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The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations

AI Analysis

Executive Summary

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 competence, care, and diligence. - Cooperation with Regulators: Advisors must provide documents and information requested during regulatory investigations; refusal constitutes a separate breach of diligence and loyalty obligations.

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
  • *Training and Governance

Key Dates

11 April 2022 - AMF Enforcement Committee issued original decision imposing five-year ban and fines
18 July 2022 - Conseil d'ร‰tat suspended enforcement of fines pending appeal
9 September 2024 - Conseil d'ร‰tat dismissed appeal, upholding all sanctions and ordering payment of โ‚ฌ1,500 each to AMF

Compliance Impact

Urgency: HIGH

Who is Affected

Financial investment advisorsAsset management advisorsManagers and directorsAny firm marketing non-EU or non-authorized investment products to French clients

Summary

Sanctions & settlements Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations

Relevant Firm Types

Asset ManagerWealth Manager
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