRIIPs, impacting retail investor-facing firms. It matters for proactive compliance, as early adoption of clearer formats could mitigate future enforcement risks amid Retail Investment Strategy scrutiny, especially given AMF's history of fee doctrine updates (e.g., turnover fee bans).
Sustainable Finance Asset management Sustainable Finance Disclosure Regulation: the AMF publishes a study on classifications and fossil fuel exposure in the French funds universe
Why this matters
This regulatory update from the AMF (French financial markets regulator) is focused on the Sustainable Finance Disclosure Regulation (SFDR) and the classification and fossil fuel exposure of French investment funds.
Employee savings scheme Long term investment Collective investments Retail investors Professional investors Journalists Employee savings: a sharp increase in awareness and ownership of employee savings schemes; support for employees and company managers...
Why this matters
This regulatory update discusses trends in employee savings schemes, including increased awareness and ownership. It is relevant for investment managers, wealth managers, and all firms that offer or manage employee savings products.
Sanctions & settlements Journalists The AMF Enforcement Committee fines the head of consolidation of a listed company for insider dealing
AI Analysis
The AMF Enforcement Committee fined the head of consolidation at a listed company for insider dealing, highlighting the regulator's aggressive enforcement against misuse of privileged information by senior finance personnel. This case underscores the personal liability of executives with routine access to inside information and reinforces the need for robust internal controls in listed entities. Compliance teams should prioritize this as a reminder of heightened scrutiny on insider networks and trading restrictions.
Key dates
December 4, 2024
EU Regulation 2024/2809 enters into force; , amending MAR on inside information and disclosures
June 5, 2026
Certain amendments to insider trading policies apply; (e.g., in Groupe Casino policy)
June 30, 2026
AMF General Regulation updates take effect; , covering prospectuses and admissions
Within 3 trading days Deadline
PDMRs must report transactions; to issuer and AMF
Suggested considerations
Enhance insider lists and training: Maintain updated lists of permanent/occasional insiders; train on MAR Article 7/17 prohibitions, including risks of "insider networks" linked to organized crime.
Implement/enforce black-out periods: Prohibit trading 30 days before annual/interim results and 15 days before quarterly info for executives and insiders; notify via Insider Trading Committee.
Strengthen policies on gifts/invitations and whistleblowing: Formalize in codes of ethics; monitor for corruption risks in information sharing.
Monitor and report transactions: PDMRs and related persons report within 3 days; firms oversee compliance function role in breaches.
Conduct risk assessments: For consolidation teams' access to inside info; integrate AMF/AFA joint vigilance calls.
What changed
This is an enforcement decision, not a regulatory change, but it aligns with ongoing Market Abuse Regulation (MAR) requirements under EU rules transposed in France, including Article 17 prohibitions on insider dealing. No new requirements are introduced; it exemplifies application of existing rules like black-out periods (30 days before annual/interim results, 15 days for quarterly) and trading bans for insiders, as recommended by AMF Position-Recommendation No 2016-08.
Compliance impact
Urgency: High – This demonstrates AMF's focus on executive accountability in insider dealing, amid rising "insider networks" concerns noted in 2024/2025 reports, with joint AMF/AFA warnings amplifying detection risks. Firms face fines, reputational damage, and procedural enhancements under strengthened AMF powers (e.g., 2025 Labaronne bill), making immediate policy reviews essential for listed entities.
Long term investment Equity Retail investors Professional investors Journalists The AMF has produced the standard profile of active investors in 2022
Why this matters
This regulatory update from the AMF provides information on the standard profile of active investors in 2022, which is relevant for investment management firms, wealth managers, and broker-dealers that serve retail and professional investors.
Sustainable Finance Publication by the Climate and Sustainable Finance Commission: climate resolutions
Why this matters
This regulatory update from the AMF's Climate and Sustainable Finance Commission relates to climate resolutions, which is relevant for banking, investment management, and wealth management firms from an ESG and disclosure perspective.
Sustainable Finance Executive & other private individuals Journalists Listed companies and issuers Shareholder dialogue on environmental and climate issues
Why this matters
This regulatory update discusses shareholder dialogue on environmental and climate issues, which is relevant for banking, investment management, and capital markets firms, as well as listed companies. The key topics covered are ESG/sustainability, reporting and disclosure, and shareholder engagement.
MIFID Supervision Retail investors Journalists Mystery shopping campaign to bank branches: progress made in the questioning to client, improvements needed in the information provided
Why this matters
This regulatory update from the AMF focuses on a mystery shopping campaign to bank branches, which is relevant for banking, investment management, and wealth management firms. The key topics covered are consumer protection, reporting and disclosure requirements, and authorization and licensing.
Warning Warning Savings protection Forex and binary options The AMF warns the public about fraudulent investment offers through trading robots
Why this matters
This regulatory update from the AMF warns the public about fraudulent investment offers through trading robots, which impacts firms in the banking, investment management, and wealth management sectors. It relates to consumer protection, authorization and licensing requirements, and technology/cyber risks.
AMF activity Asset management Contributions payable to the AMF: a new complaints form for a more effective follow-up
Why this matters
This regulatory update from the AMF relates to a new complaints form for contributions payable to the AMF, which impacts asset managers and wealth managers in the investment management and wealth management sectors. It is focused on consumer protection and reporting/disclosure requirements.
Innovation Markets AI enthusiasts, the AMF challenges you
Why this matters
This regulatory update from the AMF (Autorité des Marchés Financiers) in France is focused on innovation and AI in the financial services sector, particularly targeting asset managers, wealth managers, and fintech firms. The key topics covered include technology/cyber, authorization/licensing, and consumer protection.
Innovation Market infrastructures Post-trading infrastructures Market infrastructures on blockchain: Application of the EU DLT Pilot Regime from March 23rd
Why this matters
This regulatory update discusses the application of the EU DLT Pilot Regime, which is relevant for capital markets and crypto/digital asset firms. It covers technology and authorization/licensing topics, so it is of medium urgency for fintechs and crypto exchanges.
Asset management Anti-money Laundering Anti-money laundering and combating the financing of terrorism: the AMF applies the guidelines of the European Banking Authority
Why this matters
This regulatory update from the AMF applies guidelines from the European Banking Authority related to anti-money laundering and combating the financing of terrorism, which is relevant for investment managers, banks, and wealth managers.
Asset management Anti-money Laundering Money Laundering and Terrorist Financing: update of the COLB’s National Risk Assessment
Why this matters
This regulatory update from the AMF focuses on the national risk assessment for money laundering and terrorist financing, which is relevant for investment management and wealth management firms that need to comply with AML/CFT requirements.
Sanctions & settlements professional obligations Investment advice Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined financial investment advisor Capexis €120,000 on 15 February 2023 for breaches including receiving prohibited payments from client loan repayments and failing to disclose commissions from SCPI usufruct subscriptions, with the Conseil d'Etat later increasing the fine to €150,000 on 3 March 2025. This enforcement action underscores AMF's strict oversight of **financial investment advisors (Conseillers en Investissements Financiers - CIFs)** on professional obligations like payment restrictions and transparency. It matters for compliance as it highlights personal liability risks and the educational role of such decisions in clarifying regulations.
Key dates
15 February 2023
- AMF Enforcement Committee decision imposing €120,000 fine on Capexis
3 March 2025
- Conseil d'Etat judgment increasing fine to €150,000, overturning some findings, and ordering publication on AMF website
Suggested considerations
Review payment structures: Audit all client interactions for prohibited receipts (e.g., loan repayments, indirect commissions); ensure only advisory fees are collected.
Enhance disclosure policies: Implement mandatory client notifications on commissions, including SCPI or similar structures, with documented evidence.
Conduct gap analysis: Assess compliance with best interests duty, conflict identification, and product authorization; maintain registers and procedures.
Training and monitoring: Train staff on CIF obligations; monitor for similar breaches in fund marketing or client lending.
Prepare for inspections: Ensure diligence in cooperating with AMF inspectors, as non-cooperation can lead to sanctions.
What changed
This is an enforcement decision, not a new regulation, but it reinforces existing requirements under French financial regulations for CIFs:
Prohibition on non-remunerative payments: CIFs cannot receive payments beyond fees for advisory services, such as loan repayments from clients.
Commission disclosure: CIFs must inform clients of the nature, amount, or calculation method of any commissions received in connection with investment advice, e.g., from SCPI usufruct arrangements.
No aggravating factor for incomplete information on unauthorized marketing absent specific provisions, but core duty to ensure authorized products and act in clients' best interests remains paramount...
Compliance impact
Urgency: High - This matters due to escalating fines (e.g., €120k to €150k on appeal), permanent/temporary bans in parallel cases, and director liability up to €2m. Recent 2024-2025 enforcements signal AMF's intensified focus on CIF misconduct amid fund scandals, risking reputational damage and operational bans for non-compliant firms. Immediate policy reviews are essential to avoid similar outcomes.
EMIR Termination of membership towards Indian central counterparties: a transition period planned for the French credit institutions
Why this matters
This regulatory update is relevant for French credit institutions and their membership towards Indian central counterparties. It involves prudential and authorization requirements, which are of medium importance for the banking sector.
Financial disclosures & corporate financing Financial products Journalists Listed companies and issuers The AMF calls on listed companies to improve investor information regarding the risks incurred in the case of dilutive financing transactions
Why this matters
This regulatory update from the AMF calls on listed companies to improve investor information regarding the risks of dilutive financing transactions, which is relevant for capital markets and listed companies. The focus is on reporting and disclosure requirements.
Asset management Extension of the preparation of a Key Information Document to all collective investments: the AMF updates its policy
Why this matters
This regulatory update from the AMF extends the requirement to prepare a Key Information Document to all collective investments, which impacts asset managers and wealth managers. It relates to consumer protection and disclosure requirements.
Financial products Sustainable Finance Asset management Journalists Investment management companies The Sustainable Finance Disclosure Regulation: the AMF proposes a targeted review to include minimum environmental criteria
Why this matters
This regulatory update from the AMF focuses on the Sustainable Finance Disclosure Regulation, which impacts investment management firms, wealth managers, and banks that offer sustainable financial products.
Sustainable Finance Periodic & ongoing disclosures Taxonomy Article 8 reporting: publication of Frequently Asked Questions by the European Commission
Why this matters
This regulatory update is relevant for investment managers and wealth managers as it provides guidance on Article 8 taxonomy reporting, which is a key ESG disclosure requirement. The update is of medium urgency as firms need to prepare for these reporting obligations.
Savings protection Marketing Marketing of financial products to ageing populations: publication of an independent academic research report on customer relations and sales processes
Why this matters
This regulatory update focuses on the marketing of financial products to aging populations, which impacts firms across the banking, investment management, and wealth management sectors. Key topics include consumer protection, operational resilience, and disclosure requirements.
Sanctions & settlements Journalists The AMF Enforcement Committee fines three legal entities and eight individuals for insider dealing breaches and failure to maintain and update insider lists
AI Analysis
The AMF Enforcement Committee imposed fines totaling over €3 million on three legal entities and eight individuals in its 30 January 2023 decision for insider dealing in Terreïs shares based on two pieces of inside information, and for Terreïs's failure to maintain and update its insider list. This case matters because it exemplifies AMF's rigorous enforcement of market abuse rules under the Market Abuse Regulation (MAR), highlighting indicators like atypical trading timing, order placement methods, and information transmission channels that trigger sanctions, serving as a deterrent and educational tool for compliance programs.
Key dates
30 January 2023
- AMF Enforcement Committee decision date, imposing fines for insider dealing and insider list failures
Suggested considerations
Review and strengthen insider list management: Issuers must ensure lists are complete, updated in real-time for changes in access to inside information, and accessible for AMF inspections; Terreïs's €350,000 fine underscores non-compliance risks.
Enhance market abuse surveillance: Implement systems to flag atypical trading (e.g., urgency, timing, order methods) and investigate plausible information channels; train staff on MAR prohibitions against use, disclosure, or inducement.
Conduct insider trading risk assessments: Map primary/secondary insiders, including family/partners, and enforce pre-approval for trades during closed periods; document justifications for all transactions to counter AMF indicators.
Update compliance training and policies: Incorporate case-specific lessons, such as high-confidence bets on price movements, into annual programs for directors, employees, and advisors.
What changed
This enforcement decision does not introduce new regulatory changes or requirements; it applies existing obligations under French market abuse rules aligned with EU MAR (Regulation (EU) No 596/2014). Key reaffirmed requirements include: prohibiting the use, disclosure, or recommendation of inside information for trading; maintaining and regularly updating insider lists with details of persons having access to inside information; and ensuring issuers like Terreïs promptly detect and prevent breaches through robust surveillance.
Compliance impact
Urgency: Medium - This 2023 decision reinforces longstanding MAR rules without new mandates, but its detailed analysis of enforcement indicators demands immediate policy reviews to mitigate fines up to €1M+ per breach. It matters for firms handling listed securities, as AMF prioritizes educational enforcement via public decisions, increasing scrutiny on insider lists and trading surveillance amid ongoing cases (e.g., 2024-2025).
Long term investment Equity Equity Savings Plan Retail investors Journalists Investment services providers Investment management companies Listed companies and issuers Over 1.5 million retail investors bought or sold shares in...
Why this matters
This regulatory update discusses retail investor activity in the equity markets, which is relevant for investment management firms, broker-dealers, and wealth managers that serve retail clients.
Sustainable Finance Periodic & ongoing disclosures Publication of the new directive on corporate sustainability reporting (CSRD)
Why this matters
This regulatory update on the new Corporate Sustainability Reporting Directive (CSRD) is highly relevant for financial firms across banking, investment management, and capital markets sectors. It introduces new ESG reporting and disclosure requirements that these firms will need to comply with.
Warning Warning Savings protection The AMF warns the public about calls from fraudsters claiming to help recover funds
Why this matters
This regulatory update from the AMF warns the public about fraudulent calls claiming to help recover funds, which is relevant for banking, investment management, and wealth management firms that handle client funds.
Artificial intelligence Financial disclosures & corporate financing Innovation Prospectus Artificial intelligence, towards new contributions for regulators
Why this matters
This regulatory update discusses the implications of artificial intelligence for financial regulators, covering topics related to financial disclosures, corporate financing, and innovation.
This regulatory update from the AMF covers a range of sectors and topics relevant to investment management, capital markets, and crypto/digital assets firms. It includes priorities around authorization, reporting, and technology/cyber, indicating medium urgency for firms in these areas to review and prepare.
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
AI Analysis
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.
Key dates
30 December 2022
- AMF Enforcement Committee decision SAN-2023-01 imposing fines and sanctions
- Conseil d'État dismisses appeals (n. 471548, 471744), upholding sanctions and ordering €3,000 costs to AMF
Suggested considerations
Review portfolios: Audit UCITS/AIF holdings for liquidity, rating compliance, prospectus alignment, and issuer/counterparty limits; divest non-eligible assets.
Enhance due diligence: Implement robust processes for unlisted/illiquid securities valuation, liquidity risk modeling, and repo unwind risks; document all assessments.
Strengthen governance: Senior managers must oversee investment ratios and eligibility; update procedures for buy & sell backs in exposure calculations.
Depositary checks: Verify oversight of management company systems for ratios, legality, and prospectus terms.
Training/remediation: Conduct firm-wide training on UCITS rules; test controls against AMF/FCA principles (e.g., skill/care, regulator relations).
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; risks of unwinding transactions at market value must be evaluated.
These align with parallel FCA findings on due diligence failures for Tennor investments...
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 (e.g., H2O fund gates), risking similar sanctions amid rising AMF actions on depositaries and managers.