AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
Executive Summary
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness and personal accountability in asset management, serving as a regulatory warning for firms to strengthen internal controls or face escalating sanctions. #
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 instruments without firm commitment, circumventing permitted investment services. - Conflicts of interest: Systems must effectively identify, prevent, and manage conflicts. - AML/CFT due diligence: Procedures, risk mapping, and due diligence on fund assets/liabilities must be operational and systematic.
What You Need To Do
- Conduct gap analysis
- Enhance AML/CFT
- Strengthen governance
- Audit marketing/distribution
- Senior manager certification
- report remediation to AMF Secretary General if breaches identified
Key Dates
Compliance Impact
Urgency: High - This recent (Dec 2025) decision, alongside similar fines (e.g., €1.3M on Altaroc Partners in Sep 2025, €400k on Eternam in Sep 2025), signals AMF's intensified scrutiny on asset manager operations post-AIFMD reviews, with personal fines rising (up to €500k+). Non-compliance risks enforcement, reputational damage, and appeals delays; act within 3-6 months to align before potential a
Who is Affected
Summary
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