Sanctions & settlements Journalists The AMF Enforcement Committee fines two individuals for insider dealing breaches
The AMF Enforcement Committee has sanctioned two individuals, Ytane Mamou and Elie Houri, a total of €50,000 for insider dealing related to a takeover of a listed company, based on trading in July 2021. The decision confirms and illustrates how the AMF infers possession and use of inside information from circumstantial indicators (transmission channels, atypical trading, timing, and weak explanations), which has direct implications for how firms design surveillance, control personal account dealing, and train staff and related persons.
What Changed
- - The decision reiterates and operationalises the definition of “inside information” under the EU Market Abuse Regulation (MAR, Regulation (EU) No 596/2014), confirming that information relating to a...
- The Enforcement Committee shows that it will infer possession and use of inside information from a combination of factors (plausible transmission channels, atypical trading patterns, timing around...
- The decision confirms that the use of inside information through trading on own account and on the account of closely related persons (spouse, parent) will be treated as separate instances of misuse...
- The Committee explicitly treats recommendations to invest made on the basis of inside information as a distinct form of insider dealing, exposing the recommender to sanctions even if they do not...
- The ruling reinforces that relatives and close associates (here, cousins) who act on such recommendations can be sanctioned for insider dealing, even when they are not employees or insiders of the...
Suggested Considerations
- Review and update MAR market abuse policies to explicitly cover the prohibition on recommending or inducing others to trade on the basis of inside information, including for non-staff related persons.
- Enhance insider dealing surveillance scenarios to capture atypical trading patterns before takeover or M&A announcements, including trading by retail clients and accounts linked to employees’ family members where identifiable.
- Tighten procedures for the management of inside information during corporate transactions (takeovers, mergers, acquisitions), including clear designation of insiders, controlled information flows, and logging of who is aware of pending deals.
- Strengthen controls around potential transmission channels for inside information, including guidance and monitoring for staff who may informally share information with relatives or friends, and explicitly prohibit such behaviour in codes of conduct.
- Provide targeted MAR training to staff, senior management, and high‑risk functions (M&A, corporate finance, strategy, legal, finance) that uses this case as an example of how the AMF infers insider dealing and the consequences for both insiders and relatives.
Key Dates
- Period during which Mr Ytane Mamou purchased shares in the listed company on his own account, for his wife, and for his father, and when Mr Houri acquired shares following his cousin’s recommendation, prior to takeover-related announcements
- AMF Enforcement Committee decision SAN‑2026‑04 is adopted, finding insider dealing by Mr Mamou and Mr Houri and imposing fines of €30,000 and €20,000 respectively
- AMF publishes the news release summarising the Enforcement Committee decision and sanctions; appeal against the decision remains possible from this date in accordance with French procedural rules
Compliance Impact
Failure to prevent, detect, and report insider dealing exposes firms and individuals to substantial administrative fines, reputational damage, and potential criminal consequences under French law. The AMF’s reliance on circumstantial evidence in this case raises the bar for firms’ surveillance, documentation, and staff training, since weak explanations and poor records can be interpreted against market participants.
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Asset ManagerBroker DealerBank MMF Asset management The AMF complies with ESMA’s guidelines on updating the stress scenario parameters provided for in Article 28 of the Money Market Funds Regulation for 2026
Asset Manager
Collective investments Marketing Financial products Retail investors Journalists The AMF unveils its 2026-2028 financial education plan to boost women’s investment
Asset ManagerBroker DealerAll Firms
Asset management AIFMD UCIT Regulatory developments Liquidity Management Tools: the AMF intends to comply with ESMA’s Guidelines
Asset ManagerHedge Fund
Appointment Institutional Christophe Bonnet appointed Data and Surveillance Director at the Autorité des Marchés Financiers
All Firms
Asset management The Autorité des Marchés Financiers (AMF) has approved the updated ‘Provisions’ of the AFG Code of Ethics for Third-Party Asset Management and extended these to all investment services providers
All Firms
Fees Collective investments Shares Fees for financial investments continue to decline, particularly those for mutual funds
All Firms
Supervision Marketing Financial products Investment services Savings protection Journalists Investment services providers In an increasingly digital investment landscape, the AMF stresses the importance of the quality of the information...
Fintech
Warning Savings protection Warning Crypto-assets Crypto-assets: the Autorité des Marchés Financiers warns the public about the activities of several unauthorized entities
Crypto Exchange
Warning Warning Savings protection Forex and binary options The AMF and the ACPR warn the public against several entities offering in France investments in the unregulated foreign exchange market (Forex) and in crypto-assets derivatives without being authorized to do so
Crypto Exchange
Cooperation Europe & international Equity Journalists Listed companies and issuers AMF Québec, OSC and AMF France enter into an agreement to support cross-listing of securities in Canada and France
Asset ManagerBroker Dealer
MAR Offence of obstructing an AMF investigation sentenced by the Paris Tribunal Correctionnel
The Paris Tribunal Correctionnel on 9 April 2026 sentenced an individual to a six-month suspended prison term and €20,000 fine for obstructing an AMF house search during a market abuse investigation, plus €5,000 in AMF procedural costs and €1 in damages. This enforcement action underscores the criminal liability for impeding AMF investigations, reinforcing the regulator's authority and serving as a deterrent against non-cooperation. Compliance teams must prioritize training on full cooperation to avoid similar penalties, as maximum sanctions include up to two years' imprisonment and €300,000 fines under the Monetary and Financial Code.
What Changed
This is not a regulatory change but an enforcement precedent affirming existing rules under the Monetary and Financial Code (CMF), specifically Article L.642-2, which criminalizes obstruction of AMF inspections or investigations, including refusing access during authorized house searches. The ruling reiterates that even initial refusal of access constitutes obstruction, with courts upholding AMF operations via prior judicial authorization from the *Juge des Libertés et de la Détention*. It highlights dual administrative and criminal tracks, though a 2022 Constitutional Court decision (QPC no.
Suggested Considerations
- Immediate training: Conduct firm-wide sessions on AMF inspection protocols, emphasizing mandatory cooperation, document access, and avoiding any delay or refusal (e.g., scripted responses for employee interactions).
- Policy updates: Revise compliance manuals to explicitly prohibit obstruction, including scenarios like home searches for remote workers; designate 24/7 points of contact for AMF visits.
- Mock drills: Simulate AMF searches at offices and residences to test response times and access protocols.
- Legal readiness: Retain counsel experienced in CMF Article L.642-2 matters; pre-approve cooperation clauses in employee contracts.
- Reporting: Enhance internal surveillance to detect potential market abuse early, reducing investigation risks.
Key Dates
- AMF investigators, with judicial police, conducted authorized house search; individual initially refused access
- AMF filed report with Paris Public Prosecutor's Office
- Paris *Cour d’Appel* upheld search authorization, finding sufficient presumption of market abuse; ordered €5,000 costs to AMF
- AMF lodged formal complaint
- Paris *Cour d’Appel* validated search and seizure operations; ordered additional €5,000 costs to AMF
Compliance Impact
Urgency: High – This recent (April 2026) criminal conviction demonstrates swift judicial support for AMF actions, with appeals consistently rejected, signaling zero tolerance for even minor obstructions. It elevates risks for individuals and firms in *MAR* probes, potentially leading to personal liability, reputational damage, and cascading sanctions; firms must act preemptively as investigations can stem from routine surveillance.
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Broker DealerAll Firms
Savings protection Warning Retail investors Journalists The AMF confirms the resumption of trading in Rapid Nutrition shares
Broker DealerAsset Manager
MAR Journalists Listed companies and issuers The AMF welcomes the first criminal rulings in an insider network case
BankBroker DealerAsset Manager
Sanctions & settlements professional obligations Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor and its directors for breaches of their professional obligations
The AMF Enforcement Committee sanctioned financial investment advisor Kerdiz Finance et Conseil with a €300,000 fine and its directors Anthony Finck and Marc Peuvrier with €75,000 fines each, plus a 5-year ban on advisory activities, for multiple breaches of professional obligations from 2020-2023. This case underscores AMF's strict enforcement against unauthorized product marketing, conflict of interest mismanagement, product governance failures, and AML shortcomings, serving as a warning for advisors to prioritize client best interests and regulatory compliance. It matters because it highlights personal liability for directors and escalating penalties for systemic procedural lapses.
What Changed
- This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French financial advisor rules (e.g., derived from MiFID II and AIFMD implementations):
- Accurate representation: Advisors must not misrepresent authorization status or claim unapproved services like investment services provision.[Source URL:...
- Conflict of interest management: Procedures must identify and mitigate risks from commercial/ownership ties (e.g., to Vivat Multitalent group), beyond mere shareholding disclosures.
- Product governance: Collect and review product information to ensure investor protection; verify asset managers/depositaries for securities.
- Marketing limits: Prohibit advising prohibited securities (e.g., Multitalent AG bonds without French authorization) or high-risk offers like Guyane Agricole exceeding initial contributions.
Suggested Considerations
- Immediate review: Audit marketing materials, website, and client communications for accurate authorization claims; cease any unapproved representations.
- Enhance procedures: Update conflict of interest policies to fully identify/mitigate risks from promoter ties; implement robust product governance collecting issuer details (e.g., asset managers, depositaries, marketing eligibility in France).
- Product due diligence: For all recommended securities/offers, verify French marketing authorization (e.g., AMF registration, prospectus, AIFMD passport); document high-risk features like loss exceeding contributions.
- AML/CFT strengthening: Ensure full compliance with due diligence and inspector cooperation; conduct gap analysis against AMF guidelines.
- Training and governance: Train directors/staff on personal liability; test procedures via internal audits.
Key Dates
28 June 2023; Period of breaches investigated
Date of AMF Enforcement Committee decision imposing fines and 5-year ban
Compliance Impact
Urgency: High – This demonstrates AMF's pattern of heavy fines (€300k+ firm, €75k personal) and long bans (5 years) for procedural failures, with director accountability. It matters amid rising enforcement on unauthorized AIF/alternative product marketing (see related cases), risking similar sanctions for non-EU promotions; firms should prioritize audits now to preempt inspections.
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Wealth ManagerAll Firms
Supervision Asset management Compliance Journalists Investment management companies The Autorité des Marchés Financiers publishes the findings of its SPOT inspections on asset management companies’ compliance and internal control systems
Asset Manager
Markets Europe & international Cooperation FMSB signs Consultation Agreement with Autorité des Marchés Financiers
The Autorité des Marchés Financiers (AMF) and Financial Markets Standards Board (FMSB) have signed a Consultation Agreement to enhance collaboration on developing guidance for wholesale Fixed Income, Currencies, and Commodities (FICC) markets, allowing AMF to provide expertise on FMSB drafts. This matters for compliance professionals as it signals regulatory endorsement of FMSB's non-binding standards, potentially elevating their influence on market conduct expectations in France and Europe, particularly as Paris grows as a trading hub. https://www.amf-france.org/en/news-publications/news/fmsb-signs-consultation-agreement-autorite-des-marches-financiers
What Changed
This is not a regulatory change imposing new rules but a bilateral Consultation Agreement outlining cooperation mechanisms. Key elements include: AMF input on FMSB's annual strategy refresh via discussions with FMSB Chair/CEO; annual high-level oral updates on FMSB strategy progress; operational updates on FMSB workplan/priorities; and AMF's ability to review and challenge draft FMSB guidance materials and publications for wholesale FICC markets. The agreement is non-binding, personal to the parties, and amendable only by mutual written consent, with no third-party rights.
Suggested Considerations
- Review and monitor FMSB's 2026 Workplan for upcoming Standards/Statements, noting AMF-influenced drafts (e.g., via FMSB committees and buy-side forum). https://fmsb.com/wp-content/uploads/2026/01/FMSB-2026-Workplan_Final.pdf
- Benchmark internal FICC practices against FMSB guidance, especially vulnerability areas like market structures or conduct.
- Engage with FMSB membership or working groups if applicable, to align with emerging standards endorsed by AMF.
- Track AMF/FMSB updates for Paris-specific FICC developments. https://fmsb.com/fmsbsignsconsultationagreementwithamf/
Key Dates
- Operational oral updates on FMSB workplan/priorities as needed. https://www.amf-france.org/sites/institutionnel/files/private/2026-03/fmsb-amf-accord-2026.pdf
- Agreement signed and announced, marking effective date of collaboration (today's date). https://www.amf-france.org/en/news-publications/news/fmsb-signs-consultation-agreement-autorite-des-marches-financiers
- FMSB provides high-level oral update to AMF on strategy progress
- FMSB Chair/CEO discusses strategy refresh with AMF for input
Compliance Impact
Urgency: Low - This agreement introduces no direct obligations, deadlines, or penalties; it fosters indirect influence via enhanced credibility of FMSB's voluntary standards in AMF-regulated markets. It matters for long-term conduct risk management in FICC, as firms ignoring FMSB guidance (now AMF-supported) may face heightened supervisory scrutiny, especially amid Paris's trading growth and AMF's 2026 priorities for resilient markets. https://zoominvest.fr/actualites/patrimoine/amf-des-priorites-2026-axees-sur-l-attractivite-l-innovation-et-la-securite-des-marches/iob24fnqfmfh258iwmxwwicy
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Broker DealerBank
Asset management Regulatory developments The AMF clarifies its doctrine on several aspects relating to asset management companies
Asset ManagerBank
Long term investment Shares ETF Retail investors Journalists The stock market attracted a record number of retail investors in 2025
Asset ManagerBroker DealerWealth Manager
Crypto-assets MiCA Crypto-assets: The AMF applies ESMA guidelines on the knowledge and competence of staff of crypto-asset service providers under MiCA
Crypto ExchangeFintech
Asset management Crowdfunding: the AMF reminds platforms of their complaint handling obligations
Asset ManagerBroker DealerWealth Manager Warning Savings protection MAR Retail investors Professional investors Journalists AMF requests extension to the RAPID NUTRITION share suspension
The AMF has requested Euronext to extend the trading suspension of RAPID NUTRITION shares until April 10, 2026, due to ongoing suspicions of "pump and dump" market abuse under Article L. 420-10 of the Monetary and Financial Code. This enforcement action underscores the AMF's proactive market surveillance and highlights risks of unauthorized investment recommendations, urging investors to report evidence. Compliance professionals should note this as a signal of heightened scrutiny on manipulative practices in small-cap stocks like those on Euronext Growth.
What Changed
- This is not a new regulation but an enforcement extension; no broad regulatory changes are introduced. Key elements include:
- Extension of trading suspension from March 13, 2026, to April 10, 2026, to allow continued AMF analysis of price manipulation indicators.
- Reiterated definition and warning on pump and dump schemes, involving unauthorized promotions without disclosure of promoters' holdings, leading to artificial price inflation followed by dumps.
- Invocation of MAR (Market Abuse Regulation) principles, aligned with EU standards, emphasizing orderly market operations and investor protection.
Suggested Considerations
- Trading venues (e.g., Euronext): Implement and maintain suspension of RAPID NUTRITION shares until April 10, 2026, or AMF notice.
- Firms under AMF jurisdiction: Review trading surveillance systems for pump-and-dump signals (e.g., aggressive social media/email pitches promising quick gains); ensure no facilitation of unauthorized recommendations.
- Investors: Preserve all pitch documents (screenshots, emails, messages) and submit to AMF via Epargne Info Service platform or phone.
- Compliance teams: Conduct immediate audits of client communications and holdings in similar volatile stocks; train staff on MAR obligations for disclosing positions in recommendations.
- No new reporting deadlines, but proactive evidence submission is urged.
Key Dates
- Initial trading suspension requested by AMF until 13 March 2026 due to pump-and-dump suspicions
- End of initial suspension period; AMF requests extension
- New end date for extended trading suspension, or until further notice
Compliance Impact
Urgency: High - This active enforcement on a live suspension (as of March 14, 2026, just post-initial period) signals AMF's aggressive stance on market abuse in retail-targeted small-caps, with potential for fines or further sanctions (e.g., prior AMF cases fined €850,000). Firms must act swiftly to mitigate exposure to similar schemes, as failure to detect/report could trigger secondary liability under MAR; impacts trading desks and surveillance functions directly.
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Broker DealerAll Firms
Shares Asset management Post-trading infrastructures The AMF analyses the typology of participants on the French equity market over the past five years.
Asset ManagerBankBroker Dealer
Collective investments Marketing Financial products Other professionals Executive & other private individuals Journalists Investment services providers Investment management companies Listed companies and issuers ...
Asset ManagerWealth Manager
Appointment Institutional Sophia Bennani appointed AMF Director of Inspections
Asset ManagerWealth Manager
Supervision Sustainable Finance Marketing Journalists Investment services providers Investment management companies The AMF publishes the findings of its inspections on the consideration of client sustainability preferences
Asset ManagerWealth Manager
MAR Executive & other private individuals Journalists Listed companies and issuers The Casino case: the Paris Tribunal Correctionnel ruling marks the end of a market abuse case in which the AMF has been heavily involved
BankBroker DealerAsset Manager
Warning Savings protection Retail investors Professional investors Journalists Listed companies and issuers The AMF has required the suspension of RAPID NUTRITION shares and calls on investors to be vigilant
The AMF has mandated the suspension of trading in RAPID NUTRITION shares (Euronext Growth Paris: ALRPD) from February 19, 2026, until March 13, 2026, due to indicators of "pump and dump" market manipulation, urging investors to exercise extreme caution against unauthorized high-upside recommendations. This enforcement action highlights AMF's proactive surveillance of market abuse in small-cap listings and serves as a reminder for firms to enhance client protection measures against boiler room tactics. It matters for compliance as it underscores heightened scrutiny on retail investor-facing activities amid volatile stock surges, like RAPID NUTRITION's 437% rise since January 1, 2026.[AMF publication]
What Changed
- This is not a new regulation but an enforcement action under existing French financial markets and market abuse rules (e.g., EU Market Abuse Regulation - MAR, transposed via AMF oversight).
- Trading suspension on Euronext at AMF's request due to suspected "pump and dump" (boiler room) practices, involving unauthorized recommendations promising rapid gains without disclosing promoters'...
- No formal rule changes; reinforces prohibitions on market manipulation (Article 12 MAR), unlawful investment recommendations (MiFID II Article 24), and failure to disclose conflicts.
- AMF's call for evidence collection emphasizes ongoing investigations into aggressive sales pitches via emails, messaging, or screenshots.[AMF publication]
Suggested Considerations
- Investors: Preserve all solicitation evidence (screenshots, emails, messages) and report via AMF's Epargne Info Service (online or +33(0)1 5345 6200, Mon-Fri 9am-12:30pm).
- Trading venues (Euronext): Implement and maintain suspension until lifted.
- Firms/brokers:
- Suspend trading in RAPID NUTRITION shares.
- Enhance surveillance for pump-and-dump indicators (e.g., unusual volume/price spikes, correlated recommendations).
- Review client communications for unauthorized advice; block/blocklist suspicious patterns.
Key Dates
Trading suspension begins; (effective from this trading session)
Scheduled end of suspension; (inclusive, or earlier if market conditions allow via new AMF notice)
Compliance Impact
Urgency: High - Immediate trading halt requires system updates today (Feb 19, 2026); ongoing AMF probe risks fines/sanctions under MAR for non-compliant surveillance or advice. Matters due to retail investor exposure in volatile Euronext Growth stocks, potential for follow-on enforcement (e.g., against unauthorized advisors), and signal of intensified AMF monitoring amid 437% surges, amplifying conduct risk for client-facing firms.[AMF publication]
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Broker DealerAll Firms
Anti-money Laundering Asset management The AMF invites financial market participants to AMLA’s consultations on three draft AML/CFT implementing standards
The AMF is urging financial market participants, especially in asset management and related sectors, to engage in AMLA's public consultations on three draft Regulatory Technical Standards (RTS) under the new EU AML/CFT package, covering customer due diligence (CDD), identification of business relationships/transactions, and enforcement measures. These RTS aim to provide harmonized, proportionate implementation guidance, significantly impacting CDD processes and supervisory consistency across the EU, with underlying rules applying from 10 July 2027.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
What Changed
- - CDD RTS: Builds on EBA's prior draft with AMLA refinements for legal clarity, proportionality, and risk adaptation; specifies information/sources for identity verification of natural persons/legal...
- Business Relationships/Occasional/Linked Transactions RTS: Defines criteria under AMLR Article 19(9) to harmonize identification, ensuring consistent EU-wide application beyond basic...
- Enforcement RTS (Pecuniary Sanctions/Administrative Measures): Under AMLD6 Article 53(10), standardizes supervisor assessment/categorization of breaches for proportionate, effective, dissuasive...
Suggested Considerations
- Gap analysis and preparation: Assess current CDD/business identification/enforcement processes against drafts; identify changes for remote onboarding, PEPs, sectoral measures (e.g., asset manager Article 17 scenarios), and sanctions screening; set milestones for policy/system updates by July 2027.
- Engage hearings: Attend 24 March 2026 public hearing for CDD/business RTS.
- Monitor post-consultation: Track AMLA/EC adoption (expected Q1 2026 for some related RTS) and national implementations (e.g., CSSF data reporting).
Key Dates
- Consultations opened by AMLA on three draft RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
- Consultation closes on RTS for pecuniary sanctions/administrative measures
- Online public hearing on CDD and business relationships RTS
- Consultations close on CDD RTS and business relationships/linked transactions RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
- AMLA submits final draft RTS to European Commission for adoption
Compliance Impact
Urgency: High - These RTS operationalize core AMLR/AMLD6 mandates with July 2027 applicability, demanding immediate consultation input to influence final rules and 18-month lead time for system/process overhauls (e.g., CDD verification sources, harmonized transaction linking). Failure to engage risks non-compliant frameworks amid AMLA's push for EU-wide consistency, elevated direct supervision risks, and stricter enforcement; asset managers face acute challenges from intermediary distribution rules.[Source URL:...
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Asset ManagerCrypto ExchangeAll Firms
Asset management The AMF announces that the withdrawal of the authorisation of the portfolio management company APICAP is effective
Asset Manager
Derivatives or structured products MIFID The AMF revises the position limits applicable to the salmon derivative contract listed on Euronext
All Firms
Supervision Asset management Journalists Investment management companies The Autorité des Marchés Financiers publishes the findings of its inspections of asset management companies' operational risk management
Asset ManagerBank
Institutional Markets Journalists The AMF awards its 2025 prize for young researchers in economics to Alexandre Madelaine
Asset ManagerBroker DealerFintech
MiCA Investment services The AMF reminds Digital Asset Service Providers that the transitional period allowing them to continue providing crypto-asset services in France without MiCA authorisation ends on 1 July 2026
Crypto ExchangeFintech
Institutional Regulatory developments Financing the economy Other professionals Journalists Listed companies and issuers The AMF awards its Marie-Josèphe-Vanel thesis prize in law to Vincent Ramonéda
Asset ManagerBroker DealerBank
Derivatives or structured products Marketing MIFID The AMF publishes a working group study on structured products
Asset ManagerBroker Dealer
Artificial intelligence Innovation Fintech Journalists Investment services providers Investment management companies Listed companies and issuers A study by the AMF finds widespread levels of adoption in artificial intelligence by French...
Sanctions & settlements MAR Compliance Journalists Investment services providers The AMF Enforcement Committee fines an investment services provider and its director a total of €850,000
Broker DealerAll Firms
Financial disclosures & corporate financing Periodic & ongoing disclosures Reporting ESEF Closing of the 2025 accounts: the AMF flags up points for vigilance and issues recommendations
BankBroker DealerAsset Manager Supervision Compliance Journalists Investment services providers The AMF publishes the findings of its inspections on the role and involvement of the compliance function at investment services providers
BankAsset ManagerBroker Dealer
Strategy Supervision Institutional Other professionals Retail investors Journalists Investment services providers Investment management companies Listed companies and issuers The AMF sets its priorities for 2026 for...
Asset ManagerBroker DealerBank Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including non-operational investment systems, deficient AML/CFT procedures, inadequate conflict of interest management, and poor due diligence traceability. This decision underscores AMF's focus on operational robustness in asset management, with personal liability for senior managers, signaling heightened enforcement risk for similar firms. Compliance teams must prioritize reviewing internal procedures to avoid comparable sanctions, as appeals are possible but do not suspend obligations.
What Changed
- This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under the French Monetary and Financial Code for asset managers to maintain operational procedures.
- Imprecise investment allocation processes lacking traceability, rendering systems non-operational.
- Failure to fulfill conflict of interest identification, prevention, and management obligations.
- Deficient AML/CFT systems with inadequate due diligence on fund assets/liabilities.
These align with prior AMF expectations for "honest, fair, and professional" conduct with skill, care, and...
Suggested Considerations
- Conduct immediate gap analysis of investment processes for operationality, traceability, and precision in allocation rules.
- Enhance AML/CFT systems: Update risk mapping, procedures, and due diligence on fund assets/liabilities; ensure systematic application.
- Review conflict of interest frameworks for identification, prevention, and management; document controls rigorously.
- Senior managers: Demonstrate personal oversight via governance records to mitigate attribution of firm breaches.
- Audit marketing materials, fee retrocessions, and valuation procedures (e.g., for real estate or experts) against AMF standards.
Key Dates
December 2023; - Period of breaches investigated
- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors
- Public news release date for the decision
Compliance Impact
Urgency: High - This reflects a pattern of 2025-2026 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc 15 Sep 2025; €400k on Eternam 9 Sep 2025), indicating intensified scrutiny and personal accountability. Firms risk multimillion fines and reputational damage; immediate audits are essential pre-audit cycles, especially with appeals highlighting ongoing litigation risk.
AI-generated analysis. May contain errors or omissions — verify with the
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Asset Manager
Asset management AIFMD UCIT AIFM II: the AMF updates its doctrine to make introducing liquidity management tools easier for UCITS and AIFs
Asset ManagerHedge Fund
Warning Forex and binary options Warning Savings protection The AMF and the ACPR warn the public against several entities offering in France investments in the unregulated foreign exchange market (Forex) and in crypto-assets derivatives without being authorized to do so
BankFintechCrypto Exchange