The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations

What Changed

• The decision does not introduce new regulatory requirements but rather clarifies enforcement expectations for existing obligations:
• Liquidity Risk Management: Asset managers must establish procedures that are both adequate in design and operational in practice, not merely documented
• Market Abuse Detection Systems: Surveillance systems must specify conditions for participation in market surveys and establish clear consequences for non-compliance
• AML/CFT Procedures: Risk mapping and client onboarding procedures must be sufficiently detailed to identify and assess money laundering risks, including beneficial owner identification and politically exposed person (PEP) detection
• Compliance Function: The compliance and internal control officer must actively centralize and monitor information on market abuse across the organization

Suggested Considerations

• assessments across these areas:
• *Liquidity Risk Management: Review procedures for adequacy and operational effectiveness; ensure they address fund-specific liquidity profiles and stress scenarios
• *Market Abuse Detection: Audit surveillance systems to confirm they specify participation conditions in market surveys and document consequences for violations
• *AML/CFT Compliance: Enhance risk mapping to capture money laundering typologies; strengthen client onboarding procedures to verify beneficial owners and screen for PEPs
• *Compliance Monitoring: Establish centralized processes for the compliance officer to aggregate and review market abuse information across all business lines
• *Documentation: Ensure all procedures are documented, communicated, and evidenced through staff training and audit trails

Key Dates

Who is Affected