This FINRA Information Notice dated August 14, 2025, reminds registered persons and firms of annual continuing education (CE) requirements under FINRA Rule 1240, including 2025 Regulatory Element completion by December 31, 2025, and resources for Firm Element plans via the FLEX catalog. It matters because non-compliance triggers automatic CE inactive status, halting registered activities, with today's date (January 25, 2026) indicating the deadline has passed, requiring immediate remediation for affected individuals.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
#
What Changed
Effective January 1, 2023, amendments to FINRA Rule 1240 mandate annual completion of both Regulatory Element and Firm Element for all registered persons, per CE Council recommendations.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
Launched July 1, 2024, the Financial Learning Experience (FLEX) serves as an optional centralized catalog for Firm Element e-learning courses to support written training plans.[https://www.finra.org/rules-guidance/notices/information-notic
What You Need To Do
Registered persons
Verify FinPro access/recovery; contact FINRA Testing and Continuing Education Department for questions
Key Dates
January 1, 2023- Effective date of CE rule amendments requiring annual Regulatory and Firm Elements.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
July 1, 2024- Launch of FLEX catalog for Firm Element resources.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
October 1 (annually)- FINRA publishes upcoming Regulatory Element topics by registration category.
December 31, 2025- Deadline to complete 2025 Regulatory Element courses; non-completion results in automatic CE inactive status.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]DEADLINE
Compliance Impact
Urgency: High - The December 31, 2025, deadline has passed (as of January 25, 2026), meaning non-compliant registered persons are already CE inactive and barred from registered functions until remediation, risking operational disruptions, exam retakes, or enforcement. Firms face supervisory liabilit
The FCA's updated Statement of Policy outlines its approach to statutory investigations into possible regulatory failures under Part 5 of the Financial Services Act 2012, including criteria for triggering investigations and producing reports for HM Treasury. It matters because it clarifies when the FCA must self-scrutinize serious lapses in regulation, helping firms anticipate rare but high-profile probes into systemic issues affecting consumer protection, market integrity, or competition. The primary update adjusts inflation-linked monetary thresholds for assessing "significant" consumer detriment, ensuring the policy remains relevant.
#
What Changed
Inflation-adjusted monetary thresholds for consumer detriment: Detriment exceeding ยฃ210 million is more likely deemed "significant," while below ยฃ45 million is unlikely to meet the threshold unless qualitative factors (e.g., consumer vulnerability, widespread impact) apply. These replace 2013 levels and will be reviewed periodically.
No other substantive changes from the 2013 policy; refinements emphasize internal "lessons learned" reviews for non-statutory cases to avoid resource duplication in
What You Need To Do
Monitor for triggering events
Enhance internal reviews
No direct firm obligations
Document qualitative factors (e
Key Dates
14 November 2025- Publication date of updated Statement of Policy.
Compliance Impact
Urgency: Medium. This update signals FCA's commitment to accountability without imposing new firm-level rules, but it heightens focus on significant failures (ยฃ45m+ detriment), potentially leading to public reports exposing industry-wide gaps. Firms with high consumer exposure (e.g., retail-facing)
The FCA's PS25/23 finalizes guidance on tackling **non-financial misconduct (NFM)** in financial services, amending the COCON sourcebook to clarify how serious NFM breaches conduct rules and integrating it into FIT assessments for fitness and propriety. This matters because it aligns rules across banks and non-banks, enhances accountability, deters harmful workplace cultures, and supports FCA objectives like consumer protection and market integrity by ensuring consistent handling of issues like bullying or harassment.
#
What Changed
COCON amendments: Expands scope to non-banks for work-related serious NFM involving financial services personnel; provides flowcharts, examples, and factors (e.g., seriousness, pattern, dishonesty, violence) to assess breaches consistently; clarifies only "serious" NFM qualifies, aligned with Equality Act concepts, and excludes trivial/private matters.
FIT sourcebook updates: Integrates NFM into fit and proper tests for employees/senior personnel; firms assess case-by-case without investigating
What You Need To Do
Review and update policies/handbooks to incorporate COCON/FIT guidance on NFM assessment, including flowcharts and factors for breaches/fitness
Train HR, compliance, and managers on applying rules consistently, emphasizing seriousness thresholds, case-by-case judgement, and alignment with employment law/privacy
Enhance regulatory reference processes to disclose past NFM; ensure reporting of serious breaches to FCA
Assess current NFM handling for gaps (e
Firms not to investigate trivial/improbable allegations or overstep privacy laws
Key Dates
2023Consultation on D&I in financial sector opened
2023Consultation on D&I in financial sector closed
2025Policy Statement and Consultation on non-financial misconduct guidance (CP25/18) published
2025Consultation on non-financial misconduct guidance closed
2025Policy Statement on non-financial misconduct (PS25/23) published
Compliance Impact
Urgency: High โ With rules effective 1 September 2026 (9+ months from today), firms have preparation time, but PS25/23 closes FCA's NFM policy work, shifting to supervision/enforcement focus; non-compliance risks enforcement, FIT failures, and reputational damage amid trust-building priorities in FC
The Securities and Exchange Commission today announced the senior team from the Division of Corporation Finance responsible for advising division Director James Moloney on all matters the division has before the Commission. These include rulemakingโฆ
The Securities and Exchange Commission today announced that Keith E. Cassidy has been appointed Director of the Division of Examinations. Mr. Cassidy has served as Acting Director since May 2024 and previously was the divisionโs Deputy Director, Actingโฆ
CSSF Circular 26/906, published on 20 January 2026, establishes detailed requirements for central administration, internal governance, and risk management for payment institutions (PIs) and electronic money institutions (EMIs) in Luxembourg, repealing prior circulars IML 95/120, IML 96/126, IML 98/143, and CSSF 04/155. It clarifies application of the amended Law of 10 November 2009 on payment services, emphasizing robust governance amid sector growth to ensure safety, efficiency, and trust. This matters for compliance as it mandates comprehensive reviews and updates to governance frameworks by mid-2026, addressing rising transaction volumes.
#
What Changed
The circular consolidates and updates governance rules, focusing on:
Management bodies: Responsibilities, composition, qualifications, organization, and functioning, including CSSF authorization of members based on professional experience, standing (e.g., police records), and irreproachable conduct.
Internal control functions: Responsibilities, characteristics, organization, and execution of work for compliance officers and internal auditors, with notifications to CSSF including detailed persona
What You Need To Do
Gap analysis
Updates and notifications
Implementation
Documentation
Key Dates
20 January 2026- Publication date of Circular CSSF 26/906.
30 June 2026- Compliance deadline: Institutions must assess/review central administration, internal governance, and risk management frameworks to ensure full compliance.DEADLINE
Compliance Impact
Urgency: High - With ~5 months from publication (20 Jan 2026) to compliance (30 Jun 2026), firms face tight timelines for assessments, policy overhauls, and CSSF notifications, especially given repealed circulars and sector growth pressures. Non-compliance risks supervisory actions, as this fosters
Central administration, internal governance and risk management
AI Analysis
Circular CSSF 26/906, published on 20 January 2026, consolidates and clarifies Luxembourg's rules on central administration, internal governance, and risk management specifically for payment institutions, electronic money institutions, and account information service providers. It repeals prior circulars (IML 95/120, IML 96/126, IML 98/143, and CSSF 04/155) to address growth in transaction volumes by mandating robust governance, control functions, and risk processes, enhancing safety, efficiency, and trust in these services. This matters for compliance professionals as it strengthens defenses against financial crime, operational risks, and supervisory scrutiny in a high-growth sector.
#
What Changed
Consolidation and repeal: Replaces outdated circulars with unified requirements under the amended Law of 10 November 2009 on payment services, covering central administration (decision-making must be in Luxembourg), management body responsibilities, internal control functions (compliance, risk management, internal audit as independent second/third lines), conflicts of interest management, new product approval processes, and client funds safeguarding (e.g., segregation, daily/weekly reconciliatio
What You Need To Do
Assess and update governance frameworks
Confirm control functions
Implement operational safeguards
Document proportionality
Retain records and report
Key Dates
20 January 2026 - Publication date of Circular CSSF 26/906.
30 June 2026 - Compliance deadlineInstitutions must assess, review, and ensure their central administration, internal governance, and risk management frameworks fully comply with the circular.DEADLINE
Compliance Impact
Urgency: High โ With a 30 June 2026 deadline (five months from publication), firms face immediate pressure to review and remediate governance gaps amid sector growth and heightened AML/CFT scrutiny; non-compliance risks supervisory actions, fines, or license issues, especially as it closes criminal
Application of the Guidelines of the European Banking Authority on the management of environmental, social and governance (ESG) risks (EBA/GL/2025/01)
AI Analysis
Circular CSSF 26/905 mandates the application of EBA Guidelines (EBA/GL/2025/01) on managing **ESG risks** for Luxembourg-supervised institutions, requiring integration of environmental, social, and governance risk identification, measurement, management, and monitoring into internal processes. This aligns with CRD amendments (Articles 74, 76, 87a) and emphasizes proportionality to institutions' business models, with plans including timelines, targets, and milestones toward EU climate goals like net-zero by 2050. It matters for compliance as it embeds ESG into prudential supervision, potentially impacting capital, risk frameworks, and supervisory reviews.
#
What Changed
Institutions must establish proportionate strategies, policies, processes, and systems for ESG risk management, covering short-, medium-, and long-term horizons, including transition and physical environmental risks.
Develop plans per Article 76(2) CRD with specific timelines, intermediate quantifiable targets, and milestones to address ESG financial risks, consistent with EU objectives (e.g., 55% GHG reduction by 2030, climate neutrality by 2050).
Incorporate ESG into internal governance, risk
What You Need To Do
Map and integrate ESG risks into governance, risk management frameworks, and business strategies, proportionate to scale/risk exposure
Develop and document ESG risk management plans with quantifiable targets, milestones, timelines, and scenario analyses (broad requirements now; detailed later)
Conduct assessments of ESG risks in portfolios, including sustainability products, transition finance, and loan origination policies, for SREP submission
Embed in internal processes per Articles 74, 76, 87a CRD: identify/measure ESG risks (minimum standards), monitor over time horizons, and report to CSSF
Review and update existing policies/systems for compliance by applicable dates; prepare for CSSF supervisory evaluation of plan robustness
Key Dates
20 January 2026- Circular published by CSSF.
1 April 2026- Application date for Less Significant Institutions (other than SNCIs).
11 January 2027- Application date for SNCIs (dependent on CRD transposition).
Compliance Impact
Urgency: High - With application starting 1 April 2026 (just over 2 months from publication), firms face immediate pressure to gap-analyze current ESG frameworks against EBA standards, especially for SREP integration and long-term risk planning. Non-compliance risks supervisory scrutiny, capital add
PS1/26 represents the UK Prudential Regulation Authority's final implementation framework for the Basel 3.1 international banking standards, effective 1 January 2027 (with market risk internal models delayed to 1 January 2028). This policy statement establishes mandatory capital, credit risk, operational risk, and market risk requirements for UK-regulated banks, building societies, and investment firms, addressing post-financial crisis shortcomings in risk-weighted asset (RWA) calculations and capital adequacy frameworks.
What Changed
*Credit Risk Framework**
Implementation of restrictions on Internal Ratings-Based (IRB) approach scope, effective 1 January 2027, with firms required to reclassify certain exposures (e.g., slotting approach IPRE exposures) as High-Volatility Commercial Real Estate (HVCRE) where applicable.
Minor clarifications and amendments to the Standardised Approach and credit risk mitigation techniques.
*Operational Risk**
Updated Business Indicator Component (BIC) calculation methodology requiring inclusi
What You Need To Do
*Immediate (by mid-2026)
*Conduct impact assessment
*Review IRB permissions
*Assess FRTB-IMA readiness
*Arrange board-level assurance
Key Dates
20 January 2026โ PRA publishes PS1/26 (final rules)
1 January 2027โ Effective date for Basel 3.1 implementation (credit risk, operational risk, reporting/disclosure, IRB scope restrictions, SDDT regime)
1 January 2027โ Interim period begins for FRTB-IMA transition; existing IMA permissions retained; out-of-scope positions move to ASA/SSA
1 January 2028โ FRTB-IMA implementation effective date
2026 ICAAP submission deadlineโ Must include Basel 3.1/SDDT impact assessmentDEADLINE
The Prudential Regulation Authority (PRA) has published the final rules for the implementation of Basel 3.1 standards in the UK, with an effective date of January 1, 2027. The rules aim to enhance the resilience of banks and improve the stability of the financial system. Firms must review and update their policies and procedures to ensure compliance with the new requirements.
What Changed
The PRA has introduced new rules for the calculation of risk-weighted assets, including changes to the credit risk standardised approach, market risk framework, and operational risk requirements. The rules also include amendments to the definitions of probability of default, loss given default, and conversion factor.
What You Need To Do
Review and update credit risk policies and procedures to ensure compliance with the new standardised approach
Assess the impact of the new market risk framework on trading book positions and capital requirements
Update operational risk management frameworks to reflect changes to the Business Indicator and subcomponents
Key Dates
1 Jan 2027Basel 3.1 rules take effectDEADLINE
1 Jan 2028Internal model approach for market risk takes effectDEADLINE
Non-Compliance Risk
Non-compliance with the new rules may result in enforcement action, fines, or other regulatory penalties
The FCA's decision to ban Darren Antony Reynolds from working in financial services and fine him ยฃ2,037,892 has been upheld by the Upper Tribunal. The FCA's decision to ban Darren Antony Reynolds from working in financial services and fine him ยฃ2,037,892 has been upheld by the Upper Tribunal.Mr Reynolds was dishonest when he gave pension transfer advice and investment recommendations to his customers, causing them significant harm.Mr Reynolds showed a clear disregard for his customersโ intere...
The Securities and Exchange Commission today announced that J. Russell โRustyโ McGranahan has been named SEC General Counsel. As the SECโs chief legal officer, Mr. McGranahan will oversee the provision of legal expertise and advice to the Office of theโฆ
Introduction Good morning and thank you to Michael for inviting me to speak at the Compliance Instituteโs Annual General Meeting. It is always a real pleasure to engage with compliance professionals. At the Central Bank, we recognise the essential role played by the compliance community in ensuring that financial firms are well-run and contributing to a financial system that is trusted and resilient. We also recognise the important role played by the compliance institute, equipping those work...
AI Analysis
This speech by Gerry Cross, Director of Capital Markets and Funds at the Central Bank of Ireland (CBI), outlines key supervisory priorities including securing customers' interests via the revised Consumer Protection Code, Individual Accountability Framework (IAF) implementation, regulatory simplification, resilience, technology leverage, and an evolving outcomes-focused supervision approach. It matters because it signals CBI's expectations for compliance professionals to drive these outcomes in firms, emphasizing proportionality and ongoing engagement amid regulatory evolution. Compliance teams must integrate these themes to align with CBI's shift toward less process-driven, more effective oversight.
#
What Changed
Revised Consumer Protection Code: Introduces new Standards for Business, building on the Code reviewed with industry input; focuses on delivering good outcomes for consumers and the economy.
Individual Accountability Framework (IAF): Implemented 18 months prior (circa mid-2024); enhances clarity on responsibilities, supports governance, and aligns with outcomes-focused regulation rather than enforcement-heavy approaches.
Supervisory Approach Evolution: Shifting in 2025-2026 to risk-based, outcom
What You Need To Do
Implement Revised Consumer Protection Code
Adopt Outcomes-Focused Practices
Engage with CBI
Leverage Technology
Key Dates
24 March 2026- Revised Consumer Protection Code comes into force; firms must ensure full readiness and ongoing embedding of provisions, including new Standards for Business.DEADLINE
January 2026speech).
Compliance Impact
Urgency: Medium. This speech reinforces imminent obligations like the 24 March 2026 Consumer Protection Code effective date (less than 2 months from speech/publication), requiring immediate readiness checks, but lacks new rules or critical enforcement threats. It matters for long-term alignment with
The Securities and Exchange Commission today announced that Paul H. Tzur and David M. Morrell have been named as Deputy Directors of the Division of Enforcement. Mr. Tzur joined the Commission on January 6, 2026, as the Deputy Director overseeing theโฆ
AI Analysis
The SEC announced on January 12, 2026, the appointment of Paul H. Tzur and David M. Morrell as Deputy Directors of the Division of Enforcement, with Tzur joining on January 6, 2026, to oversee key operations. This personnel change is part of a broader reorganization replacing Regional Directors with Deputy Directors for more centralized oversight of investigations. It matters for compliance teams as it signals greater consistency in enforcement approaches, potentially affecting investigation timelines, Wells process strategies, and settlement negotiations across SEC-regulated entities.
#
What Changed
This announcement reflects structural reforms rather than new substantive regulations:
Replacement of Regional Directors with Deputy Directors, centralizing reporting from local offices (e.g., Boston, Fort Worth, Atlanta) and specialized units directly to headquarters-led Deputy Directors.
Enhanced supervision of enforcement decisions, aiming for consistency and reduced regional variations in handling investigations.
Complements parallel Wells process reforms under Chairman Paul Atkins, includin
What You Need To Do
Review and update internal protocols for SEC investigations to align with centralized reporting structures, anticipating uniform standards across regions
Train legal/compliance staff on refined Wells process (e
Monitor upcoming SEC communications for Enforcement Director Judge Margaret Ryan's guidance on fraud-focused priorities
Assess current or potential matters for earlier engagement with Deputy Directors on case theories and resolutions
Key Dates
January 6, 2026- Paul H. Tzur joins SEC as Deputy Director of the Division of Enforcement.[User Query]
January 12, 2026- SEC announces appointments of Paul Tzur and David Morrell as Deputy Directors.[User Query]
Compliance Impact
Urgency: Medium. This matters due to its role in ongoing SEC transition under Chairman Atkins and Director Ryan, promising more predictable enforcement but requiring adaptation to centralized decision-making and Wells enhancements. While not imposing immediate obligations, it could accelerate case r
Administrative sanction imposed on the alternative investment fund manager Max Gain Capital S.ร r.l. (โAIFMโ)
AI Analysis
The CSSF imposed a โฌ10,000 administrative fine on Max Gain Capital S.ร r.l., an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's active monitoring of AML/CFT compliance obligations and its willingness to sanction non-cooperation, even for procedural failures unrelated to substantive money laundering violations.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All CSSF-supervised professionals must submit an annual questionnaire on financial crime covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT imposes a non-negotiable duty to cooperate with CSSF supervisory requests.
Enforcement Escalation: The CSSF will issue reminders before imposin
What You Need To Do
regulated entities must
*Identify Reporting Obligations
*Calendar Management
*Documentation
*Escalation Protocol
Key Dates
4 April 2025- Deadline for submission of financial crime questionnaire for the year ending 31 December 2024DEADLINE
Before 11 September 2025- CSSF issued two reminders to Max Gain Capital after the missed deadlineDEADLINE
11 September 2025- CSSF imposed the โฌ10,000 administrative fine
9 January 2026- CSSF published the administrative sanction decision
Administrative sanction imposed on JTC (Luxembourg) S.A.
AI Analysis
The CSSF imposed a โฌ102,000 administrative fine on JTC (Luxembourg) S.A. on 23 July 2025 for breaches in its professional obligations as a depositary of non-financial assets under the AIFM Law, identified during an on-site inspection from February 2023 to January 2024 covering activities up to December 2022. This enforcement action highlights CSSF's scrutiny of depositary functions, particularly risk assessment and oversight controls, serving as a warning for similar entities to strengthen compliance amid rising supervisory focus on AIFM depositaries.
#
What Changed
This is an enforcement action, not a regulatory change; it enforces existing requirements under Article 51(1) (1st and 7th indents) and Article 51(2) (1st sub-paragraph, 3rd indent) of the amended Law of 12 July 2013 on AIFMs (AIFM Law), and related provisions like Article 92(1) of Commission Delegated Regulation (EU) No 231/2013 (CDR 231/2013). Key breaches include: failure to properly assess risks tied to AIFs' strategies and AIFMs' organization for oversight processes; lack of processes to ve
What You Need To Do
related entities) must
Conduct immediate gap analyses on risk assessment processes for AIF strategies and AIFM organization per Article 92(1) CDR 231/2013
Implement robust verification processes for AIFM compliance with asset delegation rules
Ensure availability of key documentation and evidence of controls for the depositary function, addressing pre-2022 gaps if applicable
Develop and test oversight processes, leveraging self-identified improvements and action plans as mitigating factors, as JTC did prior to inspection
Key Dates
February 2023 - January 2024Period of CSSF on-site inspection on depositary obligations, covering activities up to December 2022.
23 July 2025Date CSSF imposed the โฌ102,000 administrative fine on JTC (Luxembourg) S.A.
9 January 2026Date of official CSSF publication announcing the sanction.
Compliance Impact
Urgency: High โ This matters due to the fine's size (โฌ102,000), reflecting breach accumulation, severity, and duration, despite JTC's partial remediation; it signals intensified CSSF on-site scrutiny of depositary functions post-2023 inspections, with potential for higher penalties absent proactive
Long Form Report โ Practical rules concerning the self-assessment questionnaire to be submitted by investment firms โ Mission and related reports of the rรฉviseurs dโentreprises agrรฉรฉs (approved statutory auditors)
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
AI Analysis
The AMF Enforcement Committee fined asset management company M Capital Partners โฌ200,000 and its directors Rudy Secco (โฌ70,000) and Stรฉphanie Minissier (โฌ35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including non-operational investment systems, deficient AML/CFT procedures, inadequate conflict of interest management, and poor due diligence traceability. This decision underscores AMF's focus on operational robustness in asset management, with personal liability for senior managers, signaling heightened enforcement risk for similar firms. Compliance teams must prioritize reviewing internal procedures to avoid comparable sanctions, as appeals are possible but do not suspend obligations.
#
What Changed
This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under the French Monetary and Financial Code for asset managers to maintain operational procedures. 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., โฌ1.3M on Altaroc 15 Sep 2025; โฌ400k on Eternam 9 Sep 2025), indicating intensified scrutiny and personal accountability. Firms risk multimillion fines and reputational damage; immedia
Update of Circular CSSF 24/853 on the Long Form Report (as amended by Circular CSSF 25/870) โ Practical rules concerning the self-assessment questionnaire to be submitted by investment firms Mission and related reports of the rรฉviseurs dโentreprises agrรฉรฉs (approved statutory auditors)
AI Analysis
Circular CSSF 26/904 updates Circular CSSF 24/853 (as amended by Circular CSSF 25/870) by introducing a revised Long Form Report (LFR) for investment firms, featuring a digital self-assessment questionnaire (SAQ) and enhanced auditor reports focused on AML/CFT and risk management. This matters because it aligns reporting with CSSF's risk-based supervision under CSSF 4.0, reduces redundancies, applies proportionality based on business models, and mandates digital submission to improve efficiency and data analysis.
#
What Changed
Revised LFR Structure: Comprises four parts in a single digital document: (1) yearly SAQ completed by investment firms; (2) descriptive elements verified by approved statutory auditors (REAs); (3) AML/CFT report with risk assessments, declarations on audits, and data on incomplete fund transfers; (4) REA's independent assessment of ML/FT risks and organizational aspects.
Digital Format: Completion and submission via CSSF's online portal, supporting CSSF 4.0 digital strategy for efficient process
What You Need To Do
Investment Firms
REAs/Auditors
Key Dates
Financial year ending 31 December 2024- Applicability of revised LFR to all investment firms; submissions begin for this period onward on a yearly basis.
No specific submission deadline stated- Yearly production required via CSSF portal; firms should align with existing annual reporting cycles for auditors (typically post-year-end).DEADLINE
Compliance Impact
Urgency: High - Applies immediately to FY ending 31 December 2024 reports, requiring swift updates to reporting processes, digital tools, and AML/CFT documentation amid CSSF's risk-based shift; non-compliance risks supervisory actions, as LFR directly informs CSSF oversight on key prudential/AML are
This page contains information about fines published during 2026. The total amount of fines so far is ยฃ371,700. Firm or individual finedDateAmountReasonRichard Adam07/01/2026ยฃ232,800The Final Notice refers to knowing concern in breaches of Article 15 of the Market Abuse Regulations, Listing Rule 1.3.3R, Listing Principle 1 and Premium Listing Principle 2.Zafar Khan07/01/2026ยฃ138,900The Final Notice refers to knowing concern in breaches of Article 15 of the Market Abuse Regulations, Listing Ru...
The FCA has fined 2 former finance directors for their part in misleading statements being issued by Carillion plc. Richard Adam and Zafar Khan were both aware of serious financial troubles in Carillionโs UK construction business but failed to reflect this in company announcements or alert the Board and audit committee, leading to poor oversight.Mr Adam and Mr Khan have been fined ยฃ232,800 and ยฃ138,900, respectively. The fines were imposed after Mr Adam and Mr Khan withdrew their challenges t...
The Securities and Exchange Commission today announced that Cicely LaMothe, Deputy Director of the Division of Corporation Finance, has retired from the agency.โCicely has gone above and beyond the call of duty over the past twenty-four years to serveโฆ
The Bank's Court of Directors acts as a unitary board, setting the organisation's strategy and budget and taking key decisions on resourcing and appointments. Required to meet a minimum seven times per year, it has five executive members from the Bank and up to nine non-executive members.
Update of Circular CSSF 24/850 on the practical rules concerning the descriptive report and the self-assessment questionnaire to be submitted on an annual basis by support PFS, as well as the engagement of the rรฉviseurs dโentreprises agrรฉรฉs (approved statutory auditors) of support PFS and practical rules concerning the management letter and the separate report to be drawn up on an annual basis.
AI Analysis
Circular CSSF 25/903 updates Circular CSSF 24/850, refining practical rules for support Professional of the Financial Sector (support PFS) in Luxembourg regarding their annual descriptive report, self-assessment questionnaire, and the roles of approved statutory auditors (rรฉviseurs dโentreprises agrรฉรฉs). It specifies requirements for auditors' engagement, management letters, and separate annual reports. This matters for support PFS as it enhances supervisory oversight, ensures consistent reporting quality, and strengthens internal controls, directly impacting compliance and audit processes amid CSSF's focus on robust PFS supervision.
#
What Changed
Updates to Descriptive Report and Self-Assessment Questionnaire: Refines content, format, and submission requirements for support PFS's annual submissions, emphasizing more detailed disclosures on operations, risks, and controls (building on CSSF 24/850).
Auditor Engagement Rules: Introduces specific practical guidelines for approved statutory auditors, including mandatory scope of work, independence confirmations, and standardized procedures for reviewing support PFS reports.
Management Letter
What You Need To Do
*Review and Update Processes
*Engage/Confirm Auditors
*Implement Templates and Testing
*Training and Governance
*Submit on Time
Key Dates
1 January 2026 - Effective DateApplies to annual reporting cycles starting for financial year 2025 onwards.
30 April (annually) - Submission DeadlineSupport PFS must submit descriptive report, self-assessment questionnaire, management letter, and separate auditor report to CSSF by 30 April following the financial year-end (first applicable: 30 April 2026 for FY 2025).DEADLINE
31 December 2025 - Preparation MilestoneAuditors must be engaged and initial scoping completed by year-end 2025 for FY 2025 compliance.DEADLINE
Compliance Impact
Urgency: High. This is high urgency for support PFS due to the impending 30 April 2026 deadline for FY 2025 submissions, with non-compliance risking supervisory fines, license reviews, or reputational damage under CSSF's PFS enforcement regime. It matters as it tightens audit accountability, potenti
Practical rules concerning the descriptive report and the self-assessment questionnaire to be submitted on an annual basis by support PFS.Engagement of the rรฉviseurs dโentreprises agrรฉรฉs (approved statutory auditors) of support PFS and practical rules concerning the management letter and the separate report to be drawn up on an annual basis.
AI Analysis
Circular CSSF 24/850, as amended by Circular CSSF 25/903, establishes practical rules for support Professional of the Financial Sector (support PFS) in Luxembourg to submit annual descriptive reports and self-assessment questionnaires, while also defining the roles of approved statutory auditors (rรฉviseurs dโentreprises agrรฉรฉs) in issuing management letters and separate reports. This guidance standardizes supervisory reporting and audit processes to enhance oversight of support PFS, which provide essential back-office services to authorized PFS. It matters because non-compliance risks supervisory sanctions, reputational damage, and operational disruptions for entities reliant on support PFS structures.
#
What Changed
Standardized Reporting Templates: Introduces detailed formats and content requirements for the annual descriptive report and self-assessment questionnaire, covering governance, risk management, internal controls, and operational metrics specific to support PFS activities (e.g., IT services, administrative support, custody).
Auditor Engagement Rules: Mandates approved statutory auditors to perform specific procedures, issue a management letter highlighting control weaknesses, and prepare a separa
What You Need To Do
Annual Reporting Cycle
February to review submissions, test controls, and issue management letter (flagging deficiencies) plus separate compliance report
Governance Updates
Auditor Coordination
Record-Keeping
Key Dates
31 March annually- Deadline for submission of descriptive report, self-assessment questionnaire, management letter, and separate auditor report to CSSF (first applicable for FY 2024 reporting due 31 March 2025).DEADLINE
1 January 2025- Effective date of original Circular CSSF 24/850.
15 December 2025- Effective date of amendments in Circular CSSF 25/903, applicable to 2025 reporting cycle onwards.
End of February annually- Support PFS must engage auditors and provide necessary data to enable timely report preparation.DEADLINE
Compliance Impact
Urgency: High โ This is a recurring annual obligation with a firm 31 March deadline, where delays trigger automatic CSSF notifications and potential fines (up to โฌ250,000 per Law 1993). It matters for support PFS as it intensifies scrutiny on operational resilience in a post-SFI (2021) landscape, wh
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
AI Analysis
The AMF Enforcement Committee fined CACEIS Bank โฌ3.5 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.
#
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: โฌ3.5M fine and warning imposed on CACEIS Bank.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision directly impacts depositaries with โฌ3.5M precedent for oversight failures, amid AMF's pattern of multi-million fines (e.g., โฌ5.67M total in related 2024 case involving CACEIS). It elevates risks for UCITS/AIF depositaries handling non-standard assets,
The Securities and Exchange Commission today announced that financial economist and academic scholar Dr. Joshua T. White will return to the agency beginning the week of Jan. 5, 2026, to serve as its Chief Economist and Director of the Division ofโฆ
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its former director a total of โฌ500,000
AI Analysis
The AMF Enforcement Committee fined asset management company Novaxia Investissement โฌ400,000 and its former director Joachim Azan โฌ100,000 on 10 December 2025 for breaches of professional obligations, primarily due to an incomplete and non-operational investment/divestment procedure lacking traceability of compliance checks and formalized due diligence. This enforcement action underscores AMF's focus on robust operational procedures in asset management, serving as a deterrent and educational tool for ensuring honest, fair, and diligent business conduct. Compliance teams should prioritize procedure operationalization to avoid similar sanctions, as this fits a pattern of recent AMF fines targeting procedural deficiencies.
#
What Changed
This is an enforcement decision, not a new regulation, but it reinforces existing requirements under AMF professional obligations for asset managers (sociรฉtรฉs 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 dโรtat).DEADLINE
Compliance Impact
Urgency: High โ This decision, part of a 2025 enforcement wave fining asset managers โฌ400kโโฌ1.3m 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
Authorisation and organisation of entities acting as UCI administrators
AI Analysis
Circular CSSF 22/811, as amended by Circular CSSF 25/900, establishes CSSF requirements for the authorisation, governance, internal organisation, and oversight of entities acting as UCI (Undertakings for Collective Investment) administrators in Luxembourg. It matters because it standardises practices amid regulatory, technological, and market evolutions, ensuring robust controls, risk management, and supervision for fund administration activities critical to Luxembourg's fund industry.
#
What Changed
Authorisation Requirements: Prior CSSF authorisation is mandatory for appointment as UCI administrator, via full application under sectoral laws or a simplified administrative procedure; application must include details per Annex A, with ongoing updates for substantial changes.
Scope of UCI Administration: Defines three core functionsโregistrar, NAV calculation/accounting, and client communicationโrequiring only one designated service provider per function per UCI (or compartment); UCI/IFM may p
What You Need To Do
Submit authorisation application to CSSF with Annex A information before commencing UCI administration; notify substantial changes and keep file updated
Establish/implement governance, controls, escalation processes, resource adequacy, ICT/business continuity per circular; ensure single provider per function
For delegations
Conclude written contracts with UCI/IFM; submit annual UCIA activity reports
Compliance Impact
Urgency: High โ Non-compliance risks CSSF sanctions, as authorisation is prior and ongoing; critical for Luxembourg fund ecosystem given evolutions in tech/markets/DORA. Firms must act promptly if unauthorised or misaligned, especially with annual reporting since 2023 and DORA integration; impacts o
Earlier this year, we undertook a refresh of our Sustainable Finance Advisory Committee. In line with good governance, we planned to refresh the membership on a staggered basis, allowing us to bring in new expertise whilst benefiting from some continuity. Following this process, we are pleased to announce the appointment of two new members to the Committee:Elly Dowding, Director of ESG AccordFarnam Bidgoli, Independent AdviserThese appointments reflect our commitment to drawing on diverse exp...
With over 20 yearsโ experience and responsibility for supervising 5,000 firms, I know that when an issue arises, the first question is often: 'What action will you take?'Thatโs a fair question โ enforcement is one of the most visible ways we act. It often grabs headlines with big fines and publicity.But our role as supervisors is to exercise judgement - selecting the right tool to achieve the best and fastest outcomes for consumers and markets.While enforcement is a vital part of the kit, itโ...
AI Analysis
This FCA blog post outlines the regulator's supervisory "toolkit" for addressing consumer harm, emphasizing proactive supervision over enforcement to achieve faster outcomes like redress and market-wide improvements. It matters because it signals FCA's preference for swift, non-enforcement interventions (e.g., skilled person reviews, voluntary requirements), urging firms to respond promptly to supervisory feedback to avoid escalation. Compliance teams should view this as a reminder to prioritize Consumer Duty compliance, as supervision tools are increasingly tied to it for rapid harm prevention.
#
What Changed
No new rules or requirements are introduced; this is a supervisory strategy update highlighting FCA's full range of tools beyond enforcement. Key emphases include:
Prioritizing supervision for quick fixes, such as multi-firm reviews, good/poor practice guidance, and skilled person reviews (s.166) under FSMA.
Integration of Consumer Duty (Principle 12) as a core principle for assessing and remedying poor outcomes, e.g., unclear policy renewals or inadequate support.
Examples from insurance (e.g.,
What You Need To Do
Embed proactive monitoring
Respond swiftly to FCA contact
Improve practices market-wide
Evidence compliance
Facilitate redress
Key Dates
October 2022Boards to scrutinise and agree implementation plans.
July 2023) - Implement for new/existing products.
July 2024) - Extend to closed-book products.
Compliance Impact
Urgency: Medium โ This reinforces existing obligations under Consumer Duty and Principles, but underscores risk of supervisory escalation if firms ignore early warnings. It matters because FCA prioritizes speed (supervision over enforcement), enabling quick harm fixes but exposing non-responsive fir
Governance Annual report Executive & other private individuals Journalists Listed companies and issuers The AMF examines the transparency of executive succession plans as part of its 2025 Corporate Governance Report
Mr Philip Smith, former Chief Executive Officer (CEO) and Executive Director of RSA Insurance Ireland DAC disqualified for 13 years by the Central Bank of Ireland for his admitted participation in a breach of financial services law by RSAII On 1 December 2025 the Central Bank of Ireland reprimanded Mr Smith and disqualified him for 13 years from being a person concerned in the management of a regulated financial service provider for his participation in a breach by RSA Insurance Ireland DAC (...
AI Analysis
The Central Bank of Ireland (CBI) reprimanded and disqualified former RSA Insurance Ireland DAC (RSAII) CEO Philip Smith for 13 years from management roles in regulated financial service providers due to his admitted role in under-reserving large loss claims, breaching Article 13(1)(a) of the European Communities (Non-Life Insurance) Framework Regulations 1994 (S.I. No. 359/1994). This enforcement action underscores CBI's commitment to individual accountability for senior executives who circumvent controls, risking policyholder protection and firm solvency, as evidenced by RSAII's subsequent need for a major capital injection. It matters for compliance professionals as it demonstrates CBI's use of prolonged disqualifications and inquiries under the Administrative Sanctions Procedure (ASP) to deter governance failures in insurance firms.
#
What Changed
This is not a regulatory change or new requirement but an enforcement precedent reinforcing existing obligations under the 1994 Regulations for insurers to maintain adequate technical reserves reflecting true liabilities. It highlights CBI's focus on senior executive accountability for deliberate policy circumvention, such as undocumented processes overriding claims handlers' estimates, which inflated reported profits and understated liabilities. No new rules were introduced; instead, it applies
What You Need To Do
Review senior management oversight of claims handling; document all approvals and prohibit informal (e
Enhance governance training for executives on personal liability under ASP, including simulations of reserving decisions and policyholder risk scenarios
Assess historical exposures for under-reserving; remediate if needed, and prepare for potential CBI inquiries (noting 10+ year investigation timelines)
Update conduct and culture frameworks to align with CBI expectations for CEOs to drive compliance, as per Deputy Governor Colm Kincaid's comments
Key Dates
2014- CBI enforcement investigation into Mr Smith and RSAII commences.
December 2018- CBI reprimands and fines RSAII โฌ3.5m for related breaches, including reserve failures.
November 2022- CBI decides to hold an Inquiry into Mr Smith's participation under Part IIIC of the Central Bank Act 1942.
1 December 2025- Reprimand and 13-year disqualification imposed on Mr Smith, effective immediately under IAF Act transitional provisions (no High Court confirmation needed).
12 December 2025- CBI publishes public statement on the enforcement action.
Compliance Impact
Urgency: High โ This action signals intensified CBI scrutiny on individual accountability in insurance reserving, with 13-year bans possible for deliberate breaches risking policyholders, even without actual losses. It matters now (post-1 Dec 2025 effective date) as firms face elevated enforcement r
We're providing guidance to support firms to tackle bullying, harassment and violence in financial services, after they asked for additional support. In July, we changed our rules โ setting clearer standards for how financial services firms should address non-financial misconduct.This more closely aligned the rules for banks and non-banks. We wanted to give firms the confidence to act against serious misconduct, drive consistency and make it clearer when non-financial misconduct is a breach o...
The Board of Directors of the Swiss Financial Market Supervisory Authority FINMA has appointed Hedwig Ulmer Busenhart as the new Head of the Insurance division. The qualified mathematician and actuary has over 25 years of management experience in the insurance sector and will take up her position on 1 April 2026. She succeeds Birgit Rutishauser, who left FINMA in April 2025.
The Securities and Exchange Commission today announced that Lori J. Schock, who has served as the Director of the Office of Investor Education and Assistance (OIEA) since 2009, will retire from the agency at the end of December.โI have known Lori forโฆ
The Prudential Regulation Authority (PRA) has issued PS26/25, finalizing the withdrawal of Supervisory Statement (SS) 20/15, which previously set prescriptive expectations for building societies' treasury and lending activities, effective immediately upon publication on 5 December 2025. This deregulatory move reduces administrative burdens, enhances proportionality across deposit takers, and promotes competition by aligning building societies more closely with banks, while relying on existing tools like the PRA Rulebook, SMCR, and routine supervision for risk management. It matters for compliance teams as it eliminates specific guidance often misinterpreted as binding requirements, freeing firms to tailor risk frameworks but requiring vigilance on broader prudential expectations.
#
What Changed
Full deletion of SS20/15: Removes all expectations on treasury and lending activities, including the "Treasury Approaches" framework, without replacement.
Consequential amendments: Updates SS31/15 (Internal Capital Adequacy Assessment Process and Supervisory Review and Evaluation Process) to excise references to SS20/15.
Alignment with broader policy: Addresses inconsistencies with PRA's approach for banks, improved sector risk management maturity, and proportionality for smaller firms; supports
What You Need To Do
Review and update policies
Assess risk management
Update governance documents
Engage supervisors
Monitor related reforms
Compliance Impact
Urgency: Medium โ Effective immediately (5 December 2025), but deregulatory nature reduces burdens rather than imposing new obligations; critical for year-end 2025/early 2026 planning to avoid legacy SS20/15 misapplication. Matters as it shifts from prescriptive "hard limits" (often treated as rules
PS25/25 is the PRA's policy statement providing feedback on CP10/25 and issuing updated Supervisory Statement SS5/25, which replaces SS3/19 to enhance banks' and insurers' management of climate-related financial risks through strengthened governance, risk management, scenario analysis, data quality, and disclosures. It matters because it sets a higher regulatory bar for embedding climate risks proportionately into core processes like ICAAP, ILAAP, ORSA, and financial reporting, promoting resilience and strategic decision-making amid evolving climate threats.
#
What Changed
The main changes in SS5/25 from SS3/19 and CP10/25 responses include:
Proportionate application clarification: New 'Overarching aims' section in Chapter 3 explains how firms should tailor expectations to their climate risk exposure, business size, and complexity via a two-step process (assess materiality, then respond).
Governance strengthening: Boards and senior management must actively oversee climate risks, embedding them in strategy and ensuring accountability.
Risk management enhancements:
What You Need To Do
Conduct gap analysis against SS5/25 within 6 months and remediate (e
Integrate climate risks into board oversight, strategy, risk registers, ICAAP/ILAAP (banks), ORSA/stress testing (insurers), and financial reporting
Perform CSA exercises commensurate with exposures, using suitable scenarios to inform decisions; enhance data quality and disclosures
Ensure senior accountability and alignment with standards like SS1/21
Key Dates
3 December 2025- PS25/25 and SS5/25 published; SS5/25 effective immediately, replacing SS3/19.
Within 6 months (by ~June 2026)- Firms assess gaps against new expectations and develop remediation plans (industry guidance).
Ongoing- Forward-looking, strategic implementation proportionate to risks; PRA may request progress evidence.
Compliance Impact
Urgency: High โ Effective immediately (3 Dec 2025), requiring significant uplift to existing approaches; non-compliance risks supervisory scrutiny, as PRA expects ambitious, ongoing progress and may request evidence. Matters for capital/liquidity planning, resilience, and strategic viability amid ma
SS5/25 is the PRA's updated supervisory statement, published on 3 December 2025, replacing SS3/19 and setting enhanced expectations for banks and insurers to manage climate-related risks through governance, risk management, scenario analysis, data quality, and disclosures. It matters because it represents a step change from awareness-raising to embedding robust, proportionate practices that integrate climate risks into core prudential processes like ICAAP, ILAAP, ORSA, and capital planning, aligning with the PRA's objectives for firm safety and soundness amid evolving physical and transition risks.
#
What Changed
Replaces SS3/19 entirely: Introduces a more mature, consolidated framework reflecting international standards (e.g., BCBS), with detailed transmission channels for climate risks across credit, market, liquidity, insurance, and operational categories.
Governance enhancements: Emphasizes board accountability, integration into business strategy, climate risk appetite statements, and linkage to Senior Managers & Certification Regime (SM&CR) without new Senior Management Functions (SMFs); promotes ch
What You Need To Do
Conduct materiality assessment of climate risks to scope proportionality (leverage TCFD/CSRD work)
Embed climate risks in governance
Integrate into risk frameworks
Perform climate scenario analysis
Enhance data
Key Dates
3 December 2025Publication of PS25/25 and SS5/25; replaces SS3/19 effective immediately.
Within 6 months of 3 December 2025 (by ~3 June 2026)Firms assess gaps against new expectations and develop implementation plans.
April 2025Consultation paper CP10/25 issued (feedback incorporated in final policy).
Compliance Impact
Urgency: High โ Effective immediately with a 6-month window (~June 2026) for gap closure, this demands significant operational uplift (e.g., data, scenarios, integration) amid PRA's shift to enforcement; non-compliance risks supervisory action, given climate risks' materiality to prudential stabilit
The Board of Directors of the Swiss Financial Market Supervisory Authority FINMA has extended Beat Fellmannโs term of office by one year until the end of 2026.
The Securities and Exchange Commission today announced that Cristina Martin Firvida, who has served as the Director of the Office of the Investor Advocate since January 2023, will conclude her tenure with the agency at the end of January 2026. Asโฆ
The PRA held roundtable meetings on artificial intelligence and machine learning (AI and ML) in the context of Supervisory Statement (SS)1/23 โModel risk management principles for banksโ
AI Analysis
The Prudential Regulation Authority (PRA) held roundtable sessions on 20 and 22 October 2025 with 21 regulated firms to discuss AI and machine learning (AI/ML) adoption under Supervisory Statement SS1/23 on model risk management (MRM) principles for banks. This matters because it highlights PRA's strategic supervisory focus on AI/ML model risks, urging firms to enhance governance, risk appetite, monitoring, and validation to mitigate opacity, overfitting, and rapid performance degradation in these models. https://www.bankofengland.co.uk/prudential-regulation/publication/2025/november/pra-holds-model-risk-management-roundtable-on-ai | https://www.bankofengland.co.uk/-/media/boe/files/prudential-regulation/publication/2025/november/ai-roundtable-oct-2025.pdf
#
What Changed
This is not a formal rule change but supervisory guidance via roundtable insights reinforcing SS1/23 principles (effective since 2023). Key emphases include:
Risk appetite: Boards must articulate AI/ML-specific model risk appetite pre-deployment to avoid exceeding tolerances, given higher uncertainty from opacity.
Model inventories and tiering: Address inaccurate/incomplete inventories and aggregate risks from deploying similar AI/ML across portfolios/jurisdictions; challenge tiering for complex
What You Need To Do
Review and strengthen board-level model risk appetite statements to explicitly cover AI/ML opacity and uncertainty; integrate into governance triggers like re-validation
Enhance model inventories for completeness, aggregate risk assessment, and cross-jurisdictional tiering challenges
Update model development policies to evaluate AI/ML trade-offs (e
Revise ongoing monitoring policies for more frequent, quantitative checks on AI/ML (e
Participate in PRA initiatives like MRM roundtables or AI Consortium for dialogue; align first/second-line defenses per SS1/23
Key Dates
20-22 October 2025- PRA held CRO roundtable sessions with 21 firms on AI/ML MRM.
24 November 2025- PRA published roundtable summary and slides. https://www.bankofengland.co.uk/prudential-regulation/publication/2025/november/pra-holds-model-risk-management-roundtable-on-ai
Compliance Impact
Urgency: Medium - Not critical as no new rules or deadlines, but high relevance for AI/ML users amid PRA's strategic MRM focus; non-compliance risks supervisory actions, given observations of gaps in monitoring and governance. Matters for banks scaling AI (rising adoption per industry views), as una
This joint PRA-FCA consultation (CP23/25 from PRA and Chapter 4 of FCA's CP25/33) proposes policy updates to regulatory fees, levies, and invoice processes for 2026/27, including new fee blocks for emerging activities like PISCES operators and targeted support, alongside adjustments to FOS/FSCS levies and payment timelines. It matters for compliance teams as it directly impacts budgeting, fee calculations, and cash flow management for fee-payers, with potential cost increases and procedural changes effective from April 2026.
#
What Changed
New fee structures: Introduction of a periodic fee block for PISCES operators based on regulated income (baseline ยฃ2,200 annual fee, variable above ยฃ500,000 threshold); extension of fee-block A.13 to include "targeted support" activities (Category 2 variation fee for existing firms, Category 4 for new entrants); registration fees for Deferred Payment Credit (DPC/buy-now-pay-later) activities aligned with Temporary Permissions Regime, added to FOS consumer credit fee-block but excluded from FSCS.
What You Need To Do
Review current fee/levy exposure and model impacts of new blocks (e
Assess invoice processes if paying ยฃ50,000+ in FCA/PRA fees; prepare for aligned due dates
Submit consultation responses by deadlines, focusing on targeted support by 9 January 2026
Budget for potential fee increases; monitor Spring 2026 fee-rates CP
For applicants
Key Dates
9 January 2026- Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7).DEADLINE
16 January 2026- Consultation close for all other proposals, including PRA-FCA joint changes; responses to cp25-33@fca.org.uk.
February 2026- FCA publishes feedback and rules on targeted support in Handbook Notice.
March 2026- FCA publishes feedback and rules on all other proposals (including Chapter 4) in Handbook Notice; Spring fee-rates consultation.
April 2026- PRA publishes feedback and rules on Chapter 4; changes effective for 2026/27 fee year (April-March).
Compliance Impact
Urgency: High โ Firms must act imminently on consultation responses (deadlines passed as of today, but feedback analysis pending March/April 2026 rules) to influence outcomes; changes affect 2026/27 budgets starting April, with cash flow risks from invoice timing and new fees for emerging activities
The Federal Council has appointed Katia Villard to the Board of Directors of the Swiss Financial Market Supervisory Authority FINMA. A professor of criminal law, Ms Villard will succeed Ursula Cassani Bossy who is stepping down from FINMA's Board of Directors at the end of the year.
The Securities and Exchange Commission today announced that Antonia M. Apps, Deputy Director of the Division of Enforcement (Northeast), will conclude her tenure with the agency effective Dec. 1, 2025. โI thank Antonia for her steadfast leadership inโฆ
AI Analysis
This SEC press release announces the departure of Antonia M. Apps, Deputy Director of the Division of Enforcement (Northeast), effective December 1, 2025. It signals ongoing leadership transitions within the restructured Enforcement Division under new SEC Chair Paul Atkins, which may influence enforcement priorities, transparency, and regional consistency, requiring firms to adapt compliance strategies amid a "return to basics" approach focused on core investor protection.
#
What Changed
This announcement itself introduces no new regulatory changes or requirements; it is a personnel update. However, it occurs amid broader Enforcement Division restructuring, including:
Consolidation from one Deputy Director to four (three regional: Northeast, Southeast, West; one for specialized units), reducing reporting lines for a more unified nationwide enforcement program.
Rescission in March 2025 of delegated authority for the Enforcement Director to issue formal orders of investigation, no
What You Need To Do
Review ongoing Northeast Regional Office investigations for potential leadership changes and engage early with new deputies on cooperation opportunities
Enhance internal self-reporting and remediation protocols to align with Enforcement's stated rewards for cooperation and robust Wells processes
Update compliance training on restructured reporting lines and Commission-authorized formal orders, ensuring defenses stick to established securities laws rather than novel theories
Monitor SEC staff directory for replacement announcements, such as potential roles for Samuel Waldon or others in the Northeast
Key Dates
December 1, 2025- Antonia M. Apps concludes her tenure as Deputy Director of Enforcement (Northeast).[User Query]
December 26, 2025- Nekia Hackworth Jones concluded her tenure as Deputy Director of Enforcement (Southeast).
March 2025- SEC rescinded delegation of formal order authority to Enforcement Director.
April 2025- Nekia Hackworth Jones appointed Deputy Director (Southeast).
September 2, 2025- Margaret A. Ryan appointed Director of Enforcement.
Compliance Impact
Urgency: Low - This is a routine personnel change with no immediate regulatory shifts or deadlines post-December 1, 2025. It matters indirectly as part of 2025's Enforcement Division overhaul (15% headcount reduction, regional consolidation), likely leading to prioritized, transparent enforcement on
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 โฌ2.5...
AI Analysis
The AMF Enforcement Committee fined financial investment advisor Carat GP โฌ300,000 and its directors Jimmy Guinet (โฌ200,000) and Sรฉbastien Renaud (โฌ2 million) a total of โฌ2.5 million on 5 November 2025, imposing permanent bans on Carat GP and Renaud, and a 10-year ban on Guinet, for breaches including inadequate documentation, failure to act honestly and professionally in clients' interests, AML failures, lack of conflict detection systems, and insufficient cooperation with inspectors. This decision marks the first time the Committee held directors personally liable for breaches, signaling heightened personal accountability for senior managers in French investment firms. It matters as it reinforces AMF's focus on governance, AML, and client protection, with severe sanctions serving as a deterrent amid rising enforcement trends.
#
What Changed
This is an enforcement action, not a regulatory change, but it clarifies and strengthens application of existing AMF rules for conseillers en investissements financiers (CIFs) under French 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 โฌ2.5m 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
Provisions relating to credit institutions and investment firms of EU origin established in Luxembourg by way of branches or exercising activities in Luxembourg by way of free provision of services
AI Analysis
Circular CSSF 07/325, as amended by Circulars CSSF 21/765, CSSF 22/827, and most recently CSSF 25/898, establishes supervisory requirements for EU credit institutions and investment firms operating in Luxembourg via branches or free provision of services (FOPS). It matters for compliance professionals as it defines CSSF's host authority role, notification obligations, reporting, and enforcement powers, ensuring alignment with CRD and MiFID II while adapting to evolving EU rules.
#
What Changed
CSSF 21/765: Updated provisions following amendments to CSSF Regulation No 12-02, refining notification and operational requirements for branches and FOPS.
CSSF 22/827: Further amendments to align with CRD and MiFID II changes, including enhanced notifications for programme alterations (e.g., one-month prior written notice for changes in operations, services, or activities).
CSSF 25/898: Latest update (noted in CSSF Newsletter No 298, November 2025), incorporating recent legal/regulatory develop
What You Need To Do
Notifications
Supervision cooperation
Key Dates
One month before change effective date- Notify CSSF and home authority in writing of programme changes (e.g., operations, services, additional places of business) per CRD Article 36(3) and MiFID II Article 35(10).
Within 3 months of receipt- Home state authority communicates notification file to CSSF for branch/FOPS establishment.
Six months after financial year-end- Submit electronically signed SAQ (via eDesk), annual AML/CFT and conduct of business report (per Circular CSSF 19/731, to be repealed by CSSF 25/902), reviewed by REA.
Compliance Impact
Urgency: Medium - Matters due to recurring annual reporting (e.g., SAQ, AML/CFT within six months post-year-end) and prior notifications for changes, with CSSF enforcement powers (e.g., measures under LFS Article 46(2)) for non-compliance. Recent CSSF 25/898 update (Nov 2025) requires immediate revi
The Bank's Court of Directors acts as a unitary board, setting the organisation's strategy and budget and taking key decisions on resourcing and appointments. Required to meet a minimum seven times per year, it has five executive members from the Bank and up to nine non-executive members.
SS31/15 is the PRA's foundational supervisory statement establishing expectations for how UK-regulated banks and large investment firms must conduct their Internal Capital Adequacy Assessment Process (ICAAP) and how the PRA will evaluate these assessments through its Supervisory Review and Evaluation Process (SREP). This guidance is critical because it directly determines the capital requirements firms must maintain and establishes the supervisory framework through which the PRA assesses whether firms hold sufficient capital to cover material risks.
What Changed
The supervisory statement establishes several core regulatory expectations:
*ICAAP Requirements**
Firms must assess on an ongoing basis whether they hold sufficient capital to cover all material risks, including interest rate risk in the banking book (IRRBB), market risk, operational risk, concentration risk, group risk, pension obligation risk, and foreign currency lending to unhedged retail and SME borrowers
Firms must implement stress testing and scenario analysis as integral components of c
What You Need To Do
*Immediate Compliance Actions
*Establish ICAAP Framework
*Risk Identification and Assessment
*Stress Testing and Scenario Analysis
Results of stress tests carried out in accordance with CRR requirements for firms using IRB approaches or internal models
Key Dates
29 July 2015- SS31/15 first published, replacing PRA SS5/13 and PRA SS6/13
1 July 2026- Effective date for updates to SS31/15 (as referenced in recent amendments)
Ongoing- Firms must carry out ICAAP on a continuous basis in accordance with PRA ICAA rulesDEADLINE
Supervision Asset management Governance Journalists Investment management companies The Autoritรฉ des Marchรฉs Financiers publishes the findings of its thematic inspections on governance and role of senior managers at asset management companies
The PRA and FCA have today confirmed plans to increase flexibility around senior banker pay, alongside changes to create better links between bonus awards and responsible risk-taking.
PS21/25 implements reforms to PRA remuneration rules for banks, building societies, and PRA-designated investment firms, simplifying Material Risk Taker (MRT) identification, aligning deferral periods with international standards (4 years for non-SMF MRTs and 5 years for SMFs), and enhancing links to individual accountability under the Senior Managers Regime (SMR). These changes matter as they reduce regulatory burden, increase flexibility in bonus structures (e.g., marginal deferral rates and cash payments), and promote competitiveness while maintaining risk alignment, potentially reversing trends toward higher fixed pay.
#
What Changed
MRT Identification: Simplified quantitative threshold to the top 0.3% of earners (assessed against risk impact); qualitative criteria unchanged; raised proportionality threshold for disapplying rules from ยฃ44,000 variable pay to ยฃ660,000 total pay (with variable pay โค33% of total); reintroduced exemption for MRTs serving <3 months.
Deferral Periods: 4-year minimum for non-SMF MRTs (previously varied); reduced to 5 years for SMFs (from 7 years); aligns with FCA and international practice.
Deferra
What You Need To Do
Review and update MRT identification processes, applying simplified top 0
Revise remuneration policies for deferral (4/5 years, marginal rates), upfront cash flexibility, and instrument expectations; update bonus award calculations
Embed SMR-linked adjustments
For dual-regulated firms
Optional early adoption for specified changes on 2025/unvested awards; document governance for RemCo approvals and board policies
Key Dates
15 October 2025Publication date; some changes (e.g., deferral periods, pro-rata vesting) may apply to ongoing 2025 performance year and unvested prior awards at firm discretion.
16 October 2025Final rules and updated SS2/17 take effect; apply to performance years starting after this date (e.g., mandatory from 1 January 2026 for calendar-year firms).
November 2024Preceding joint consultation (CP16/24/PRA, CP24/23/FCA) closed prior to PS.
Compliance Impact
Urgency: High โ Mandatory from performance years post-16 October 2025 (e.g., 2026 for most), with immediate opt-in possible; impacts 2026 bonus cycles, requiring swift policy rewrites amid year-end planning. Matters due to simplified but ownership-heavy MRT processes, SMR-pay linkages raising accoun
PS16/25 is the PRA's policy statement restating firm-facing organisational requirements from the MiFID Org Reg (e.g., outsourcing, record-keeping, risk management, compliance, internal audit, and governance) into the PRA Rulebook, with no material changes, to align with HMT's revocation of the EU regulation under FSMA 2023. This matters because it ensures continuity of prudential oversight for PRA-authorised firms post-revocation, preventing enforcement gaps in systems and controls while adapting provisions (e.g., supervisory function) to UK governance structures.
#
What Changed
Restatement of requirements: Provisions from MiFID Org Reg Articles on outsourcing, record-keeping, control procedures, risk management, compliance, internal audit, and governance are transferred verbatim or with minor clarifications into PRA Rulebook parts (e.g., Risk Control).
Supervisory function adjustment: Following consultation feedback, PRA retained Article 25 provisions but substituted "governing body" for "supervisory function" to fit UK firm structures, preserving board-level oversight
What You Need To Do
Review and map existing MiFID Org Reg compliance processes against restated PRA Rulebook provisions (e
Confirm governing body oversight aligns with adapted Article 25 requirements; document any adjustments for UK structures
Update internal references in algorithmic trading governance documents to new rule 2
Conduct gap analysis and training on minor clarifications; prepare for dual FCA/PRA alignment if applicable
Monitor HMT commencement order; if delayed, reassess implementation plans
Key Dates
9 October 2025- PRA publishes PS16/25 with final rules and feedback to CP9/25 consultation.
23 October 2025- New PRA rules and technical standards come into force, coinciding with HMT's anticipated revocation of MiFID Org Reg via commencement order (FCA rules align on same date).
Prior to 23 October 2025- HMT expected to lay second Statutory Instrument revoking remaining MiFID Org Reg provisions; PRA may delay/revoke rules if not made.
Compliance Impact
Urgency: High โ Firms must act promptly as rules take effect on 23 October 2025 (past deadline as of current date), with no transition period; non-compliance risks enforcement gaps in core systems/controls post-revocation. Impact is low for substance (restatement only) but requires documentation upd
The Securities and Exchange Commission today announced that Ken Johnson, who has been serving as Chief Operating Officer (COO) since December 2017, will retire from the agency in December. โKen has been an integral leader at the SEC for more than twoโฆ
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 โฌ1.3 million
AI Analysis
The AMF Enforcement Committee fined asset management company Altaroc Partners โฌ600,000 and its senior managers Maurice Tchenio (โฌ500,000) and Patrick de Giovanni (โฌ200,000) a total of โฌ1.3 million on 15 September 2025 for breaches of professional obligations, including non-operational investment procedures, inadequate AML/CFT due diligence, deficient marketing materials, and unproven benefits from fee retrocessions to distributors. This decision underscores the AMF's heightened scrutiny on operational controls and senior accountability in asset management, serving as a critical enforcement signal for firms to strengthen procedures amid a pattern of similar sanctions.
#
What Changed
This is an enforcement action rather than new legislation, but it reinforces and clarifies existing professional obligations under AMF regulations for asset managers (sociรฉtรฉs 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 dโรtat against decision SAN-2025-09.
Compliance Impact
Urgency: High โ 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
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined an asset management company โฌ400,000 on 9 September 2025 for multiple breaches of professional obligations, including deficient marketing disclosures, inadequate conflict of interest systems, non-operational valuation procedures, failure to oversee external experts, and deficient AML/CFT systems in managing AIFs and club deals. This enforcement action underscores the AMF's focus on operational robustness and investor protection in asset management, serving as a critical reminder for firms to ensure procedures are not only documented but fully operational and effective. Compliance teams should review this to benchmark internal controls, as it highlights personal accountability for senior managers and recurring AMF priorities in recent sanctions.
#
What Changed
This is an enforcement decision, not a regulatory change introducing new rules; it enforces existing professional obligations under AMF jurisdiction for asset managers. 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 โฌ400,000 fine on Eternam for breaches.
Compliance Impact
Urgency: High โ This recent (2025) decision aligns with a pattern of AMF fines on asset managers for similar operational and AML failures (e.g., โฌ1.3M on Altaroc Partners for lacking investment procedures and AML due diligence; โฌ200K+ on M Capital for non-operational systems and AML deficiencies). I
Adoption of the EBA Guidelines on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures (sanctions)
AI Analysis
Circular CSSF 25/896 adopts the EBA Guidelines EBA/GL/2024/14 and EBA/GL/2024/15, mandating Luxembourg financial institutions to establish robust internal policies, procedures, and controls for complying with EU and national restrictive measures (sanctions). This matters because it sets binding EU-wide standards to prevent sanctions violations and circumvention, with absolute obligations for immediate asset freezing and reporting, amid escalating geopolitical tensions.
#
What Changed
Institutions must develop, implement, and maintain up-to-date policies, procedures, and controls for identifying, investigating, and applying restrictive measures without delay, including risk management for violations and circumvention.
Management body responsibilities expanded: approve sanctions compliance strategy, oversee implementation, conduct at least annual assessments of exposure and controls, ensure remedial actions, and report deficiencies.
Screening and monitoring requirements: Maint
What You Need To Do
Conduct annual exposure assessments to sanctions risks and circumvention; update policies accordingly
Appoint senior management/board-level responsibility for approving and overseeing sanctions strategy, including annual reviews and deficiency reporting
Implement reliable screening systems for customers, transactions, and lists; define screenable datasets; test systems regularly for effectiveness (e
Provide documented training to relevant staff on sanctions, institutional exposure, and internal processes
Establish processes for immediate action on matches: suspend transfers, freeze assets, report to Ministry of Finance/CSSF/FIU without delay; maintain whitelists only under strict conditions
Compliance Impact
Urgency: High โ With less than 12 months until the 30 December 2025 deadline (as of January 2026), firms face binding requirements for absolute compliance, including personal accountability for management bodies; non-compliance risks enforcement by CSSF, reputational damage, and fines amid frequent
Thomas Hirschi has decided to leave the Swiss Financial Market Supervisory Authority FINMA effective 31 August 2025. The Head of the Banks division will pursue a new career outside FINMA. FINMAโs Board of Directors and Executive Board thank Thomas Hirschi for his valuable contribution during his time at FINMA.
MiCA Crypto-assets Innovation Implementation of MiCA: The AMF applies ESMA and EBA Guidelines on the assessment of the suitability of members of the management body
At its meeting on 25 June 2025, the Federal Council was informed of the resignation of Rene W. Keller from the Board of Directors of the Swiss Financial Market Supervisory Authority FINMA.
Supervision Professional certification Asset management Journalists Investment management companies The AMF publishes the findings of its inspections on the verification and assessment of employee knowledge within asset management companies
Governance Journalists Listed companies and issuers Women on Boards Directive: the AMF is now the competent authority for analysing and monitoring gender balance among the directors of listed companies
Anti-money Laundering Asset management AMF invites financial market participants to take part in the EBA consultation on draft AML/CFT implementing standards
AI Analysis
The AMF is urging French financial market participants to engage in the EBA's consultation launched on March 6, 2025, on draft Regulatory Technical Standards (RTS) for AML/CFT implementing standards under AMLD6 and AMLR, focusing on harmonized risk assessment methodologies for supervisors and obliged entities. This matters because it signals a shift to uniform EU-wide AML/CFT supervision via AMLA (post-EBA handover on January 1, 2026), requiring firms to adapt to standardized risk indicators, data reporting, and enforcement, with new CDD rules applying from July 2027. Participation ensures firms influence final standards amid the transition to a single EU AML rulebook.
#
What Changed
The draft RTS propose harmonized methodologies for AML/CFT supervision, including:
Risk Assessment of Obliged Entities (Article 40(2) AMLD6): A three-step process with indicators for inherent risk (customers, products/services, geography, distribution channels), control effectiveness (governance, policies, procedures, group supervision), and residual risk; annual reviews and ad-hoc reassessments; standardized scoring for consistent EU supervision.
Risk Assessment for Direct Supervision (Article
What You Need To Do
Participate in EBA consultation
Conduct compliance gap analysis
Enhance systems
Prepare for AMLA supervision
Ongoing monitoring
Key Dates
March 6, 2025 - EBA consultation launchon draft RTS for AML/CFT standards (ongoing as of analysis).
January 1, 2026 - EBA hands over AML/CFT mandates, tools (e.g., EuReCa database), and functions to AMLA; existing EBA guidelines remain until replaced.
July 10, 2027 - New AMLD6/AMLR rules apply directly, including CDD for new customers and start of phased compliance.DEADLINE
By July 2032 - Full CDD compliancefor existing customers (five-year transition from 2027).
2028 - AMLA begins direct supervisionof selected high-risk entities.
Compliance Impact
Urgency: High โ While not yet final, the consultation shapes binding RTS under the new AMLA-led regime post-January 2026 handover, with direct rules from July 2027 requiring system upgrades and data readiness; delays risk non-compliance with harmonized supervision, higher sanctions, and AMLA scrutin
Sanctions & settlements professional obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines Pharnext and its former directors a total of โฌ800,000
AI Analysis
The AMF Enforcement Committee fined Pharnext โฌ500,000 and its former directors Daniel Cohen (โฌ200,000) and David Horn Solomon (โฌ100,000) 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.
#
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 (nยฐ25/05331).
Post-20 January 2025- Appeal lodged by Pharnext, Cohen, and Solomon to Paris Court of Appeal (ongoing).
Compliance Impact
Urgency: Medium โ 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 โฌ15M. Matters for listed firms with pipelin
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 โฌ5,670,000
AI Analysis
The AMF Enforcement Committee imposed total fines of โฌ5,670,000 on a financial investment advisor (FIA), two asset management companies (AMCs), their directors, and a credit institution for breaches of professional obligations. This enforcement action underscores the AMF's rigorous scrutiny of operational controls, due diligence, and governance in investment services, serving as a critical reminder for firms to maintain robust procedures to avoid similar sanctions. It matters because it highlights personal liability for directors and escalating fines for systemic failures, potentially influencing peer reviews and audit priorities.
#
What Changed
This is an enforcement decision, not a regulatory change introducing new rules. It reinforces existing AMF requirements under professional obligations, including:
Implementation of operational procedures for investment/divestment processes, such as verifying lender authorizations.
Systematic anti-money laundering (AML) and counter-terrorism financing (CTF) due diligence on fund assets and liabilities.
Justification of retrocessions (rebates) to distributors, proving enhanced client service 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
15 September 2025Altaroc Partners decision (appeal lodged to Conseil dโรtat).
9 July 2025MND insider dealing decision (appeal to Paris Court of Appeal).
10 December 2025Novaxia Investissement decision.
5 November 2025Carat GP FIA decision.
Compliance Impact
Urgency: High โ This signals intensified AMF enforcement on professional obligations in 2025 (multiple similar fines: โฌ1.3M, โฌ1.89M, โฌ0.5M, โฌ2.5M implied, โฌ0.305M, โฌ3.5M), with personal bans and multimillion fines. Matters due to director accountability trends, potential for follow-on audits, and ed
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
AI Analysis
The AMF Enforcement Committee fined asset management company M Capital Partners โฌ200,000 and its directors Rudy Secco (โฌ70,000) and Stรฉphanie Minissier (โฌ35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness and personal accountability in asset management, serving as a regulatory warning for firms to strengthen internal controls or face escalating sanctions.
#
What Changed
This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and fully operational; failure to verify compliance (e.g., loan authorizations) breaches honesty, fairness, and 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., โฌ1.3M on Altaroc Partners in Sep 2025, โฌ400k on Eternam in Sep 2025), signals AMF's intensified scrutiny on asset manager operations post-AIFMD reviews, with personal fines rising (up to โฌ500k+). Non-compliance risks enf
Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breaches of their professional obligations
AI Analysis
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 โฌ2.5 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 conductโrequirements that apply across the entire financial investment advisory sector.
#
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 Sรฉquence 13 and Jean-Louis Lehmann (โฌ15,000 fines each; 5-year ban)
11 April 2022- AMF Enforcement Committee decision against DCT and Didier Maurin (โฌ150,000 and โฌ200,000 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 (โฌ20,000 and โฌ80,000 fines; 3-year ban)
2 July 2019- AMF Enforcement Committee decision against Invest Securities and financial advisors (โฌ90,000 to โฌ60,000 fines)
Appointment AMF activity Journalists Marie Seiller appointed Resources, Operations and Transformation Director at the Autoritรฉ des Marchรฉs Financiers
Appointment AMF activity Retail investors Journalists France Mayer appointed Retail Investor Relations and Protection Director at the Autoritรฉ des Marchรฉs Financiers
Professional certification AMF activity Journalists The Autoritรฉ des Marchรฉs Financiers announces the new composition of the Financial Skills Certification Board
Appointment Sanctions & settlements Journalists Valรฉrie Michel-Amsellem becomes Chair of the AMF Enforcement Committee
AI Analysis
This AMF publication announces the appointment of Valรฉrie 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.
#
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.
#
What You Need To Do
Review backgrounds of key AMF personnel, including Valรฉrie 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 โฌ100 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
Appointment Sanctions & settlements Journalists Appointements to the AMF Enforcement Committee
AI Analysis
This AMF publication announces the partial renewal of the Enforcement Committee, including four new appointments, two reappointments, and the subsequent election of Valรฉrie 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.
#
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 Aurรฉlien 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 Valรฉrie 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
Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations
AI Analysis
The AMF Enforcement Committee imposed 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
Sanctions & settlements Disclosure Obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines a former manager of a listed company for failing to disclose inside information as soon as possible and for failing to disclose major shareholdings
AI Analysis
The AMF Enforcement Committee imposed a fine on a former manager of a listed company for two violations: failing to disclose inside information to the public as soon as possible under Article 17 of the EU Market Abuse Regulation (MAR), and failing to disclose major shareholdings as required by French regulations. This enforcement action underscores the AMF's strict enforcement of market abuse rules, emphasizing personal accountability for executives in ensuring timely transparency to prevent insider trading risks and maintain market integrity. Compliance teams should review it as a reminder of heightened scrutiny on disclosure delays and threshold crossings.
#
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 >โฌ20k/year), and penalties (up to โฌ100m fines, criminal sanctions)
Key Dates
3 trading days- Managers/PDMRs must report securities transactions to issuer and AMF if annual total exceeds โฌ20,000.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., โฌ10
Sanctions & settlements professional obligations Investment advice Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations
AI Analysis
The AMF Enforcement Committee imposed a five-year ban on financial investment advisor DCT (formerly Didier Maurin Finance) and its director Didier Maurin from practicing, plus fines of โฌ150,000 on the firm and โฌ200,000 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.
#
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 โฌ1,500 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., โฌ2.5M on Carat GP in 2025; โฌ120K-โฌ150K on Capexis upheld 2025), amid 2024-2025 enforcement wave on professional obligations. Matters for CIFs as it heightens
Sanctions & settlements Journalists The AMF Enforcement Committee fines a French tied agent of a Cypriot investment services provider and its manager for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee fined France Safe Media (FSM), a French tied agent of Cypriot provider VPR Safe Financial Group Limited (Alvexo platform), โฌ300,000 and imposed a 10-year ban from tied agent activities and reception/transmission of orders (RTO) services, while its manager Lior Mattouk received a โฌ100,000 fine and similar 10-year ban, for breaches occurring January 2019โSeptember 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.
#
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 (nยฐ 490826) dismissing appeals by FSM and Mattouk, confirming sanctions and ordering โฌ4,000 costs to AMF.
Compliance Impact
Urgency: High โ Though dated (2019โ2021 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
Marketing Savings protection Retail investors Professional investors Journalists The ACPR and AMF encourage financial institutions to continue their efforts to take account of the vulnerability of ageing clients
Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee fined asset management company M Capital Partners โฌ200,000 and its directors Rudy Secco (โฌ70,000) and Stรฉphanie Minissier (โฌ35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness in asset managers, particularly those acting as tied agents, and holds senior managers personally accountable. It matters for compliance as it exemplifies enforcement trends targeting systemic deficiencies, with potential appeals signaling ongoing scrutiny.
#
What Changed
This is an enforcement action, not a regulatory change, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and compliant; failure to verify or document renders systems non-operational.
Scope of services: Asset managers (and tied agents) cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing licensed 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., โฌ1.3M on Altaroc Partners 15 Sep 2025; โฌ400k on Eternam 9 Sep 2025), signaling intensified scrutiny post-AIFMD reviews. Matters due to personal liability for managers, appeal risks amplify
Sanctions & settlements professional obligations Journalists The AMF Enforcement Committee fines the Association Nationale des Conseillers Financiers-CIF for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined the Association Nationale des Conseillers Financiers-CIF (ANACOFI-CIF), a professional association approved for investment advisors (CIFs), โฌ250,000 with a warning, and its former president โฌ20,000 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.
#
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 (โฌ250,000) and M. Patrick Galtier (โฌ20,000).
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 โฌ500,000 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
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined asset management company Altaroc Partners (formerly Amboise Partners SA) โฌ600,000 and its senior managers Maurice Tchenio (โฌ500,000) and Patrick de Giovanni (โฌ200,000) on 15 September 2025 for multiple breaches of professional obligations, including lack of operational procedures for fund investments/divestments, inadequate AML/CFT due diligence, unproven benefits of fee retrocessions to distributors, and shortcomings in marketing materials. This decision underscores the AMF's strict enforcement on operational controls, governance, and client protection in asset management, serving as a critical warning for firms to ensure robust, documented procedures and senior manager accountability. It matters because it highlights personal liability for executives and reinforces AMF's educational role through sanction explanations, potentially increasing scrutiny on similar firms.
#
What Changed
This is an enforcement action, not a regulatory change; it reaffirms and clarifies existing obligations under French financial regulations for asset managers (sociรฉtรฉs 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 dโรtat 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 (โฌ1.3M 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
Sanctions & settlements Journalists Investment services providers By two decisions, the AMF Enforcement Committee fines two investment services providers for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee issued two decisions on 19 June 2023 fining Crรฉdit Industriel et Commercial (โฌ1 million) and Banque CIC Sud-Ouest (โฌ250,000) 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.
#
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 โ 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
Sanctions & settlements Asset management Journalists Investment management companies The AMF Enforcement Committee sanctions an asset management company and two of its managers for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee sanctioned asset management company M Capital Partners and its managers Rudy Secco (โฌ70,000 fine) and Stรฉphanie Minissier (โฌ35,000 fine) with a total firm fine of โฌ200,000 in its decision dated 31 December 2025, for multiple breaches of professional obligations spanning August 2019 to December 2023. This case underscores AMF's strict enforcement on operational compliance, scope of authorized activities, and AML/CFT systems in asset management, serving as a critical reminder for firms to ensure robust, traceable processes and manager accountability. It matters because it highlights personal liability for senior managers and recurring AMF focus on tied agents exceeding permitted services, potentially signaling increased scrutiny in 2026.
#
What Changed
This is an enforcement decision, not a new regulation, but it reinforces and clarifies existing requirements under French Monetary and Financial Code (e.g., Article L. 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 (โฌ200,000), Rudy Secco (โฌ70,000), and Stรฉphanie Minissier (โฌ35,000).
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 โฌ305,000 showing AMF's willingness to penalize both firms and individuals. It matters amid a pattern of similar sanctions (e.g., โฌ200k on Eres
Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined portfolio asset management company M Capital Partners โฌ200,000, and its directors Rudy Secco (โฌ70,000) and Stรฉphanie Minissier (โฌ35,000) on 31 December 2025, for multiple breaches spanning August 2019 to December 2023, including unauthorized placement of financial instruments as a tied agent, non-operational investment allocation processes, inadequate compliance with investment procedures, deficient conflicts of interest management, and non-operational AML/CFT systems. This decision underscores AMF's strict enforcement of operational compliance and scope limitations for asset managers, serving as a critical reminder for firms to ensure robust, traceable systems and director accountability. It matters because it highlights personal liability for managers and recurring AMF focus on AML/CFT and procedural deficiencies, potentially signaling increased scrutiny in 2026.
#
What Changed
This is an enforcement action, not a regulatory change introducing new rules. It reinforces existing obligations under French financial regulations (e.g., Monetary and Financial Code) for asset 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 Stรฉphanie 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., โฌ200k 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
Sanctions & settlements Asset management Compliance Anti-money Laundering Executive & other private individuals Investment management companies The AMF Enforcement Committee fines a portfolio asset management company and its manager for breaches of their...
AI Analysis
The AMF Enforcement Committee fined portfolio asset management company M Capital Partners โฌ200,000 and its managers Rudy Secco (โฌ70,000) and Stรฉphanie Minissier (โฌ35,000) on 31 December 2025 for multiple breaches of professional obligations from August 2019 to December 2023, including unauthorized investment services as a tied agent, non-operational investment allocation processes, deficient conflict-of-interest management, and inadequate AML/CFT systems. This decision underscores AMF's strict enforcement against operational failures in asset management, particularly for firms balancing portfolio management with tied agent roles, emphasizing personal accountability for managers. Compliance teams must review this for gaps in procedures, as it highlights how imprecise processes and poor traceability lead to substantial sanctions.
#
What Changed
This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) for asset managers:
Asset management companies (sociรฉtรฉs 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 Stรฉphanie 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
Appointment AMF activity Institutional Journalists Laure Tertrais is appointed Head of the AMF Chairโs Executive Office with effect from 1 April 2023
Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines the British company H2O AM LLP and two of its executives at the time of the facts for several breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee fined UK asset manager H2O AM LLP โฌ75 million and its executives Bruno Crastes (โฌ15 million, plus a 5-year ban) and Vincent Chailley (โฌ3 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'รtat'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.
#
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'รtat rejects preliminary constitutionality question.
13 June 2025- Conseil d'รtat dismisses appeals (n. 471548, 471744), upholding sanctions and ordering โฌ3,000 costs to AMF.
June 2025.
Compliance Impact
Urgency: High - Finalized enforcement (June 2025) with massive fines (โฌ93M 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
Governance Sustainable Finance Executive & other private individuals Journalists Listed companies and issuers Social and environmental responsibility, the focus of the AMF's 2022 report on corporate governance and executive compensation of listed companies
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
AI Analysis
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 โฌ150,000 and โฌ200,000 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).
#
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 โฌ1,500 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
Markets Periodic & ongoing disclosures The AMF has requested the suspension of ORPEA's financial instruments
AI Analysis
On October 24, 2022, France's Autoritรฉ des marchรฉs 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
Governance Europe & international The AMF encourages French participants to provide feedback to ESMAโs call for evidence on the implementation of the Shareholders Rights Directive (SRD 2)
AI Analysis
The AMF publication urges French market participants to submit feedback to ESMA's call for evidence evaluating the implementation of the Shareholder Rights Directive II (SRD II), which aims to enhance long-term shareholder engagement, transparency in voting processes, and issuer-shareholder dialogue across the EU/EEA. This matters for compliance teams as it signals ongoing regulatory scrutiny of SRD II transposition and operational compliance, potentially leading to harmonized amendments that could require process updates in shareholder identification, voting transmission, and engagement disclosures. French firms' input can influence future EU rules, mitigating risks of non-compliance with evolving standards.
#
What Changed
This AMF notice itself introduces no new regulatory changes; it promotes participation in ESMA's review of SRD II (Directive (EU) 2017/828), implemented via national laws by June 2019 and effective from September 3, 2020. SRD II's core requirements include: shareholder identification without delay, electronic/machine-readable transmission of voting and meeting information along the intermediary chain, confirmation of vote recording/counting, transparency on institutional investor and asset manag
What You Need To Do
Submit feedback to ESMA
Review current compliance
Enhance processes if needed
Monitor ESMA/EC outputs
Key Dates
June 10, 2019- EU Member States' transposition deadline for SRD II into national law (e.g., France via law of May 22, 2019).DEADLINE
September 3, 2020- SRD II go-live date for operational requirements like shareholder identification and voting processes.
October 3, 2022- European Commission request to ESMA/EBA for SRD II input, contextualizing ESMA's ongoing review.
of 2026.)
Compliance Impact
Urgency: Medium - SRD II has been live since 2020, so core compliance is established, but ESMA's review could trigger targeted amendments (e.g., operational standardization), especially for French intermediaries handling cross-border flows. This matters for avoiding supervisory findings in ongoing A
AMF activity AMF Chair: Proposal to appoint Marie-Anne Barbat-Layani
AI Analysis
This AMF publication announces a proposal to appoint Marie-Anne Barbat-Layani as Chair of the AMF, France's financial markets authority responsible for investor protection, market supervision, and regulatory enforcement. It matters for compliance professionals because leadership changes at key regulators like the AMF can signal shifts in enforcement priorities, supervisory focus, or policy directions affecting investment firms, asset managers, and market participants across the EU. While not imposing immediate rules, it warrants monitoring for potential impacts on ongoing consultations and governance expectations.
#
What Changed
No specific regulatory changes or new requirements are outlined in this publication, as it solely concerns a leadership appointment proposal rather than substantive rule amendments. The AMF's standard process for such proposals involves board review and government ratification, but no alterations to the General Regulation, policies, or compliance obligations are proposed here.
#
What You Need To Do
binding appointment proposal without compliance obligations
Monitor AMF website (https
Review existing AMF relationships and prepare for potential shifts in supervisory engagement
Urgency: Low โ This is a procedural leadership announcement with no immediate regulatory or operational impacts. It matters for long-term strategic planning, as the new Chair could influence AMF's approach to MiFID II implementation, sustainability integration, or enforcement, but firms face no urge
Sanctions & settlements Compliance Journalists Investment services providers The AMF Enforcement Committee fines a depositary for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined RBC Investor Services Bank France SA (RBC ISBF) โฌ500,000 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.
#
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 โฌ500,000 fine and warning on RBC ISBF.
08 January 2026- Public news release/publication date of the decision.
Compliance Impact
Urgency: Medium โ 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 (โฌ500k) on procedural lapses, reinforces liability for cash/rat
Sanctions & settlements Journalists The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined an unnamed portfolio asset management company โฌ400,000 for multiple breaches of professional obligations, including non-operational investment/divestment procedures, inadequate conflict of interest management with group service providers, lack of transparency on distributor fee retrocessions, deficient client categorization, and weak AML/CFT due diligence. This enforcement action, mirroring recent similar cases against firms like Novaxia Investissement and Eternam, underscores the AMF's heightened scrutiny on operational robustness and transparency in asset management, serving as a critical reminder for firms to ensure procedures are fully implemented and documented to avoid personal liability for executives.
#
What Changed
This is an enforcement decision rather than new legislation, but it reinforces and clarifies existing regulatory requirements under AMF professional obligations for portfolio asset managers (sociรฉtรฉs 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 โฌ400,000 (similar case on marketing, club deals, conflicts, valuation, AML/CFT).
10 December 2025- AMF Enforcement Committee decision fining Novaxia Investissement โฌ400,000 and director โฌ100,000 (investment processes, group providers, distributor fees, client categorization, AML/CFT).
31 December 2025- AMF Enforcement Committee decision fining M Capital Partners โฌ200,000 and directors โฌ70,000/โฌ35,000 (investment systems, conflicts, AML/CFT).
Compliance Impact
Urgency: High - Recent cluster of identical fines (โฌ200k-โฌ500k 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
Institutional AMF activity Appointment Journalists Appointments to the Legal Affairs Directorate and Enforcement Assistance Directorate of the Autoritรฉ des Marchรฉs Financiers
AI Analysis
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.
#
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., Amรฉlie 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 Sรฉbastien 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
Sanctions & settlements Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee fined financial investment advisor Sรฉquence 13 and its director Jean-Louis Lehmann โฌ15,000 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.
#
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 Sรฉquence 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
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
AI Analysis
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.
#
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 2019AMF Enforcement Committee decision fining Novactifs Patrimoine โฌ250,000 and CEO โฌ100,000 for breaches from March 2014โJuly 2016.
11 April 2022AMF Enforcement Committee decision imposing 5-year bans and fines (โฌ150,000 firm, โฌ200,000 manager) on DCT/Didier Maurin Finance; appeal dismissed by Conseil d'Etat on 9 September 2024.
4 November 2024AMF fines totaling โฌ5,670,000 on FIA Smart Trรฉso Conseil, asset managers, and CACEIS Bank for fund marketing/management breaches.
5 November 2025AMF Enforcement Committee decision fining Carat GP and directors โฌ2.5 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 โฌ2.5M, 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
Sanctions & settlements Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
AI Analysis
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'รtat suspended enforcement of fines pending appeal
9 September 2024- Conseil d'รtat dismissed appeal, upholding all sanctions and ordering payment of โฌ1,500 each to AMF
Appointment Journalists Investment management companies The AMF announces the appointment of Jessica Reyes as Director of the Asset Management Regulation Division
Sanctions & settlements Journalists The AMF to call for an amendment of the law on obstructing investigations and inspections
AI Analysis
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
Sanctions & settlements Journalists The AMF Enforcement Committee fines an issuer's Chief Financial Officer for insider dealing
AI Analysis
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.
#
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
Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company for several breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined asset management company Altaroc Partners โฌ600,000 and its senior managers Maurice Tchenio (โฌ500,000) and Patrick de Giovanni (โฌ200,000) on 15 September 2025 for multiple breaches of professional obligations, including lack of operational procedures for fund investments/divestments, inadequate AML/CFT due diligence, unproven benefits of fee retrocessions to distributors, and shortcomings in marketing materials. This decision underscores AMF's focus on operational controls, due diligence, and transparency in asset management, serving as a key enforcement precedent that highlights personal liability for senior managers. Compliance teams must review it to strengthen internal procedures and governance amid rising AMF scrutiny on these issues.
#
What Changed
This is an enforcement action, not a regulatory change introducing new rules; it enforces existing obligations under French financial regulations for asset management companies (sociรฉtรฉs 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.
202509 (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 โฌ1.3 million and personal accountability, amid a pattern of similar actions (e.g., M Capital Partners โฌ305,000 in Dec 2025, Eternam โฌ400,000 in Sep 20