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
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Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including non-operational investment systems, deficient AML/CFT procedures, inadequate conflict of interest management, and poor due diligence traceability. This decision underscores AMF's focus on operational robustness in asset management, with personal liability for senior managers, signaling heightened enforcement risk for similar firms. Compliance teams must prioritize reviewing internal procedures to avoid comparable sanctions, as appeals are possible but do not suspend obligations.
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What Changed
This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under the French Monetary and Financial Code for asset managers to maintain operational procedures. Key breaches highlighted include:
Imprecise investment allocation processes lacking traceability, rendering systems non-operational.
Failure to fulfill conflict of interest identification, prevention, and management obligations.
Deficient AML/CFT systems with inadequate due diligence on fund assets/lia
What You Need To Do
- Conduct immediate gap analysis of investment processes for operationality, traceability, and precision in allocation rules
- Enhance AML/CFT systems
- Review conflict of interest frameworks for identification, prevention, and management; document controls rigorously
- Senior managers
- Audit marketing materials, fee retrocessions, and valuation procedures (e
Key Dates
31 December 2025 - AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors.
08 January 2026 - Public news release date for the decision.
August 2019 - December 2023 - Period of breaches investigated.
Compliance Impact
Urgency: High - This reflects a pattern of 2025-2026 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc 15 Sep 2025; €400k on Eternam 9 Sep 2025), indicating intensified scrutiny and personal accountability. Firms risk multimillion fines and reputational damage; immedia
Asset Manager
Sanctions & settlements professional obligations Journalists Investment management companies Listed companies and issuers AMF Enforcement Committee fines the depositary CACEIS Bank for breaches of its professional obligations
The AMF Enforcement Committee fined CACEIS Bank €3.5 million and issued a warning on 17 December 2025 for breaches of its professional obligations as depositary for seven French-law UCITS funds managed by H2O AM LLP (later transferred to H2O AM Europe). This decision underscores the AMF's strict enforcement of depositary oversight duties, particularly in verifying fund managers' investment monitoring systems, asset valuations, and compliance with prospectus constraints like issuer limits and security ratings. It matters for compliance teams as it highlights personal accountability risks and potential fines for inadequate due diligence in fund depositary roles, signaling heightened scrutiny amid past H2O fund issues.
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What Changed
This is an enforcement action, not a regulatory change; it reinforces existing obligations under French UCITS rules (transposing UCITS Directive V) for depositaries. Key upheld objections include:
Failure to perform sufficient checks on the asset management company's (AMC) systems for monitoring UCITS investment ratios and valuing unlisted securities.
Inadequate verification of investment decision legality, such as compliance with prospectus limits on debt security ratings, derivative types, and
What You Need To Do
- Conduct gap analysis
- Enhance oversight processes
- Training and audits
- Monitor appeals
Key Dates
17 December 2025 - AMF Enforcement Committee decision date: €3.5M fine and warning imposed on CACEIS Bank.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision directly impacts depositaries with €3.5M precedent for oversight failures, amid AMF's pattern of multi-million fines (e.g., €5.67M total in related 2024 case involving CACEIS). It elevates risks for UCITS/AIF depositaries handling non-standard assets,
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Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its former director a total of €500,000
The AMF Enforcement Committee fined asset management company Novaxia Investissement €400,000 and its former director Joachim Azan €100,000 on 10 December 2025 for breaches of professional obligations, primarily due to an incomplete and non-operational investment/divestment procedure lacking traceability of compliance checks and formalized due diligence. This enforcement action underscores AMF's focus on robust operational procedures in asset management, serving as a deterrent and educational tool for ensuring honest, fair, and diligent business conduct. Compliance teams should prioritize procedure operationalization to avoid similar sanctions, as this fits a pattern of recent AMF fines targeting procedural deficiencies.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces existing requirements under AMF professional obligations for asset managers (sociétés de gestion), including:
Fully operational investment and divestment procedures that ensure traceability of compliance checks against fund policies and constraints.
Formalized due diligence prior to allocating investment projects to funds.
No explicit changes to rules; instead, it clarifies enforcement expectations for procedure completenes
What You Need To Do
- Review and enhance investment/divestment procedures: Ensure completeness, traceability of all compliance checks (e
- Document all processes rigorously
- Conduct gap analysis against AMF expectations
- Senior manager training
- Appeal monitoring
Key Dates
10 December 2025 - AMF Enforcement Committee decision date imposing fines; appeals possible (no specific deadline stated, but typically within 2 months to Conseil d’État). DEADLINE
Compliance Impact
Urgency: High – This decision, part of a 2025 enforcement wave fining asset managers €400k–€1.3m for procedural lapses (e.g., non-operational investment processes, inadequate due diligence), signals intensified AMF scrutiny on operational integrity. Firms risk personal fines for managers and reputat
Asset Manager
Sanctions & settlements Anti-money Laundering Governance Investment advice Other professionals Journalists Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its two directors a total of €2.5...
The AMF Enforcement Committee fined financial investment advisor Carat GP €300,000 and its directors Jimmy Guinet (€200,000) and Sébastien Renaud (€2 million) a total of €2.5 million on 5 November 2025, imposing permanent bans on Carat GP and Renaud, and a 10-year ban on Guinet, for breaches including inadequate documentation, failure to act honestly and professionally in clients' interests, AML failures, lack of conflict detection systems, and insufficient cooperation with inspectors. This decision marks the first time the Committee held directors personally liable for breaches, signaling heightened personal accountability for senior managers in French investment firms. It matters as it reinforces AMF's focus on governance, AML, and client protection, with severe sanctions serving as a deterrent amid rising enforcement trends.
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What Changed
This is an enforcement action, not a regulatory change, but it clarifies and strengthens application of existing AMF rules for conseillers en investissements financiers (CIFs) under French regulations:
Mandatory compliant documentation (e.g., investment proposals).
Obligation to act honestly, fairly, and professionally in clients' best interests, including systems to prevent managers exploiting positions for undocumented investments.
AML/CFT compliance, including prohibitions on directors receiv
What You Need To Do
- Audit documentation
- Strengthen governance
- Enhance AML/CFT
- Improve inspection readiness
- Senior manager reviews
Key Dates
5 November 2025 - AMF Enforcement Committee decision issued, imposing fines and bans.
6 November 2025 - French version of press release published.
1 January 2019 to 30 June 2024 - Relevant period of breaches for Carat GP.
Compliance Impact
Urgency: High - Recent (November 2025) decision with record €2.5m fines and novel personal director liability elevates risks for CIFs and managers, amid AMF's pattern of escalating sanctions on governance/AML failures (e.g., similar cases in 2019-2025). Firms must act promptly to avoid parallel enfo
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Europe & international Sanctions & settlements Publication of the annual ESMA Report on Sanctions and Measures for 2024: AMF imposes the highest amounts in Europe
The ESMA Annual Report on Sanctions and Measures for 2024, published on 16 October 2025, aggregates enforcement data from EEA national competent authorities (NCAs), highlighting that the French AMF imposed the highest total sanctions at €29.4 million—nearly a third of the EEA's €100 million aggregate—primarily under MAR and MiFID II. This matters for compliance professionals as it signals intensified enforcement focus on market abuse and investor protection across Europe, with France leading in both fine amounts and settlement usage, underscoring a trend toward higher penalties and agile resolution mechanisms.
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What Changed
This is not a new regulation but a retrospective report documenting 2024 enforcement trends; no direct regulatory changes are introduced. Key observations include a significant rise in total fine amounts to over €100 million (from €71 million in 2023) despite stable sanction volumes (975 vs. 976), with MAR (377 sanctions, €45.5 million) and MiFID II/MiFIR (294 sanctions, €44.5 million) dominating. Notable shifts: increased settlement usage (94 agreements for €21.9 million, 22% of total), with AM
Key Dates
16 October 2025 - ESMA publishes second consolidated Annual Sanctions Report for 2024 data.
covering 2024 activities.
Compliance Impact
Urgency: medium – This report reinforces existing rules without new requirements, but signals escalating financial penalties (up 40% YoY) and settlement trends, pressuring firms to prioritize MAR/MiFID compliance to avoid outsized AMF-style fines, especially in France or cross-EEA operations. Matter
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Savings protection Warning Other professionals Executive & other private individuals Retail investors Professional investors Journalists Investment management companies Listed companies and issuers The AMF has...
The AMF enforced a trading suspension on MEXEDIA S.p.A. shares on Euronext from 11 September 2025 to 30 September 2025 due to indicators of **pump and dump** market abuse, urging investors to exercise extreme caution against unauthorized high-upside recommendations. This enforcement action underscores the AMF's proactive market surveillance and highlights ongoing risks of manipulative practices in listed equities, serving as a reminder for firms to bolster internal controls against such schemes. Compliance teams should note this as a signal of heightened regulatory scrutiny on price manipulation, potentially informing future enforcement trends.
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What Changed
This is an enforcement action rather than new regulatory changes; no legislative or rule amendments are introduced. Key elements include:
AMF's invocation of financial markets and market abuse regulations to mandate trading suspension via Euronext.
Explicit warning on pump and dump tactics, defined as unauthorized promotions inflating share prices for insider sales, leading to investor losses.
Follow-up resumption of trading on 1 October 2025 after suspension ended, with continued vigilance call
What You Need To Do
- Trading venues (e.g., Euronext)
- Investment firms and brokers
- Advisory firms
- All surveilled firms
- Investors and firms assisting them
Key Dates
11 September 2025 - Trading suspension in MEXEDIA shares effective at end of session.
12 September 2025 - AMF press release published (French version).
30 September 2025 - Scheduled end of suspension period (inclusive).
1 October 2025 - Resumption of trading confirmed; pre-suspension orders purged.
Compliance Impact
Urgency: Medium - This is a resolved, case-specific enforcement (suspension lifted 1 October 2025), not imposing new firm-wide rules, reducing immediate action needs as of January 2026. It matters for market abuse surveillance programs, signaling AMF's focus on pump-and-dump in equities, which could
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Sanctions & settlements professional obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines an asset management company and its two managers a total of €1.3 million
The AMF Enforcement Committee fined asset management company Altaroc Partners €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) a total of €1.3 million on 15 September 2025 for breaches of professional obligations, including non-operational investment procedures, inadequate AML/CFT due diligence, deficient marketing materials, and unproven benefits from fee retrocessions to distributors. This decision underscores the AMF's heightened scrutiny on operational controls and senior accountability in asset management, serving as a critical enforcement signal for firms to strengthen procedures amid a pattern of similar sanctions.
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What Changed
This is an enforcement action rather than new legislation, but it reinforces and clarifies existing professional obligations under AMF regulations for asset managers (sociétés de gestion), particularly under the AIFM regime. Key expectations highlighted include:
Operational investment/divestment procedures: Must be fully implemented, with traceability of checks on lender authorizations and compliance with fund policies.
AML/CFT due diligence: Systematic verification required on fund assets and l
What You Need To Do
- Audit procedures immediately
- Enhance AML/CFT systems
- Validate marketing and fees
- Senior manager training
- Mock AMF inspections
Key Dates
15 September 2025 - AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners, Maurice Tchenio, and Patrick de Giovanni.
16 September 2025 - French version of press release published.
Post-15 September 2025 (exact date unspecified) - Appeal lodged by Altaroc Partners, Tchenio, and de Giovanni before the Conseil d’État against decision SAN-2025-09.
Compliance Impact
Urgency: High – This fits a 2025 enforcement trend targeting asset managers' operational deficiencies (e.g., similar fines against Novaxia Investissement on 10 December 2025, M Capital Partners on 31 December 2025, and Eternam on 9 September 2025), signaling AMF's zero-tolerance for non-operational
Asset Manager
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations
The AMF Enforcement Committee fined an asset management company €400,000 on 9 September 2025 for multiple breaches of professional obligations, including deficient marketing disclosures, inadequate conflict of interest systems, non-operational valuation procedures, failure to oversee external experts, and deficient AML/CFT systems in managing AIFs and club deals. This enforcement action underscores the AMF's focus on operational robustness and investor protection in asset management, serving as a critical reminder for firms to ensure procedures are not only documented but fully operational and effective. Compliance teams should review this to benchmark internal controls, as it highlights personal accountability for senior managers and recurring AMF priorities in recent sanctions.
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What Changed
This is an enforcement decision, not a regulatory change introducing new rules; it enforces existing professional obligations under AMF jurisdiction for asset managers. Key requirements reaffirmed include:
Providing comprehensive, accurate, and understandable information to investors on fee retrocessions to distributors in AIF marketing.
Implementing effective systems for preventing and managing conflicts of interest, particularly in joint investments like club deals classified as Other AIFs.
Ma
What You Need To Do
- Verify investor disclosures on fee retrocessions are comprehensive and understandable; update marketing materials for AIFs and club deals accordingly
- Formalize independent valuer roles and implement monitoring for external experts per activity programs
- Enhance AML/CFT due diligence on fund assets/liabilities, including risk mapping and procedure testing
- Senior managers
- Test procedures via internal audits; remediate deficiencies proactively to mitigate enforcement risk
Key Dates
9 September 2025 - AMF Enforcement Committee decision imposing €400,000 fine on Eternam for breaches.
Compliance Impact
Urgency: High – This recent (2025) decision aligns with a pattern of AMF fines on asset managers for similar operational and AML failures (e.g., €1.3M on Altaroc Partners for lacking investment procedures and AML due diligence; €200K+ on M Capital for non-operational systems and AML deficiencies). I
Asset Manager
Sanctions & settlements professional obligations Disclosure Obligations Other professionals Journalists The AMF Enforcement Committee fines a Danish investment bank for breaches of professional obligations committed by a French branch
The AMF Enforcement Committee imposed a €300,000 fine on Saxo Bank A/S on 16 July 2025 for multiple breaches of professional obligations committed through its French branch, including failures to properly inform clients about significant changes to derivatives procedures, margin calculations, and securities transaction incidents, as well as deficiencies in equity savings plan (PEA) transfers. This enforcement action demonstrates the AMF's active oversight of cross-border investment banks operating in France and highlights critical gaps in client disclosure practices that compliance teams must address.
What Changed
The enforcement decision does not introduce new regulatory requirements but rather clarifies existing obligations under current French financial regulations. The key compliance expectations reinforced include:
Client notification requirements for significant procedural changes affecting derivatives trading and margin calculations
Incident disclosure obligations for securities transactions that could materially affect order execution
Timely information provision regarding regulatory consequences
What You Need To Do
- *Implement incident reporting protocols for securities transactions that could affect order execution, with documented evidence of timely client notification
- *Review PEA transfer procedures to ensure compliance with regulatory timeframes and proper documentation of information provided to clients regarding Brexit-related consequences
- *Strengthen information governance to ensure all material operational changes are communicated to clients within required timeframes and with appropriate detail
- *Conduct compliance training for front-office and operations staff on professional obligations regarding client communication and information disclosure
Key Dates
16 July 2025 - AMF Enforcement Committee decision issued imposing €300,000 fine
22 July 2025 - Official publication of enforcement decision
No specified deadline - Appeal period available (no specific timeframe stated in the decision)
Compliance Impact
Urgency: HIGH
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Sanctions & settlements MAR professional obligations Investment advice Other professionals Journalists Listed companies and issuers The AMF Enforcement Committee fines eight individuals and two legal entities a total of €1,890,000 for late...
All Firms
Sanctions & settlements MAR Journalists Listed companies and issuers The AMF Enforcement Committee fines an issuer €20,000 and its shareholders a total of €1.7 million
The AMF Enforcement Committee imposed fines totaling €1.72 million on 10 June 2025 against SMCP (an issuer) and its major shareholders European TopSoho, Dynamic Treasure Group, and Ms. Chenran Qiu for breaches including failure to report threshold crossings in shareholdings, disseminating false or misleading information constituting market manipulation, and SMCP's lapse in maintaining inside information confidentiality. This decision underscores AMF's rigorous enforcement of **Market Abuse Regulation (MAR)** obligations on issuers and shareholders, serving as a deterrent against opaque share transactions and premature disclosures that undermine market integrity. Compliance teams should prioritize robust monitoring of ownership changes and information controls to avoid similar sanctions, which can reach seven figures for individuals and entities.
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What Changed
This is an enforcement decision, not a regulatory change introducing new rules; it reinforces existing obligations under French financial markets law and MAR:
Shareholder reporting thresholds: Mandatory notification to AMF and issuers for crossing above or below capital/voting rights thresholds, plus six-month plans.
Prohibition on false/misleading information: Press releases denying control over entities when factual arrangements prove otherwise qualify as market manipulation.
Inside informatio
Key Dates
10 June 2025 - AMF Enforcement Committee decision issued, imposing fines.
Post-10 June 2025 - Appeal window opened; European TopSoho lodged appeal before Paris Court of Appeal.
Compliance Impact
Urgency: Medium - Matters due to substantial fines (€1.72M total, including €1M personal), personal liability for controllers, and appeal pending, signaling ongoing risk. Not critical as it's backward-looking enforcement (events 2016-2021), but elevates priority for listed firms handling ownership c
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Sanctions & settlements Executive & other private individuals Journalists The AMF Enforcement Committee fines three individuals and one legal entity a total of €700,000 for insider dealing breaches
The AMF Enforcement Committee imposed fines totaling €700,000 on three individuals and one legal entity for insider dealing violations, demonstrating the regulator's ongoing commitment to enforcing Market Abuse Regulation (MAR) prohibitions on trading with inside information. This case underscores the AMF's aggressive pursuit of insider networks and coordinated breaches, serving as a stark reminder for firms to bolster insider trading surveillance and training programs. Compliance teams should use it to reinforce policies amid rising detections of organized insider activities.
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What Changed
This is an enforcement action, not a regulatory change; it reaffirms existing MAR requirements under Articles 7 (inside information definition), 8 (insider lists), 14 (insider dealing prohibition), 17 (public disclosure), and 19 (PDMR trading restrictions, including 30-day black-out periods before financial results). No new rules are introduced, but it highlights AMF's reliance on firms for detection via internal policies, whistleblowing, and gift/invitation controls, as echoed in recent AMF-AFA
What You Need To Do
- Update insider policies
- Enhance training and awareness
- Strengthen surveillance
- Report promptly
- Conduct audits
Key Dates
December 4, 2024 - EU Regulation 2024/2809 enters force , amending MAR on inside information and disclosures.
June 5, 2026 - Certain amendments to insider trading policies (e.g., Groupe Casino policy) apply ; others immediate from February 2025.
June 30, 2026 - AMF General Regulation updates effective , covering certifications for financial instruments and prospectuses.
Within 3 trading days - PDMRs must report securities transactions to issuer and AMF.
Compliance Impact
Urgency: High – This enforcement signals intensified AMF focus on insider networks, with fines demonstrating willingness to penalize both individuals (€700,000 total) and entities amid a "worrying trend" of organized crime infiltration. Firms face elevated inspection risks, especially post-AMF-AFA v
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Sanctions & settlements Journalists Listed companies and issuers The AMF Enforcement Committee clears three individuals and one legal entity for insider dealing breaches
The AMF Enforcement Committee dismissed insider dealing charges against three individuals and one legal entity, determining insufficient evidence of inside information use or disclosure. This decision underscores the Committee's rigorous evidentiary standards in market abuse cases, offering reassurance to compliance teams that weak indicia alone do not trigger sanctions, while reinforcing the need for robust defenses in investigations. It matters because it provides interpretive guidance on proving insider dealing, potentially reducing overreach in enforcement but heightening focus on documentation and transaction rationales.
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What Changed
No new regulatory changes or requirements are introduced; this is an enforcement decision, not a rulemaking. It clarifies application of existing Market Abuse Regulation (MAR) rules under AMF jurisdiction, emphasizing that sanctions require concrete proof beyond timing, atypical trades, or plausible disclosure channels—such as unconvincing explanations alone are insufficient for liability. The ruling aligns with prior cases where the Committee has cleared parties when evidence falls short, as se
What You Need To Do
- Enhance insider list maintenance and training to preempt failures, as fined in parallel cases
- Document transaction rationales proactively (e
- Conduct regular MAR compliance audits, focusing on disclosure channels and trade timing surveillance
- Review internal policies against AMF Enforcement Committee precedents, ensuring defenses emphasize alternative explanations for trades
Compliance Impact
Urgency: Medium—not critical as no new rules or fines imposed, but matters for firms under AMF scrutiny or with high insider dealing risk, as it illustrates acquittal thresholds (e.g., insufficient indicators like timing alone). Heightened relevance amid ongoing AMF enforcement wave on market abuse,
Broker DealerAll Firms
Sanctions & settlements Journalists The AMF Enforcement Committee fines three individuals a total of €590,000 for price manipulation
The AMF Enforcement Committee fined three individuals a total of €590,000 for engaging in price manipulation on French markets, highlighting the regulator's aggressive stance against market abuse. This enforcement action underscores the risks of coordinated trading schemes that distort supply, demand, or prices, serving as a deterrent for market participants. Compliance teams should note it as evidence of heightened AMF scrutiny on manipulative behaviors, even absent full case details.
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What Changed
This is an enforcement decision, not a regulatory change; it reaffirms existing prohibitions under the French Monetary and Financial Code (Article L. 433-1-2) and EU Market Abuse Regulation (MAR, Regulation (EU) No 596/2014) against price manipulation, including fixing prices at artificial levels, disseminating false/misleading signals on supply/demand, or using deceptive orders. No new requirements are introduced, but it signals AMF's interpretation of manipulation in coordinated individual act
Key Dates
11 December 2024 AMF decision fining entities €4.15M for false info and price manipulation.
24 January 2024 AMF decision fining seven for price manipulation (€400k-€2M); appeals filed, partial stay granted 10 July 2024.
19 July 2024 AMF fines Parrot and directors €420k total for manipulation.
13 December 2024 AMF fines US fund €10M for IPO-related manipulation.
15 September 2025 AMF fines asset managers €1.3M total (future-dated relative to publication patterns).
Compliance Impact
Urgency: High - Matters due to escalating fines (e.g., €590k here, up to €10M in ) and personal liability for individuals, amid AMF's pattern of 2024-2025 actions targeting manipulation across assets. Non-compliance risks reputational damage, trading bans, and appeals (e.g., ongoing in ); firms must
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Sanctions & settlements professional obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines Pharnext and its former directors a total of €800,000
The AMF Enforcement Committee fined Pharnext €500,000 and its former directors Daniel Cohen (€200,000) and David Horn Solomon (€100,000) on 20 January 2025 for failing to disclose inside information promptly and disseminating false or misleading information about FDA interactions for a drug candidate. This enforcement action reinforces AMF's strict stance on market abuse rules under EU MAR, highlighting personal liability for directors in listed biotech firms where investor expectations around product approvals are high. Compliance teams should note it as a reminder of timely disclosure obligations, especially amid appeals filed by the parties.
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What Changed
This is not a regulatory change but an enforcement decision applying existing obligations under the Market Abuse Regulation (MAR), specifically:
Article 17 MAR: Requirement to disclose inside information as soon as possible (breached by Pharnext's delays from 10 April 2019 and non-disclosure from 28 October 2020).
Article 12(1)(c) MAR: Prohibition on disseminating false or misleading information that could affect market prices, via press releases and shareholder letters overstating FDA progress.
What You Need To Do
- Review inside information policies
- Audit communications
- Director training
- Monitor appeals
- wide actions mandated beyond general MAR compliance, but proactive gap analysis recommended
Key Dates
10 April 2019 - FDA request for additional study deemed inside information; not disclosed until 30 August 2019.
28 October 2020 - FDA 'non-agreement' on clinical study design deemed inside information; never publicly disclosed.
20 January 2025 - AMF Enforcement Committee decision imposing fines (SAN-2025-01).
23 July 2025 - Paris Court of Appeal dismissed David Horn Solomon's stay of execution application (n°25/05331).
Post-20 January 2025 - Appeal lodged by Pharnext, Cohen, and Solomon to Paris Court of Appeal (ongoing).
Compliance Impact
Urgency: Medium – This is a specific enforcement (not a new rule), but it signals heightened AMF scrutiny on biotech disclosures amid investor sensitivity to approval news; delays in similar cases could trigger investigations/fines up to 15% of turnover or €15M. Matters for listed firms with pipelin
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Sanctions & settlements MAR Other professionals Executive & other private individuals Listed companies and issuers The AMF Enforcement Committee fines a US investment fund and its director a total of €10 million for price manipulation during an initial public offering...
The AMF Enforcement Committee fined US-based investment fund EcoR1 Capital €7 million and its director Oleg Nodelman €3 million (total €10 million) on 13 December 2024 for price manipulation via "marking the close" trades on Euronext Paris during Innate Pharma's 2019 Nasdaq IPO, plus reporting failures on 5% ownership thresholds. This case demonstrates AMF's extraterritorial reach over foreign actors impacting French markets and underscores personal liability for executives in market abuse violations under MAR.
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What Changed
This is an enforcement decision, not a regulatory change; it reinforces existing MAR prohibitions on price manipulation (Article 12), specifically "fixing the price at an abnormal or artificial level" through timed sales at market close to influence linked ADS pricing on Nasdaq. It also highlights ongoing scrutiny of reporting obligations under Article L. 233-7 of the French Commercial Code for crossing 5% thresholds in listed companies.
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What You Need To Do
- Implement pre-trade surveillance for "marking the close" patterns, especially around issuer events like IPOs where Euronext closes influence external pricing
- Enhance 5% threshold monitoring with automated alerts and timely filings (4 trading days post-threshold)
- Conduct senior manager training on personal liability under MAR for manipulative orders benefiting the firm (e
- Review cross-border trading policies for French-listed assets, including jurisdiction assessments for non-EU funds
- Perform gap analysis on order timing controls to flag end-of-day volume spikes
Key Dates
October 10-16, 2019 - Five trading sessions during which manipulative "marking the close" sales occurred on Euronext Paris.
2019 (exact dates unspecified) - Instances of failing to report exceeding/falling below 5% ownership thresholds in Innate Pharma.
13 December 2024 - AMF Enforcement Committee decision date imposing fines.
16 December 2024 - French version of press release published.
Compliance Impact
Urgency: Medium - Matters due to AMF's aggressive fines (€10M total) and personal accountability for a US fund/director, signaling heightened cross-border enforcement on Euronext trades. Firms should prioritize surveillance upgrades now, as appeals are possible but do not suspend implications; low i
Hedge FundAsset Manager
Sanctions & settlements Disclosure Obligations Journalists Listed companies and issuers The AMF Enforcement Committee imposes fines totalling €4,150,000 on four legal entities and three natural persons for disseminating false or misleading information, and price manipulation
The AMF Enforcement Committee imposed fines totaling €4,150,000 on December 11, 2024, against Auplata (an issuer), its former CEO Didier Tamagno, statutory auditors RSM Paris and Stéphane Marie (€50,000-€300,000 range), and fund entities European High Growth Opportunities Manco SA, Alpha Blue Ocean Inc., and director Pierre Vannineuse (€1,000,000-€1,500,000 range) for disseminating false or misleading information in press releases and financial statements, plus share price manipulation via unauthorized sales. This decision underscores the AMF's rigorous enforcement of market abuse rules under French financial regulations, serving as a critical reminder for issuers, auditors, and investment managers to ensure transparent disclosure of financing terms and compliance with share disposal commitments, with appeals already lodged at the Paris Court of Appeal.
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What Changed
This is an enforcement action, not a regulatory change; it reinforces existing obligations under AMF rules prohibiting false/misleading information (e.g., omitting key clauses in financing agreements like ODIRNANEs with BSAs, failing to disclose earn-outs or include them in going concern analyses) and price manipulation (e.g., breaching share retention and daily sales volume limits). No new requirements were introduced, but the decision clarifies interpretive application: auditors face liability
What You Need To Do
- Review disclosure practices
- Enhance auditor coordination
- Strengthen trading controls
- Training and policies
- Monitor appeals
Key Dates
11 December 2024 - AMF Enforcement Committee decision issued, imposing fines.
Post-11 December 2024 - Appeals lodged by European High Growth Opportunities Manco SA, Alpha Blue Ocean Inc., Auplata Mining Group AMG, RSM Paris SAS, Stéphane Marie, and Pierre Vannineuse before the Paris Court of Appeal (exact filing date not specified).
Compliance Impact
Urgency: High - Matters due to substantial fines (up to €1.5M per entity), personal liability for executives/auditors, and broad applicability to disclosure/manipulation risks in equity financings; recent timing (2024 decision, ongoing appeals) signals AMF's active enforcement focus, prompting immed
Asset ManagerAll Firms
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines a financial investment advisor, two asset management companies and their directors, and a credit institution a total of €5,670,000
The AMF Enforcement Committee imposed total fines of €5,670,000 on a financial investment advisor (FIA), two asset management companies (AMCs), their directors, and a credit institution for breaches of professional obligations. This enforcement action underscores the AMF's rigorous scrutiny of operational controls, due diligence, and governance in investment services, serving as a critical reminder for firms to maintain robust procedures to avoid similar sanctions. It matters because it highlights personal liability for directors and escalating fines for systemic failures, potentially influencing peer reviews and audit priorities.
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What Changed
This is an enforcement decision, not a regulatory change introducing new rules. It reinforces existing AMF requirements under professional obligations, including:
Implementation of operational procedures for investment/divestment processes, such as verifying lender authorizations.
Systematic anti-money laundering (AML) and counter-terrorism financing (CTF) due diligence on fund assets and liabilities.
Justification of retrocessions (rebates) to distributors, proving enhanced client service quali
What You Need To Do
- Conduct gap analysis of operational procedures for investments/divestments, ensuring lender authorization checks (reference AMF Position-Recommendation DOC-2020-05 on portfolio management)
- Review AML/CTF due diligence frameworks for fund assets/liabilities, aligning with AMF Regulation 2016-01
- Audit retrocession practices to distributors, documenting service quality enhancements (per AMF doctrine on inducements)
- Update marketing materials and advisory processes for compliance with honesty/fairness standards
- Enhance senior manager attestations and training on personal liability under CMF L
Key Dates
2026 ) - AMF Enforcement Committee decision fining €5,670,000 total.
15 September 2025 Altaroc Partners decision (appeal lodged to Conseil d’État).
9 July 2025 MND insider dealing decision (appeal to Paris Court of Appeal).
10 December 2025 Novaxia Investissement decision.
5 November 2025 Carat GP FIA decision.
Compliance Impact
Urgency: High – This signals intensified AMF enforcement on professional obligations in 2025 (multiple similar fines: €1.3M, €1.89M, €0.5M, €2.5M implied, €0.305M, €3.5M), with personal bans and multimillion fines. Matters due to director accountability trends, potential for follow-on audits, and ed
Asset ManagerWealth ManagerBank
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines Sogenial Immobilier and its chairman a total of €180,000
The AMF Enforcement Committee issued a €180,000 combined fine against Sogenial Immobilier (€150,000) and its chairman Jean-Marie Souclier (€30,000) on September 12, 2024, for systematic breaches of professional obligations spanning investment selection, regulatory disclosure, conflict of interest management, and anti-money laundering compliance. This enforcement action demonstrates the AMF's heightened scrutiny of asset managers' operational controls and substantive compliance with fund governance requirements, particularly regarding real estate investment companies (SCPIs).
What Changed
The decision does not introduce new regulatory requirements but rather clarifies enforcement expectations across existing obligations:
Regulatory Documentation Standards: Asset managers must implement documented procedures governing the preparation of all regulatory and marketing materials for alternative investment funds, with particular attention to accurate risk disclosure and asset return reporting.
Investment Due Diligence Standards: A "high standard of diligence" is required when selecti
What You Need To Do
- *Audit Existing Procedures
- *Formalize Investment Selection Process
- *Enhance Conflict of Interest Controls
- *Implement Comprehensive AML/CFT
- *Strengthen Internal Control Functions
Key Dates
September 12, 2024 - AMF Enforcement Committee issued the decision
September 16, 2024 - Public announcement of sanctions
No specified deadline - Appeal period remains open (appeals may be lodged against the decision)
Compliance Impact
Urgency: HIGH
Asset Manager
Sanctions & settlements Disclosure Obligations Journalists AMF Enforcement Committee fines Biosynex, its CEO and several of its directors a total of €930,000
The AMF Enforcement Committee fined Biosynex and four directors (plus their holding companies) a total of €930,000 on 25 July 2024 for breaches including selective disclosure of inside information via a CEO interview, insider trading by selling shares on non-public knowledge of a treasury share sale, and failures to report share transactions to the AMF. This matters as it reinforces AMF's strict enforcement of MAR (Market Abuse Regulation) rules on information dissemination, insider dealing, and PDMR reporting, serving as a precedent for listed companies and executives during high-volatility periods like COVID-19. Appeals by some parties were dismissed as inadmissible by the Paris Court of Appeal on 9 January 2025.
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What Changed
This is an enforcement decision, not a regulatory change; it applies existing requirements under EU MAR (Regulation (EU) No 596/2014, transposed in France) and AMF rules:
Selective disclosure: Issuers must ensure "full and effective" public dissemination of inside information via press releases before any selective sharing (e.g., interviews); partial disclosure to a "restricted audience" (like journalists) without prior release violates this.
Insider trading: Prohibits trading (including selling
What You Need To Do
- Implement pre-approval for executive media interactions: Require scripts/press releases issued simultaneously with interviews to avoid selective disclosure
- Enhance insider lists and trading controls
- Automate transaction reporting
- Conduct MAR training refreshers
- Audit past disclosures
Key Dates
25 July 2024 - AMF Enforcement Committee decision issuing fines.
March-April 2020 - Violation period (interview on 20 March 2020; share sales and unreported transactions).
9 January 2025 - Paris Court of Appeal dismisses appeals by CEO Abensur, CFO Fraenckel, and ALA Financière as inadmissible (case n° 24/16188).
Compliance Impact
Urgency: Medium - Not a new rule but a high-profile enforcement (€930k total: Biosynex €50k; CEO/holding €460k; others €70k-€230k each) highlighting personal liability for executives, with appeals failing. Matters for listed firms as it stresses "full/effective" dissemination and rejects operational
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Sanctions & settlements Disclosure Obligations Professional investors The AMF Enforcement Committee fines an issuer and two of its former directors at the time of the facts for market manipulation by disseminating false or misleading information. It also fined one of the directors for insider...
The AMF Enforcement Committee imposed fines on an issuer and two former directors for market manipulation via dissemination of false or misleading information, with an additional fine on one director for insider trading violations. This enforcement action underscores the AMF's rigorous enforcement of market abuse rules under the Market Abuse Regulation (MAR), serving as a stark reminder of personal and corporate liability for disclosure failures and privileged information misuse. Compliance teams must prioritize robust controls to mitigate similar risks, as such violations erode market integrity and investor trust.
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What Changed
This is an enforcement decision rather than new legislation, so there are no direct regulatory changes. It reinforces existing obligations under Book VI of the AMF General Regulation on market abuse, including insider dealing and market manipulation, aligned with Regulation (EU) No 596/2014 (MAR). Key principles upheld include prohibitions on disseminating false/misleading information that impacts security prices and trading on inside information, with no novel requirements but heightened emphas
What You Need To Do
- Implement or strengthen disclosure controls to ensure all public information is accurate and non-misleading, with pre-approval for promotional materials submitted to AMF
- Enhance insider lists and training for directors on MAR prohibitions, including trading blackouts before announcements
- Deploy surveillance systems to detect market manipulation signals, with compliance officers mandated to report suspicious transactions to AMF
- Conduct due diligence attestations for prospectuses/public offers, confirming no material omissions
- Review governance for personal liability, including cooperation incentives in investigations per proposed AMF powers
Key Dates
30 June 2026 - End of MiCA transitional period; AMF to fully enforce crypto-asset market abuse under MAR-equivalent rules.
30 June 2026 - AMF General Regulation updates effective, enhancing MAR reporting procedures (e.g., Articles 145-1 to 145-4).
Compliance Impact
Urgency: High - This demonstrates AMF's aggressive stance on market abuse amid rising "insider networks" and organized crime threats, with fines signaling personal risk for directors. It matters because enforcement is intensifying (e.g., web scraping for investigations, expanded sanctions like 10-ye
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Sanctions & settlements professional obligations Journalists Investment management companies AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness and personal accountability in asset management, serving as a regulatory warning for firms to strengthen internal controls or face escalating sanctions.
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What Changed
This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and fully operational; failure to verify compliance (e.g., loan authorizations) breaches honesty, fairness, and diligence standards.
Scope of services: Asset managers acting as tied agents cannot provide unauthorized services like placing financial instrumen
What You Need To Do
- Conduct gap analysis
- Enhance AML/CFT
- Strengthen governance
- Audit marketing/distribution
- Senior manager certification
Key Dates
31 December 2025 - AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors.
August 2019 - December 2023 - Period of identified breaches (investment services, processes, AML/CFT deficiencies).
08 January 2026 - Public press release publication date.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision, alongside similar fines (e.g., €1.3M on Altaroc Partners in Sep 2025, €400k on Eternam in Sep 2025), signals AMF's intensified scrutiny on asset manager operations post-AIFMD reviews, with personal fines rising (up to €500k+). Non-compliance risks enf
Asset Manager
Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breaches of their professional obligations
The AMF Enforcement Committee has issued multiple enforcement decisions against financial investment advisors and their management for breaches of professional obligations, with the most recent and significant case involving Carat GP and its directors receiving combined fines of €2.5 million and permanent/extended bans from operating as financial investment advisors. These cases establish critical precedent regarding advisor duties around client disclosure, product authorization, conflict of interest management, and honest/fair conduct—requirements that apply across the entire financial investment advisory sector.
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What Changed
The enforcement decisions clarify and reinforce several core professional obligations for financial investment advisors:
*Transparency and Disclosure Obligations**
Financial investment advisors must inform clients of any remuneration received for their advice and justify improvements to advisory services in return for compensation received. Advisors cannot recommend financial products without first ensuring their marketing is authorized in the relevant jurisdiction.
*Competence and Care Standa
What You Need To Do
- *Immediate Compliance Review
- *Governance and Documentation
- *Training and Culture
- *Regulatory Engagement
Key Dates
19 December 2023 - AMF Enforcement Committee decision against Séquence 13 and Jean-Louis Lehmann (€15,000 fines each; 5-year ban)
11 April 2022 - AMF Enforcement Committee decision against DCT and Didier Maurin (€150,000 and €200,000 fines; 5-year ban)
9 September 2024 - Conseil d'Etat judgment dismissing appeal by DCT and Didier Maurin
24 October 2022 - AMF Enforcement Committee decision against Salzillo Finance and Jean Salzillo (€20,000 and €80,000 fines; 3-year ban)
2 July 2019 - AMF Enforcement Committee decision against Invest Securities and financial advisors (€90,000 to €60,000 fines)
Compliance Impact
Urgency: HIGH
Asset ManagerWealth ManagerBroker Dealer
Sanctions & settlements Journalists AMF Enforcement Committee fines one individual and clears two others for insider dealing breaches
The AMF Enforcement Committee sanctioned one individual with a fine for insider dealing violations while acquitting two others in a case involving breaches of market abuse rules under the Market Abuse Regulation (MAR). This decision underscores the AMF's rigorous enforcement of insider trading prohibitions, emphasizing evidence-based liability determinations and serving as a reminder for firms to strengthen insider monitoring and training programs. It matters because it highlights the risks of coordinated insider networks and the importance of robust compliance frameworks to mitigate personal and corporate exposure.
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What Changed
This is an enforcement decision, not a regulatory amendment, so there are no new rules or requirements introduced. It reaffirms existing obligations under MAR Articles 7 (prohibition of insider dealing), 8 (unlawful disclosure of inside information), 10 (public disclosure of inside information), 14 (abuse of inside information), 17 (fair presentation and disclosure), and 19 (PDMR transactions), as well as AMF General Regulations Articles 223-9 and 221-3. Key takeaways include strict trading rest
What You Need To Do
- Review and update insider trading policies to align with AMF Position-Recommendation No
- Implement or strengthen training on MAR prohibitions, insider network risks, and whistleblowing mechanisms, especially for those handling M&A, results announcements, or advisor roles
- Monitor and log gifts, donations, transactions in derivatives/index products, and PDMR dealings; notify insiders of blackouts via Insider Trading Committee
- Enhance surveillance for coordinated trading patterns pre-announcements (e
- For listed firms
Key Dates
Within 3 trading days PDMRs must report securities transactions to issuer and AMF. DEADLINE
30 calendar days prior to annual/interim results publication Statutory blackout period for PDMRs.
15 calendar days prior to quarterly financial info publication Recommended blackout for insiders per AMF guidance.
5 June 2026 Certain amendments in sample insider policies apply (e.g., enhanced disclosures).
Compliance Impact
Urgency: Medium. This reinforces longstanding MAR rules without new mandates, but the acquittal of two individuals signals AMF's focus on provable evidence, reducing overreach risks while heightening scrutiny on networks. It matters amid rising organized crime threats (AMF 2024 report), prompting im
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Appointment Sanctions & settlements Journalists Valérie Michel-Amsellem becomes Chair of the AMF Enforcement Committee
This AMF publication announces the appointment of Valérie Michel-Amsellem as the new Chair of the AMF Enforcement Committee, the independent body responsible for imposing sanctions in financial market violations. It matters for compliance professionals because leadership changes in enforcement can signal shifts in sanctioning priorities, rigor, or focus areas, potentially influencing how firms approach risk management and remediation. While no immediate policy changes are introduced, monitoring the new Chair's tenure is essential given the Committee's role in upholding market integrity.
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What Changed
There are no substantive regulatory changes, new requirements, or amendments to the AMF General Regulation outlined in this announcement. The publication solely details an internal governance appointment within the AMF's structure, where the Enforcement Committee maintains its established autonomy for sanction decisions, separate from the AMF Board. This aligns with prior affirmations of the Committee's independence, as upheld in ECHR rulings on its impartiality.
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What You Need To Do
- Review backgrounds of key AMF personnel, including Valérie Michel-Amsellem, for insights into enforcement trends (e
- Enhance internal monitoring of AMF sanction releases (https://www
- Conduct gap analyses on compliance programs for high-risk areas like market abuse, given the Committee's sanction powers up to €100 million or 10x profits
Key Dates
Immediate - Appointment takes effect upon announcement, with no disclosed transition period.
2026 , Enforcement Committee sanction against an asset management company, indicating ongoing enforcement operations.
Compliance Impact
Urgency: Low - This personnel change does not impose new obligations or alter existing rules, posing minimal immediate risk. It matters indirectly for long-term strategy, as the Chair could steer enforcement toward stricter penalties or novel interpretations of obligations (e.g., as analyzed in hist
Asset ManagerBroker DealerBank Appointment Sanctions & settlements Journalists Appointements to the AMF Enforcement Committee
This AMF publication announces the partial renewal of the Enforcement Committee, including four new appointments, two reappointments, and the subsequent election of Valérie Michel-Amsellem as Chair on 28 February 2024. It matters for compliance professionals as changes in committee composition can influence enforcement priorities, sanction severity, and interpretations of financial regulations under AMF jurisdiction.
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What Changed
There are no new regulatory requirements or substantive changes to laws; this is an administrative renewal of the Enforcement Committee's membership. Key developments include: new members Jean-Claude Hassan (Vice-President of the Council of State appointee, also chairs second section), Xavier Samuel (Court of Cassation appointee), Sophie Langlois and Aurélien Soustre (Ministerial appointees); reappointments of Anne Le Lorier and Ute Meyenberg. The committee maintains its structure of 12 independ
Key Dates
13 February 2024 - Ministerial order appointing new and reappointed members.
20 February 2024 - Publication of the ministerial order.
27 February 2024 - Composition published in the Official Journal.
28 February 2024 - First meeting; election of Valérie Michel-Amsellem as Chair and Jean-Claude Hassan as second section Chair.
Compliance Impact
Urgency: low - This personnel change poses minimal immediate risk but signals potential evolution in enforcement tone under new leadership experienced in sanctions and regulation (e.g., Michel-Amsellem's appellate background). It matters longer-term for firms in protracted AMF proceedings, as commit
Asset ManagerBroker DealerBank Sanctions & settlements Journalists The AMF Enforcement Committee clears twelve individuals for insider dealing breaches
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Sanctions & settlements Disclosure Obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines seven people, four for price manipulation and three for failing to comply with reporting obligations
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Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations
The AMF Enforcement Committee imposed sanctions on SPI (a financial investment advisor) and its director Vincent Rhodes on 9 January 2024 for breaching professional obligations. This case demonstrates the AMF's enforcement priorities regarding advisor conduct standards and establishes precedent for disciplinary action against both firms and individual managers who fail to meet regulatory requirements.
What Changed
The decision does not introduce new regulatory requirements but rather clarifies enforcement of existing professional obligations for financial investment advisors. The case reinforces that advisors must:
Comply with all applicable laws and regulations governing financial investment advisory activities
Maintain professional standards in their dealings with clients and regulators
Ensure their directors and managers operate within regulatory boundaries
The enforcement action reflects the AMF's i
What You Need To Do
- *For Financial Investment Advisors
- *Review compliance frameworks - Audit existing policies and procedures against the professional obligations that triggered this enforcement action
- *Enhance governance controls - Implement systems to ensure directors and senior management comply with regulatory requirements
- *Document compliance - Maintain records demonstrating adherence to professional conduct standards
- *Staff training - Ensure all personnel understand the scope of professional obligations and consequences of breach
Key Dates
9 January 2024 - AMF Enforcement Committee decision imposing sanctions on SPI and Vincent Rhodes
Immediate effect - 2-year temporary ban on both respondents from exercising financial investment advisor activities commenced following the decision
Compliance Impact
Urgency: HIGH
Wealth ManagerBroker DealerAsset Manager
Markets MAR Corporate action Shares Market manipulation identified and reported by the AMF sanctioned by the Paris Tribunal Correctionnel
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Sanctions & settlements Disclosure Obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines a former manager of a listed company for failing to disclose inside information as soon as possible and for failing to disclose major shareholdings
The AMF Enforcement Committee imposed a fine on a former manager of a listed company for two violations: failing to disclose inside information to the public as soon as possible under Article 17 of the EU Market Abuse Regulation (MAR), and failing to disclose major shareholdings as required by French regulations. This enforcement action underscores the AMF's strict enforcement of market abuse rules, emphasizing personal accountability for executives in ensuring timely transparency to prevent insider trading risks and maintain market integrity. Compliance teams should review it as a reminder of heightened scrutiny on disclosure delays and threshold crossings.
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What Changed
This is not a regulatory change but an enforcement decision reinforcing existing obligations under MAR and AMF General Regulation:
Inside information disclosure: Issuers must publicly disclose inside information "as soon as possible" per Article 17 MAR, unless specific delay conditions are met (legitimate interest, confidentiality ensured, no public misleading). Delays require post-publication notification to AMF at differepublication@amf-france.org.
Major shareholdings disclosure: Persons cross
What You Need To Do
- Assess information promptly
- Declare major shareholdings immediately upon threshold crossing to issuer/AMF; ensure custodians comply with identity disclosure requests
- Use professional information providers for dissemination to ensure wide, secure EU reach; archive on company website
- Train executives on insider lists, transaction reporting (within 3 days if >€20k/year), and penalties (up to €100m fines, criminal sanctions)
Key Dates
3 trading days - Managers/PDMRs must report securities transactions to issuer and AMF if annual total exceeds €20,000. DEADLINE
10 business days - Custodians must respond to Euroclear France/AMF requests for shareholder identity on threshold crossings. DEADLINE
effective 2016 ) and AMF GR.
Compliance Impact
Urgency: High - This matters due to personal fines on managers, signaling AMF's aggressive enforcement of MAR since 2016, with rebuttable presumptions against executives for insider misconduct unless proven otherwise. Firms face reputational risk, investigations, and cascading liabilities (e.g., €10
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Sanctions & settlements professional obligations Investment advice Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations
The AMF Enforcement Committee imposed a five-year ban on financial investment advisor DCT (formerly Didier Maurin Finance) and its director Didier Maurin from practicing, plus fines of €150,000 on the firm and €200,000 on the director, for recommending unauthorized Samoan AIF investments to 64 clients, failing to manage conflicts of interest (e.g., no conflicts register), and breaching duties of competence, care, and diligence in clients' best interests. This matters as it reinforces AMF's strict enforcement on CIFs (Conseillers en Investissements Financiers) for product authorization checks, conflicts management, and client-centric obligations under MiFID II transposition in France, signaling heightened scrutiny on advisory integrity amid rising sanctions. The Conseil d'Etat upheld the decision on 9 September 2024, dismissing appeals and confirming sanctions.
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What Changed
This is an enforcement decision, not a new regulation, but it clarifies and reinforces existing requirements for CIFs:
Product marketing authorization: CIFs must verify that recommended investments (e.g., AIFs) are authorized for sale in France before advising clients; recommending unauthorized products breaches professional obligations regardless of client outcomes.
Conflicts of interest management: CIFs must maintain an effective conflicts register, identify risks (e.g., personal benefits), an
What You Need To Do
- Immediate audit
- Conflicts policy enhancement
- Training and documentation
- Director accountability
Key Dates
11 April 2022 - AMF Enforcement Committee decision imposing bans and fines.
9 September 2024 - Conseil d'Etat judgment (no. 464877) dismissing appeals, upholding sanctions, and ordering €1,500 costs each to AMF.
Compliance Impact
Urgency: High - This upheld decision (post-2024 appeal) exemplifies AMF's pattern of escalating fines/bans on CIFs for conduct failures (e.g., €2.5M on Carat GP in 2025; €120K-€150K on Capexis upheld 2025), amid 2024-2025 enforcement wave on professional obligations. Matters for CIFs as it heightens
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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
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.
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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. No novel rules are intr
What You Need To Do
- Conduct internal audits
- Enhance monitoring systems
- Train personnel
- Update policies
- Cooperate with regulators
Key Dates
Immediate - Report suspicious transactions (insider dealing or manipulation) to AMF without delay.
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).
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
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Sanctions & settlements Journalists The AMF Enforcement Committee fines a French tied agent of a Cypriot investment services provider and its manager for breaches of their professional obligations
The AMF Enforcement Committee fined France Safe Media (FSM), a French tied agent of Cypriot provider VPR Safe Financial Group Limited (Alvexo platform), €300,000 and imposed a 10-year ban from tied agent activities and reception/transmission of orders (RTO) services, while its manager Lior Mattouk received a €100,000 fine and similar 10-year ban, for breaches occurring January 2019–September 2021. This decision, dated 10 November 2023 and upheld by Conseil d'Etat on 16 June 2025, underscores AMF's strict enforcement of professional obligations for tied agents marketing high-risk CFDs, emphasizing staff qualifications, client assessments, risk warnings, disclosures, and diligence. It matters for cross-border intermediaries as it highlights personal liability for managers and the finality of sanctions post-appeal, signaling heightened scrutiny on CFD promotion and tied agent compliance in France.
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What Changed
This is an enforcement action, not a new regulation, but it clarifies and reinforces existing requirements under French rules implementing MiFID II for tied agents:
Staff qualifications: Tied agents must verify sales staff have minimum qualifications and knowledge; post-hoc inadequate tests do not suffice.
Client knowledge/experience assessment: Questionnaires must be robust, with appropriate scoring; account managers cannot interfere (e.g., by prompting answer changes).
Promotional communicatio
What You Need To Do
- Conduct gap analysis
- Enhance manager oversight
- Audit CFD marketing
- Training programs
- Cross-border review
Key Dates
10 November 2023 - AMF Enforcement Committee decision SAN-2023-15 imposing fines and bans.
14 November 2023 - French version of press release published.
16 June 2025 - Conseil d'Etat judgment (n° 490826) dismissing appeals by FSM and Mattouk, confirming sanctions and ordering €4,000 costs to AMF.
Compliance Impact
Urgency: High – Though dated (2019–2021 breaches), the 2025 appeal dismissal makes sanctions final, serving as a binding precedent for tied agents amid AMF's ongoing CFD enforcement wave (e.g., parallel fines on providers like CIC banks). It elevates personal risk for managers and signals intensifie
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Sanctions & settlements Journalists The AMF Enforcement Committee fines two individuals for insider dealing breaches
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.
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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
What You Need To Do
- Enhance surveillance
- Insider list management
- Training programs
- Policies and procedures
- Audit and testing
Key Dates
since 2016 ). Relevant historical dates from this and similar cases:
30 January 2023 Enforcement decision fining 10 parties for Terreïs acquisition insider dealing.
9 July 2021 Decision fining individuals for disclosing/using earnings inside information.
15 May 2024 Fine for using takeover bid information.
9 July 2025 Fines including professional bans for MND-related breaches.
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 u
Broker DealerAll Firms
Sanctions & settlements Journalists Listed companies and issuers The AMF Enforcement Committee fines Rallye and its chief executive officer, Franck Hattab, for market manipulation
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.
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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 com
What You Need To Do
- Review historical/current financial communications for liquidity/debt portrayals; ensure they explicitly address dependencies (e
- Enhance governance
- Audit trails
- Monitor appeals
Key Dates
March 8, 2018 - May 15, 2019 - Period of infringing communications (11 occasions, 14 media).
2016 - Prior AMF Deputy Secretary General warning to Rallye on financial communication quality, specifically liquidity risk presentation.
September 2023 (inferred from context) - AMF Enforcement Committee decision imposing fines.
September 18-19, 2023 - Rallye appeals the AMF decision.
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 sect
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Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness in asset managers, particularly those acting as tied agents, and holds senior managers personally accountable. It matters for compliance as it exemplifies enforcement trends targeting systemic deficiencies, with potential appeals signaling ongoing scrutiny.
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What Changed
This is an enforcement action, not a regulatory change, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and compliant; failure to verify or document renders systems non-operational.
Scope of services: Asset managers (and tied agents) cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing licensed activ
What You Need To Do
- Immediate gap analysis
- Enhance AML/CFT
- Conflicts framework
- Senior manager attestation
- Marketing/retrocessions
Key Dates
31 December 2025 - AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors.
August 2019 - December 2023 - Period of breaches investigated, covering investment services, processes, conflicts, and AML/CFT failures.
08 January 2026 - Public press release date.
Compliance Impact
Urgency: High - This reflects a pattern of 2025 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc Partners 15 Sep 2025; €400k on Eternam 9 Sep 2025), signaling intensified scrutiny post-AIFMD reviews. Matters due to personal liability for managers, appeal risks amplify
Asset Manager
Sanctions & settlements professional obligations Journalists The AMF Enforcement Committee fines the Association Nationale des Conseillers Financiers-CIF for breaches of its professional obligations
The AMF Enforcement Committee fined the Association Nationale des Conseillers Financiers-CIF (ANACOFI-CIF), a professional association approved for investment advisors (CIFs), €250,000 with a warning, and its former president €20,000 with a warning, for breaching professional obligations in membership vetting, controls, archiving, and conflicts of interest management. This decision, dated September 5, 2023, underscores AMF's scrutiny of professional associations' gatekeeping and oversight roles in ensuring CIF compliance. It matters as it signals heightened enforcement against associations failing to uphold regulatory standards, potentially impacting CIF ecosystem integrity and prompting reviews of similar bodies.
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What Changed
This is an enforcement action, not a new regulation, but it reinforces existing obligations under French Monetary and Financial Code (CMF) for approved professional associations like ANACOFI-CIF. Key breaches highlighted include:
Failure to verify quality of CIF membership application dossiers and non-compliance with internal adhesion procedures.
Non-respect of procedures for member controls, sanctions, and proper archiving of control dossiers.
Violation of internal rules on conflicts of interes
What You Need To Do
- Review and strengthen internal procedures for CIF membership vetting, ensuring dossier quality checks align with approved protocols
- Implement robust systems for member controls, sanctions processes, and secure archiving of all dossiers per CMF L
- Update conflicts of interest policies and registers to fully comply with internal rules and CMF obligations, documenting all identifications
- Conduct gap analyses on governance, documentation, and AML/KYC for CIF activities, training staff on operationalizing procedures
- For CIF members
Key Dates
September 5, 2023 - AMF Sanctions Commission decision issued, imposing fines and warnings on ANACOFI-CIF (€250,000) and M. Patrick Galtier (€20,000).
Post-September 5, 2023 - Decision subject to potential recourse (appeal period not specified in public summaries, typically 1 month under AMF procedures).
June 2, 2023 - AMF Sanctions Commission hearing where €500,000 sanction was initially sought (reduced in final decision).
Compliance Impact
Urgency: Medium - This 2023 decision is not imminent but remains highly relevant given ongoing AMF focus on CIF compliance (e.g., 2025 sanctions for similar breaches like archiving and AML failures). It matters for preventing fines, bans, or reputational damage, as AMF targets systemic weaknesses in
Wealth ManagerAll Firms
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations
The AMF Enforcement Committee fined asset management company Altaroc Partners (formerly Amboise Partners SA) €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) on 15 September 2025 for multiple breaches of professional obligations, including lack of operational procedures for fund investments/divestments, inadequate AML/CFT due diligence, unproven benefits of fee retrocessions to distributors, and shortcomings in marketing materials. This decision underscores the AMF's strict enforcement on operational controls, governance, and client protection in asset management, serving as a critical warning for firms to ensure robust, documented procedures and senior manager accountability. It matters because it highlights personal liability for executives and reinforces AMF's educational role through sanction explanations, potentially increasing scrutiny on similar firms.
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What Changed
This is an enforcement action, not a regulatory change; it reaffirms and clarifies existing obligations under French financial regulations for asset managers (sociétés de gestion de portefeuille). Key requirements emphasized include:
Implementing operational procedures for investment/divestment processes, including verification of lender authorizations.
Conducting systematic AML/CFT due diligence on fund assets and liabilities.
Proving that fee retrocessions to distributors enhance client servic
What You Need To Do
- Review and document operational procedures for fund investments/divestments, including lender authorization checks
- Enhance AML/CFT systems with systematic due diligence on fund assets/liabilities and risk mapping
- Audit fee retrocession arrangements to demonstrate tangible client service improvements (e
- Validate marketing materials for accuracy and completeness
- Conduct senior manager attestations on compliance oversight; implement training on personal liability
Key Dates
15 September 2025 - AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners and managers.
16 September 2025 - French version of press release published.
Post-15 September 2025 - Appeal lodged by Altaroc Partners, Tchenio, and de Giovanni before the Conseil d’État against decision SAN-2025-09 (exact date not specified).
Compliance Impact
Urgency: High - This recent (2025) enforcement demonstrates AMF's willingness to impose multimillion-euro fines (€1.3M total) and hold executives personally accountable for systemic failures in core areas like operations, AML, and client disclosure. It matters for immediate risk as appeals are pendi
Asset Manager
MAR Anti-money Laundering Pump-and-dump practice: market manipulation sanctioned by the Paris Tribunal Correctionnel
The Paris Tribunal Correctionnel sanctioned a pump-and-dump market manipulation scheme, where perpetrators artificially inflated small-cap stock prices via social media hype before selling off, violating France's Market Abuse Regulation (MAR). This enforcement action by the AMF underscores aggressive judicial backing for anti-manipulation efforts, signaling heightened scrutiny on coordinated trading schemes, especially in illiquid assets. Compliance teams must prioritize surveillance enhancements to mitigate similar risks amid rising digital promotion tactics.
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What Changed
This is an enforcement decision rather than new legislation, reinforcing existing prohibitions under Regulation (EU) No 596/2014 (MAR) against market manipulation, including pump-and-dump tactics like false information dissemination and artificial price inflation . No novel regulatory requirements are introduced, but it exemplifies AMF's collaboration with courts for criminal sanctions, potentially increasing deterrence through public naming and fines. Related AMF General Regulation updates effe
What You Need To Do
- Enhance market abuse surveillance systems to detect coordinated trading, unusual volume spikes, and social media-driven hype in small-cap/illiquid assets
- Implement staff training on recognizing pump-and-dump indicators, such as group chats luring investors with upside promises
- Review client communications policies to block manipulative promotions; report suspicions under MAR Article L
- For crypto firms, align with "enhanced" DASP registration and MiCA AML/CFT compliance to preempt manipulation sanctions
- Conduct internal audits of trading patterns and escalate to AMF if risks identified
Key Dates
30 December 2024 - MiCA mandatory licensing for CASPs; pre-registered PSANs enter 18-month transition .
30 June 2026 - End of PSAN transitional period; full MiCA authorization required, with AMF oversight on manipulation risks . DEADLINE
Compliance Impact
Urgency: High - This case demonstrates swift judicial enforcement (Tribunal Correctionnel conviction), amplifying personal liability for individuals in manipulation schemes and pressuring firms to bolster pre-trade/post-trade surveillance. It matters amid MiCA deadlines, as unlicensed crypto operato
Broker DealerCrypto ExchangeAll Firms
Sanctions & settlements Journalists Investment services providers By two decisions, the AMF Enforcement Committee fines two investment services providers for breaches of their professional obligations
The AMF Enforcement Committee issued two decisions on 19 June 2023 fining Crédit Industriel et Commercial (€1 million) and Banque CIC Sud-Ouest (€250,000) for breaches of professional obligations in investment advisory services, including inadequate suitability assessments, client classification procedures, marketing of unsuitable instruments, and insufficient controls on costs and fees. This matters because it underscores AMF's strict enforcement of MiFID II-derived obligations, signaling heightened scrutiny on operational systems for client protection and potential for substantial fines based on breach duration and scale.
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What Changed
This is an enforcement action rather than new legislation, but it reinforces existing regulatory requirements under French Monetary and Financial Code and MiFID II transposition:
Obligation to implement an effective operational system for assessing investment suitability in advisory services.
Requirement for compliant client classification procedures aligned with regulations.
Duty to market only financial instruments suited to client profiles.
Mandate for effective control systems over investmen
What You Need To Do
- Conduct immediate gap analysis of investment advisory processes against AMF expectations for suitability assessments, client classification, product matching, and control systems
- Enhance traceability and documentation of suitability checks, client categorizations, and cost disclosures to demonstrate operational effectiveness
- Review and strengthen internal procedures for marketing instruments, ensuring alignment with client profiles and regulatory marketing authorizations (cross-reference to similar past cases)
- Implement or audit remedial measures, as considered in fine calculations, including staff training on professional obligations
- Test controls for providing clear cost information to clients, avoiding misleading disclosures
Key Dates
19 June 2023 - AMF Enforcement Committee decisions issued, imposing fines and warnings.
Compliance Impact
Urgency: High – Demonstrates AMF's willingness to impose multimillion-euro fines for systemic operational failures in core client protection areas, with penalties scaled by breach duration, number, and seriousness; firms with advisory services face elevated risk of audits or enforcement if controls
Broker DealerWealth ManagerBank
Sanctions & settlements Asset management Journalists Investment management companies The AMF Enforcement Committee sanctions an asset management company and two of its managers for breaches of their professional obligations
The AMF Enforcement Committee sanctioned asset management company M Capital Partners and its managers Rudy Secco (€70,000 fine) and Stéphanie Minissier (€35,000 fine) with a total firm fine of €200,000 in its decision dated 31 December 2025, for multiple breaches of professional obligations spanning August 2019 to December 2023. This case underscores AMF's strict enforcement on operational compliance, scope of authorized activities, and AML/CFT systems in asset management, serving as a critical reminder for firms to ensure robust, traceable processes and manager accountability. It matters because it highlights personal liability for senior managers and recurring AMF focus on tied agents exceeding permitted services, potentially signaling increased scrutiny in 2026.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces and clarifies existing requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) and AMF rules for asset managers:
Asset management companies (AMCs) acting as tied agents cannot provide placement of financial instruments without a firm commitment basis, as this exceeds the restrictive list of permitted investment services.
Investment allocation processes must be precise, operational, and traceable, w
What You Need To Do
- Review and enhance tied agent activities to ensure no unauthorized investment services like non-firm commitment placements; map against permitted services list
- Audit investment allocation systems for precision, operationality, and traceability; implement verifiable verifications
- Strengthen AML/CFT frameworks
- Update conflicts of interest policies with clear identification, prevention, and management procedures
- Conduct senior manager attestations on personal oversight; perform gap analysis against this and similar cases (e
Key Dates
31 December 2025 - AMF Enforcement Committee decision date; fines imposed on M Capital Partners (€200,000), Rudy Secco (€70,000), and Stéphanie Minissier (€35,000).
August 2019 - December 2023 - Period of breaches investigated.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision directly implicates senior accountability and operational failures in core AMC functions, with fines totaling €305,000 showing AMF's willingness to penalize both firms and individuals. It matters amid a pattern of similar sanctions (e.g., €200k on Eres
Asset Manager
Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000, and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025, for multiple breaches spanning August 2019 to December 2023, including unauthorized placement of financial instruments as a tied agent, non-operational investment allocation processes, inadequate compliance with investment procedures, deficient conflicts of interest management, and non-operational AML/CFT systems. This decision underscores AMF's strict enforcement of operational compliance and scope limitations for asset managers, serving as a critical reminder for firms to ensure robust, traceable systems and director accountability. It matters because it highlights personal liability for managers and recurring AMF focus on AML/CFT and procedural deficiencies, potentially signaling increased scrutiny in 2026.
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What Changed
This is an enforcement action, not a regulatory change introducing new rules. It reinforces existing obligations under French financial regulations (e.g., Monetary and Financial Code) for asset management companies (AMCs), particularly:
Strict limits on services: AMCs cannot provide placement of financial instruments without a firm commitment basis, even as tied agents; doing so circumvents authorized investment services.
Operational investment systems: Processes for allocating investments betwe
What You Need To Do
- Audit dual roles
- Enhance investment processes
- Strengthen controls
- Director oversight
- Documentation
Key Dates
31 December 2025 - AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier.
August 2019 - December 2023 - Period of breaches investigated.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision aligns with a pattern of AMF fines on AMCs for AML/CFT, procedural, and operational failures (e.g., €200k on Eres Gestion in 2023 for rebates/investments; warnings/fines on Inter Gestion REIM in 2024 for AML). It matters due to director liability, esca
Asset Manager
Sanctions & settlements Asset management Compliance Anti-money Laundering Executive & other private individuals Investment management companies The AMF Enforcement Committee fines a portfolio asset management company and its manager for breaches of their...
The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000 and its managers Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for multiple breaches of professional obligations from August 2019 to December 2023, including unauthorized investment services as a tied agent, non-operational investment allocation processes, deficient conflict-of-interest management, and inadequate AML/CFT systems. This decision underscores AMF's strict enforcement against operational failures in asset management, particularly for firms balancing portfolio management with tied agent roles, emphasizing personal accountability for managers. Compliance teams must review this for gaps in procedures, as it highlights how imprecise processes and poor traceability lead to substantial sanctions.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) for asset managers:
Asset management companies (sociétés de gestion) are restricted to specific investment services; providing placement of financial instruments without firm commitment (as a tied agent) circumvents these limits and is prohibited.
Investment systems must be operational with precise allocation rules between funds;
What You Need To Do
- Audit investment services scope to ensure no unauthorized placement activities, especially if acting as tied agents; cease and remediate any circumventions
- Enhance investment allocation processes with precise rules, full traceability of verifications, and demonstrable operationality
- Strengthen conflict-of-interest frameworks with identification, prevention, and management protocols, including documentation
- Overhaul AML/CFT systems for effective due diligence on clients, assets, and risks; conduct staff training and test operationality
- Review manager accountability
Key Dates
31 December 2025 - AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier.
August 2019 - December 2023 - Period of breaches investigated, covering unauthorized services, investment process failures, conflicts, and AML/CFT deficiencies.
31 December 2025 (exact deadline unspecified; standard AMF appeals must be lodged promptly, typically within 1 month). DEADLINE
Asset Manager
Sanctions & settlements Journalists The AMF Enforcement Committee fines the head of consolidation of a listed company for insider dealing
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.
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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. Recent EU Regulation 2024
What You Need To Do
- Enhance insider lists and training
- Implement/enforce black-out periods
- Strengthen policies on gifts/invitations and whistleblowing: Formalize in codes of ethics; monitor for corruption risks in information sharing
- Monitor and report transactions
- Conduct risk assessments
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 - PDMRs must report transactions to issuer and AMF.
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 strengthe
All Firms
Sanctions & settlements professional obligations Investment advice Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor for breaches of its professional obligations
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.
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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 fac
What You Need To Do
- Review payment structures
- Enhance disclosure policies
- Conduct gap analysis
- Training and monitoring
- Prepare for inspections
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.
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 oper
Wealth ManagerAll Firms
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
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.
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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 breac
What You Need To Do
- Review and strengthen insider list management
- Enhance market abuse surveillance
- Conduct insider trading risk assessments
- Update compliance training and policies
Key Dates
30 January 2023 - AMF Enforcement Committee decision date, imposing fines for insider dealing and insider list failures.
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 e
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Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines the British company H2O AM LLP and two of its executives at the time of the facts for several breaches of their professional obligations
The AMF Enforcement Committee fined UK asset manager H2O AM LLP €75 million and its executives Bruno Crastes (€15 million, plus a 5-year ban) and Vincent Chailley (€3 million) for breaches in managing French UCITS funds, including ineligible Tennor Group investments, liquidity risks, valuation failures, and non-compliance with investment ratios and counterparty limits. This matters as it underscores AMF's strict enforcement on UCITS eligibility, risk management, and prospectus adherence, with cross-border implications confirmed by the Conseil d'État's dismissal of appeals on 13 June 2025. It signals heightened scrutiny on illiquid, unrated assets and "buy & sell back" transactions for EU asset managers.
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What Changed
This is an enforcement decision, not new rules, but it reinforces existing UCITS requirements under French Monetary and Financial Code and AMF regulations:
UCITS investments must exclude illiquid, unrated securities outside prospectus scopes; liquidity risks must be properly assessed to ensure redemption capabilities.
Debt holdings per issuer capped at 10%; counterparty exposure (e.g., 5% limit) must include all relevant transactions like buy & sell backs.
Reliable valuation information required
What You Need To Do
- Review portfolios
- Enhance due diligence
- Strengthen governance
- Depositary checks
- Training/remediation
Key Dates
30 December 2022 - AMF Enforcement Committee decision SAN-2023-01 imposing fines and sanctions.
7 August 2023 - Conseil d'État rejects preliminary constitutionality question.
13 June 2025 - Conseil d'État dismisses appeals (n. 471548, 471744), upholding sanctions and ordering €3,000 costs to AMF.
June 2025 .
Compliance Impact
Urgency: High - Finalized enforcement (June 2025) with massive fines (€93M total) and bans demonstrates AMF's willingness to pursue personal/executive liability for UCITS breaches, especially cross-border. Matters for firms with illiquid strategies, as it amplifies post-2020 liquidity crisis lessons
Asset ManagerAll Firms
Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
The AMF Enforcement Committee imposed a €150,000 fine on **Inocap Gestion**, a portfolio asset management company, for multiple operational and compliance failures between 2022 and the enforcement decision date. This case demonstrates the AMF's enforcement priorities around liquidity risk management, market abuse detection systems, and anti-money laundering (AML/CFT) procedures—critical control areas that asset managers must operationalize effectively to avoid substantial penalties.
What Changed
The decision does not introduce new regulatory requirements but rather clarifies enforcement expectations for existing obligations:
Liquidity Risk Management: Asset managers must establish procedures that are both adequate in design and operational in practice, not merely documented
Market Abuse Detection Systems: Surveillance systems must specify conditions for participation in market surveys and establish clear consequences for non-compliance
AML/CFT Procedures: Risk mapping and client onboar
What You Need To Do
- assessments across these areas
- *Liquidity Risk Management
- *Market Abuse Detection
- *AML/CFT Compliance
- *Compliance Monitoring
Key Dates
21 December 2022 - Enforcement Committee decision date against Inocap Gestion
No specific implementation deadline stated - The decision addresses historical breaches; however, firms should immediately remediate similar deficiencies
Compliance Impact
Urgency: HIGH
Asset ManagerWealth Manager
Sanctions & settlements Investment advice Other professionals Journalists Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee sanctioned financial investment advisor DCT (formerly Didier Maurin Finance) and its manager Didier Maurin with a five-year ban from practicing and fines of €150,000 and €200,000 respectively for recommending unauthorized Samoan AIF shares to 64 clients and failing to identify/manage conflicts of interest, including lacking a conflicts register. This decision, upheld by the Conseil d'Etat on 9 September 2024, underscores AMF's strict enforcement of client-best-interest and conflicts obligations under French regulations. It matters as it provides binding guidance on due diligence for product marketing authorization and conflicts procedures, signaling heightened scrutiny on financial investment advisors (FIAs).
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What Changed
This is an enforcement action, not a regulatory change, but it clarifies and reinforces existing obligations for FIAs under AMF rules:
FIAs must verify marketing authorization of recommended products in France before advising clients; recommending unauthorized AIFs breaches competence, care, diligence, and client-best-interest duties.
FIAs require effective, operational procedures for identifying and managing conflicts of interest, including maintaining a conflicts register; failure to do so is
What You Need To Do
- Immediate review
- Conflicts enhancement
- Policy updates
- Documentation
- assess against AMF Position-Recommendation DOC-2021-05 on FIA obligations (https://www
Key Dates
11 April 2022 - AMF Enforcement Committee issues decision SAN-2022-04, imposing bans and fines.
9 September 2024 - Conseil d'Etat judgment (no. 464877) dismisses appeal, upholds sanctions, and orders €1,500 costs each to AMF.
Compliance Impact
Urgency: Medium - Not critical as no new rules or deadlines, but medium due to upheld precedent reinforcing FIA duties amid AMF's pattern of FIA sanctions (e.g., bans/fines in 2022-2025 cases). Matters for FIAs lacking controls, as breaches lead to personal liability, business bans, and fines scalin
Wealth ManagerAll Firms
Markets Periodic & ongoing disclosures The AMF has requested the suspension of ORPEA's financial instruments
On October 24, 2022, France's Autorité des marchés financiers (AMF) suspended all financial instruments (shares, debt securities, and related instruments) issued by ORPEA S.A., a major European care homes operator, pending disclosure of material information under the European Market Abuse Regulation. This enforcement action reflects serious governance and disclosure failures at a publicly listed company facing allegations of operational malpractice and undisclosed financial difficulties.
What Changed
The AMF's suspension order represents a temporary halt to all trading in ORPEA's financial instruments across regulated markets. This is a precautionary measure under Market Abuse Regulation (MAR) protocols designed to protect market integrity when material non-public information exists. The suspension was lifted on October 26, 2022, upon market opening, following ORPEA's disclosure of an amicable conciliation procedure and anticipated asset impairments.
The underlying trigger was ORPEA's failu
What You Need To Do
- *For ORPEA (and comparable listed companies)
- *Immediate disclosure obligations
- *Ongoing periodic updates
- *Governance remediation
- *Creditor communication
Key Dates
October 24, 2022 - AMF requests suspension of ORPEA's financial instruments before market opening
October 26, 2022 - Trading resumes upon market opening following ORPEA's disclosure of conciliation procedure and financial restructuring plan
November 8, 2022 - Q3 2022 revenue announcement (after market close)
November 15, 2022 - ORPEA to present detailed transformation plan to market
December 31, 2022 - Anticipated asset impairment recognition date
Compliance Impact
Urgency: CRITICAL
All Firms
Investment services Savings protection Europe & international Retail investors Investment services providers The AMF informs the public of the partial suspension by the CySEC of VPR Safe Financial Group Limited’s authorisation to operate in France
The AMF publication notifies the public of CySEC's August 3, 2022, decision to partially suspend VPR Safe Financial Group Limited's (operating as Alvexo) authorization to provide investment services in France, prompted by AMF findings of regulatory violations including misleading marketing, inadequate client suitability assessments, and poor tied agent oversight. This cross-border enforcement highlights escalating EU supervisory cooperation under MiFID II, serving as a warning for firms using tied agents in France. It matters for compliance as it underscores risks of AMF referrals leading to home-state suspensions, with subsequent developments including suspension revocation and full license withdrawal by September 2025.
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What Changed
This is an enforcement action rather than new rules, imposing specific prohibitions on VPR Safe Financial Group Limited in France:
Ban on accepting new French clients or entering business relationships with them.
Prohibition on advertising or marketing investment services to current or potential French clients, directly or via tied agent France Safe Media.
Restriction on receiving new deposits from existing French clients, except to cover initial margins for open positions upon explicit client r
What You Need To Do
- For VPR/Alvexo (during suspension)
- Ongoing for similar firms
- Client protection
Key Dates
August 3, 2022 - CySEC issues partial suspension decision based on AMF findings, effective immediately for French operations.
~October 4, 2022 - Two-month deadline for VPR to remediate compliance issues (from suspension date). DEADLINE
Post-August 22, 2022 (exact date unspecified) - CySEC revokes partial suspension after demonstrated compliance. DEADLINE
September 29, 2025 - CySEC fully withdraws VPR's CIF authorization pursuant to the firm's renunciation.
October 13, 2025 - CySEC publicly announces license withdrawal.
Compliance Impact
Urgency: Low (as of January 2026). The 2022 suspension is historical, resolved via revocation and superseded by full license withdrawal in 2025, posing no ongoing restrictions. It matters as a precedent for AMF-CySEC coordination on retail misconduct (e.g., CFD marketing, tied agents), urging firms
Broker DealerFintech
Sanctions & settlements Compliance Journalists Investment services providers The AMF Enforcement Committee fines a depositary for breaches of its professional obligations
The AMF Enforcement Committee fined RBC Investor Services Bank France SA (RBC ISBF) €500,000 plus a warning on 20 July 2022 (published 08 January 2026) for breaches as a UCITS and AIF depositary, including 25 confirmed failures in tiered intervention procedures for investment ratio overruns and deficient monitoring of 14 questionable cash flows over 45 months. This decision underscores AMF's strict enforcement of depositary duties under French regulations implementing UCITS/AIFMD, emphasizing robust controls for ratio compliance, cash flow verification, and documentation. It matters for compliance teams as it provides precedent on what constitutes "irregular and deficient" oversight, potentially increasing scrutiny and fines for similar lapses in depositary functions.
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What Changed
This is an enforcement decision, not a new regulation, but it clarifies and reinforces existing depositary obligations under French UCITS/AIFMD rules (e.g., Articles L. 214-7 et seq. Monetary and Financial Code):
Ratio monitoring and intervention: Depositaries must implement tiered procedures for investment/asset composition ratio breaches (e.g., diversification limits); 25 of 28 alleged anomalies were upheld due to redundant but confirmed procedural failures.
Cash flow oversight: Must identify
What You Need To Do
- Review depositary controls
- Enhance cash flow monitoring
- Conduct gap analysis
- Update policies/procedures
- Appeal if applicable
Key Dates
20 July 2022 - AMF Enforcement Committee decision date imposing €500,000 fine and warning on RBC ISBF.
08 January 2026 - Public news release/publication date of the decision.
Compliance Impact
Urgency: Medium – Recent publication (08 January 2026) signals ongoing AMF focus on depositary failings amid H2O-related probes, but stems from 2022 events with no immediate deadlines. Matters because it sets precedents for fine quantum (€500k) on procedural lapses, reinforces liability for cash/rat
Asset ManagerBankWealth Manager
Sanctions & settlements Journalists The AMF Enforcement Committee fines one natural person and five legal entities, including a management company, for failing to comply with several reporting obligations in relation to a concerted action carried out in the context of a takeover bid and, in the case of the...
The AMF Enforcement Committee imposed fines on one natural person and five legal entities, including an investment management company, for failing to comply with multiple reporting obligations related to a concerted action during a partial takeover bid.[User Query]. This enforcement action underscores the AMF's strict enforcement of transparency rules in takeover scenarios, serving as a critical reminder for market participants to adhere to disclosure timelines to avoid significant financial penalties and reputational damage.
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What Changed
This is not a regulatory change or new requirement but an enforcement decision highlighting existing obligations under French financial markets law, particularly those governing concerted actions (actions concertées) and reporting in takeover bids. Key requirements reinforced include:
Timely disclosure of positions and intentions when parties act in concert, as per AMF regulations on major holdings and takeover bids (e.g., Article L. 233-10 of the French Commercial Code and AMF General Regulatio
What You Need To Do
- Review and enhance internal procedures for monitoring share positions, identifying concerted actions, and automating AMF filings
- Train front-office and compliance teams on takeover bid disclosures, including documentation of coordination (e
- Implement pre-trade alerts for threshold breaches and conduct periodic audits of historical filings
- For management companies
Key Dates
Within 4 trading days - Declaration of crossing major holding thresholds or intent to continue acquisitions (AMF Form DOC-2005-01).
Immediate (same day) - Notification of concerted action agreements in takeover contexts.
Within 10 trading days - Detailed position reports post-crossing.
in 2025 (e.g., 16 July 2025 for inside information breaches).
Compliance Impact
Urgency: High - This matters due to the AMF Enforcement Committee's pattern of fining reporting failures (e.g., €1.89M in July 2025 for late disclosures, €1.7M in June 2025 for shareholder breaches), signaling intensified scrutiny on M&A transparency amid volatile markets. Non-compliance risks fines
Asset ManagerAll Firms
Sanctions & settlements Journalists The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
The AMF Enforcement Committee fined an unnamed portfolio asset management company €400,000 for multiple breaches of professional obligations, including non-operational investment/divestment procedures, inadequate conflict of interest management with group service providers, lack of transparency on distributor fee retrocessions, deficient client categorization, and weak AML/CFT due diligence. This enforcement action, mirroring recent similar cases against firms like Novaxia Investissement and Eternam, underscores the AMF's heightened scrutiny on operational robustness and transparency in asset management, serving as a critical reminder for firms to ensure procedures are fully implemented and documented to avoid personal liability for executives.
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What Changed
This is an enforcement decision rather than new legislation, but it reinforces and clarifies existing regulatory requirements under AMF professional obligations for portfolio asset managers (sociétés de gestion de portefeuille). Key emphases include:
Investment/divestment processes must be fully operational, with traceability of compliance checks against fund policies and formalized due diligence before allocations.
Effective conflicts of interest policies are mandatory when using group service
What You Need To Do
- Audit internal procedures
- Enhance conflict and transparency controls
- Strengthen AML/CFT and client categorization
- Senior manager accountability
- Mock AMF inspections
Key Dates
9 September 2025 - AMF Enforcement Committee decision fining Eternam €400,000 (similar case on marketing, club deals, conflicts, valuation, AML/CFT).
10 December 2025 - AMF Enforcement Committee decision fining Novaxia Investissement €400,000 and director €100,000 (investment processes, group providers, distributor fees, client categorization, AML/CFT).
31 December 2025 - AMF Enforcement Committee decision fining M Capital Partners €200,000 and directors €70,000/€35,000 (investment systems, conflicts, AML/CFT).
Compliance Impact
Urgency: High - Recent cluster of identical fines (€200k-€500k total per case) in late 2025 signals AMF's enforcement priority on operational deficiencies in asset management, with personal sanctions escalating risks for leadership. Firms with similar setups (group providers, AIFs/club deals) face i
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Institutional AMF activity Appointment Journalists Appointments to the Legal Affairs Directorate and Enforcement Assistance Directorate of the Autorité des Marchés Financiers
This AMF publication announces internal appointments to its **Legal Affairs Directorate** and **Enforcement Assistance Directorate**, signaling potential enhancements in legal oversight and enforcement capabilities within France's financial markets regulator. Compliance professionals should note this as it may indicate a renewed focus on rigorous enforcement of market rules, though it imposes no direct regulatory changes on firms.
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What Changed
There are no regulatory changes, new requirements, or policy updates in this announcement. It solely details personnel appointments within AMF's internal structure, specifically leadership roles in directorates handling legal affairs (e.g., Maxence Delorme as head of Legal Affairs Directorate) and enforcement assistance (e.g., Amélie du Passage as head of Instruction and Enforcement Assistance Directorate). These directorates support AMF's core functions like investigations, inspections, and san
What You Need To Do
- *No specific actions are required for regulated firms, as this does not introduce obligations
- Review ongoing AMF interactions (e
- Update internal AMF contact lists with confirmed governance details from https://www
- Track AMF news releases for enforcement trends at https://www
Key Dates
13 February 2024 - Ministerial order partially renewing AMF Enforcement Committee.
20 February 2024 - Publication of Enforcement Committee appointments.
27 February 2024 - Composition published in Official Journal.
16 October 2023 - Appointment of Sébastien Raspiller as AMF Secretary General.
Compliance Impact
Urgency: Low. This matters peripherally for firms anticipating AMF enforcement, as new leaders in Legal Affairs and Enforcement Assistance could signal stricter scrutiny or faster processing of cases, similar to past leadership transitions (e.g., Secretary General appointment in 2023). However, abse
Asset ManagerBroker DealerBank Sanctions & settlements Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee fined financial investment advisor Séquence 13 and its director Jean-Louis Lehmann €15,000 each and imposed a five-year ban from acting as financial investment advisors in its decision of 19 December 2023, due to failures in client disclosures, justifying remuneration, operating within regulatory limits, and managing conflicts of interest. This enforcement action underscores the AMF's strict enforcement of professional obligations for investment advisors, with personal liability for managers, serving as a deterrent against conduct breaches that harm client interests. Compliance teams should note this as part of a pattern of similar sanctions, emphasizing robust governance and documentation.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces core professional obligations under AMF rules for financial investment advisors (Conseillers en Investissements Financiers, CIFs), including:
Client information on remuneration: Advisors must disclose any remuneration received for advice and justify service improvements relative to that pay.
Regulatory scope compliance: Firms must operate strictly within authorized activities, avoiding unauthorized product recommendations.
What You Need To Do
- Review and enhance policies
- Training programs
- Client file audits
- Governance checks
- Mock inspections
Key Dates
19 December 2023 - AMF Enforcement Committee decision issued, imposing fines and five-year bans on Séquence 13 and Jean-Louis Lehmann.
Compliance Impact
Urgency: High - This decision highlights escalating AMF scrutiny on CIFs, with fines, bans, and personal accountability in multiple recent cases (2022-2025), signaling increased inspection risk and potential for director bans. It matters because failures in basic conduct rules lead to severe, long-t
Wealth ManagerAll Firms
Sanctions & settlements Journalists The AMF Enforcement Committee fines a Dutch trading firm and three Dutch traders for price manipulation
The AMF Enforcement Committee fined a Dutch trading firm and three Dutch traders for price manipulation on French markets, demonstrating the regulator's cross-border enforcement reach against market abuse. This case underscores AMF's aggressive stance on manipulative trading practices, serving as a deterrent for international firms and individuals active in EU-linked markets. Compliance teams should note it as evidence of heightened scrutiny on trading desks handling correlated instruments.
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What Changed
This is an enforcement action, not a regulatory change; it reinforces existing prohibitions under the Market Abuse Regulation (MAR, Regulation (EU) No 596/2014) against price manipulation, including fixing prices at abnormal or artificial levels through deceptive trades. It aligns with prior AMF decisions, such as the €20 million fine on Morgan Stanley for similar OAT/OLO manipulations via futures positioning (decision dated 4 December 2019). No new requirements are introduced, but it highlights
What You Need To Do
- Enhance surveillance
- Trader training
- Internal controls
- Compliance reviews
Key Dates
4 December 2019 ; EcoR1: 13 December 2024; SMCP: 10 June 2025).
30 June 2026 .
16 September 2025 .
Compliance Impact
Urgency: High – This signals AMF's expanding cross-jurisdictional enforcement (Dutch firm/traders), with fines on firms and individuals, amid proposed powers enhancements (e.g., penalty payments, communication on probes). Firms face personal accountability risks and market reputation damage; non-EU
Broker Dealer
Sanctions & settlements Investment advice Other professionals Executive & other private individuals Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee fined a financial investment advisor (FIA) firm and its manager for multiple breaches of professional obligations, including failure to provide mandatory documents, inadequate risk disclosure, poor KYC practices, misleading information, unauthorized placing activities, and improper third-party marketing mandates. This enforcement action underscores the AMF's strict scrutiny of FIAs, emphasizing due care, conflict management, and adherence to status limits, with fines and bans serving as deterrents. Compliance teams should review it for lessons on documentation, client suitability, and outsourcing controls to avoid similar sanctions.
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What Changed
This is an enforcement decision, not a regulatory change, but it reinforces and clarifies existing FIA obligations under French regulations (e.g., AMF General Regulation). Key requirements highlighted include:
Mandatory delivery of initial contact documents, engagement letters, and written reports to clients.
Clear specification of remuneration terms and comprehensive risk information for recommended products.
Thorough KYC to ensure suitability of advice.
Prohibition on misleading information, s
What You Need To Do
- Conduct Documentation Audit
- Enhance KYC and Suitability Processes
- Strengthen Conflicts Framework
- Review Activity Scope
- Training and Monitoring
Key Dates
24 January 2019 AMF Enforcement Committee decision fining Novactifs Patrimoine €250,000 and CEO €100,000 for breaches from March 2014–July 2016.
11 April 2022 AMF Enforcement Committee decision imposing 5-year bans and fines (€150,000 firm, €200,000 manager) on DCT/Didier Maurin Finance; appeal dismissed by Conseil d'Etat on 9 September 2024.
4 November 2024 AMF fines totaling €5,670,000 on FIA Smart Tréso Conseil, asset managers, and CACEIS Bank for fund marketing/management breaches.
5 November 2025 AMF Enforcement Committee decision fining Carat GP and directors €2.5 million total, with permanent/10-year bans (French release: 6 November 2025).
Compliance Impact
Urgency: Medium. This matters as part of a pattern of escalating AMF enforcement against FIAs (fines up to €2.5M, lifetime bans in recent cases), signaling heightened focus on investor protection and governance amid complex products. Firms should prioritize audits now to preempt inspections, but no
Wealth ManagerAsset ManagerAll Firms
Sanctions & settlements Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
The AMF Enforcement Committee imposed significant sanctions on DCT (formerly Didier Maurin Finance) and its manager Didier Maurin for recommending unauthorized alternative investment funds to clients and obstructing regulatory investigations. This case exemplifies critical compliance failures in product authorization verification and client suitability assessment, with enforcement upheld by France's highest administrative court in September 2024.
What Changed
This enforcement action clarifies several regulatory obligations for financial investment advisors:
Product Authorization Verification: Financial advisors must verify that recommended investment products are authorized for marketing in France before advising clients, regardless of the product's legitimacy in other jurisdictions.
Client Interest Prioritization: Recommending unauthorized products is inherently contrary to client interests and constitutes a breach of the duty to act with competen
What You Need To Do
- *Immediate compliance measures for financial investment advisors:
- *Product Authorization Audit
- *Pre-Recommendation Due Diligence
- *Client Suitability Documentation
- *Regulatory Cooperation Protocol
Key Dates
11 April 2022 - AMF Enforcement Committee issued original decision imposing five-year ban and fines
18 July 2022 - Conseil d'État suspended enforcement of fines pending appeal
9 September 2024 - Conseil d'État dismissed appeal, upholding all sanctions and ordering payment of €1,500 each to AMF
Compliance Impact
Urgency: HIGH
Asset ManagerWealth Manager
Sanctions & settlements Journalists The AMF Enforcement Committee fines a biotech company for failing to disclose inside information as soon as possible, and one of its co-founders and one of its shareholders for unlawful disclosure or use of inside information
The AMF Enforcement Committee sanctioned a biotech company for delaying disclosure of inside information, and fined a co-founder and shareholder for unlawfully disclosing or using it, violating EU Market Abuse Regulation (MAR) obligations under Articles 7, 10, and 17. This case underscores the AMF's strict enforcement of timely public disclosure and insider handling, highlighting risks of personal liability for executives and shareholders in listed biotech firms. Compliance teams must prioritize robust information barrier procedures and insider list management to mitigate similar penalties.
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What Changed
This enforcement action does not introduce new regulations but reinforces existing MAR requirements transposed into AMF General Regulation (e.g., Article 315-1), including:
Immediate public disclosure: Issuers must disclose inside information "as soon as possible" under MAR Article 17, unless three conditions for delay are met (legitimate interest, confidentiality ensured, no public misleading).
Prohibition on unlawful disclosure/use: Persons with inside information cannot disclose it except per
What You Need To Do
- Assess information promptly
- Implement controls
- Maintain insider lists
- Train personnel
- Archive disclosures
Key Dates
As soon as possible - Disclose inside information publicly, or immediately if confidentiality breached during delay.
Immediately after publication - Notify AMF (differepublication@amf-france.org) of any delayed inside information post-publication.
Within 3 trading days - Managers/directors report securities transactions to issuer and AMF.
Within 10 business days - Custodians respond to Euroclear France/AMF requests for shareholder identity disclosures.
Compliance Impact
Urgency: High - This demonstrates AMF's willingness to impose personal and corporate fines for disclosure failures, particularly in volatile sectors like biotech where trial data qualifies as inside information. Firms risk market disruption, reputational damage, and escalating penalties (e.g., hundr
All Firms
Sanctions & settlements Executive & other private individuals Journalists Listed companies and issuers The AMF Enforcement Committee sanctions a media company and its director for making investment recommendations without mentioning conflicts of interest and for price manipulation
The AMF Enforcement Committee sanctioned a media company and its director for issuing investment recommendations without disclosing conflicts of interest and engaging in price manipulation, highlighting the regulator's strict enforcement against market abuse and transparency failures. This case underscores the AMF's focus on protecting investors from misleading practices by non-traditional actors like media outlets, with penalties serving as a deterrent amid rising digital fraud. Compliance teams must prioritize conflict disclosures and surveillance to avoid similar actions, as it reinforces ongoing AMF priorities in conduct and market integrity.
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What Changed
This enforcement decision does not introduce new regulations but reaffirms and clarifies existing requirements under AMF rules and EU Market Abuse Regulation (MAR):
Mandatory conflict of interest disclosure: Investment recommendations must explicitly mention any conflicts, such as financial stakes or relationships influencing the advice, to ensure clear, non-misleading information.
Prohibition on price manipulation: Practices artificially influencing security prices, including through coordinate
What You Need To Do
- Conduct conflict of interest audits
- Enhance surveillance for market abuse
- Update compliance policies
- Training programs
- Inducement reviews
Compliance Impact
Urgency: High - This matters due to the AMF's escalating enforcement (e.g., record 12 sanction decisions in 2024 affecting 60 entities, €26.5M fines), targeting non-authorized actors like media amid digital fraud surges (181 sites shut down in 2024). Media and advisory firms face director-level liab
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Sanctions & settlements Journalists The AMF to call for an amendment of the law on obstructing investigations and inspections
The AMF announced its intention to propose legislative amendments to the French Monetary and Financial Code following a January 28, 2022 Constitutional Council decision that found dual prosecution for obstructing AMF investigations and inspections unconstitutional. The amendment aims to eliminate the possibility of simultaneous administrative and criminal penalties for the same obstruction conduct, while preserving the AMF's enforcement authority.
What Changed
The primary regulatory change addresses a constitutional violation regarding dual prosecution under the ne bis in idem principle:
Current problem: The Monetary and Financial Code previously allowed both administrative sanctions by the AMF Enforcement Committee and criminal prosecution for identical obstruction conduct, violating the constitutional prohibition against double jeopardy.
Proposed solution: Legislative amendments will eliminate the possibility of dual prosecution while maintaining
What You Need To Do
- *For compliance professionals and regulated entities:
- *Review cooperation policies
- *Assess ongoing proceedings
- *Monitor legislative developments
- *Counsel on cooperation
Key Dates
January 28, 2022 - Constitutional Council decision declaring dual prosecution unconstitutional
No specific implementation deadline stated - AMF committed to proposing amendments "as soon as possible"
Current status (as of January 2026) - Amendments appear to be in legislative proposal stage; no effective date yet announced
Compliance Impact
Urgency: MEDIUM
Asset ManagerBroker DealerAll Firms
Sanctions & settlements Journalists The AMF Enforcement Committee fines an issuer's Chief Financial Officer for insider dealing
The AMF Enforcement Committee fined an issuer's Chief Financial Officer (CFO) for insider dealing, highlighting the regulator's aggressive enforcement against market abuse by senior executives. This case underscores the personal liability of insiders who trade on privileged information, reinforcing the need for robust internal controls in listed companies. Compliance teams must prioritize insider trading prevention to mitigate similar sanctions risks.
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What Changed
This enforcement action does not introduce new regulatory changes but exemplifies ongoing application of existing Market Abuse Regulation (MAR) rules under EU Regulation 596/2014 and AMF General Regulations, including Articles 223-9 and 221-3 on inside information disclosure and trading bans. It aligns with AMF Position-Recommendation No 2016-08 on managing inside information, emphasizing black-out periods (e.g., 30 days before annual/interim results) and trading restrictions for Persons Dischar
What You Need To Do
- Maintain insider lists and notify affected persons of trading restrictions; train staff on MAR Article 17 (disclosure) and Article 19 (PDMR dealings)
- Strengthen monitoring of gifts, transactions in derivatives/index products, and whistleblowing mechanisms, as urged in AMF/AFA joint guidance
- Ensure PDMR transaction reporting within 3 trading days via AMF portal
- Conduct regular compliance inspections on insider networks and corruption risks, formalizing prohibitions in codes of ethics
Key Dates
3 trading days - PDMRs must report securities transactions to issuer and AMF. DEADLINE
December 4, 2024 - EU Regulation 2024/2809 amending MAR entered into force.
June 5, 2026 - Certain amendments in sample insider policies apply (e.g., Groupe Casino policy).
June 30, 2026 - AMF General Regulation updates effective.
Compliance Impact
Urgency: High - This demonstrates AMF's focus on holding executives accountable, with fines signaling zero tolerance amid rising "insider networks" linked to organized crime, as noted in AMF's 2024 report and 2025 AMF/AFA warnings. Firms face heightened inspection risks, reputational damage, and per
All Firms
Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company for several breaches of its professional obligations
The AMF Enforcement Committee fined asset management company Altaroc Partners €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) on 15 September 2025 for multiple breaches of professional obligations, including lack of operational procedures for fund investments/divestments, inadequate AML/CFT due diligence, unproven benefits of fee retrocessions to distributors, and shortcomings in marketing materials. This decision underscores AMF's focus on operational controls, due diligence, and transparency in asset management, serving as a key enforcement precedent that highlights personal liability for senior managers. Compliance teams must review it to strengthen internal procedures and governance amid rising AMF scrutiny on these issues.
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What Changed
This is an enforcement action, not a regulatory change introducing new rules; it enforces existing obligations under French financial regulations for asset management companies (sociétés de gestion de portefeuille). Key breaches clarified include:
Absence of operational procedures for investment/divestment processes, failing to verify lender authorizations, breaching duties to act honestly, fairly, professionally, with skill, care, and diligence.
Inability to demonstrate that retrocessed managem
What You Need To Do
- Implement and document operational procedures for all investment/divestment processes, including third-party authorization checks (e
- Conduct and document systematic AML/CFT due diligence on fund assets/liabilities, ensuring risk mapping and procedures are operational
- Substantiate retrocessions of fees to distributors with evidence of enhanced client services; otherwise, cease or disclose fully
- Review and enhance fund marketing materials for accuracy, comprehensiveness, and non-misleading content
- Senior managers
Key Dates
15 September 2025 - AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners and managers.
16 September 2025 - French version of press release published.
2025 09 (date not specified in available data).
Compliance Impact
Urgency: High - This recent (2025) decision signals intensified AMF enforcement on core operational failures in asset management, with total fines of €1.3 million and personal accountability, amid a pattern of similar actions (e.g., M Capital Partners €305,000 in Dec 2025, Eternam €400,000 in Sep 20
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