The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
Executive Summary
The AMF Enforcement Committee imposed a €150,000 fine on **Inocap Gestion**, a portfolio asset management company, for multiple operational and compliance failures between 2022 and the enforcement decision date. This case demonstrates the AMF's enforcement priorities around liquidity risk management, market abuse detection systems, and anti-money laundering (AML/CFT) procedures—critical control areas that asset managers must operationalize effectively to avoid substantial penalties.
What Changed
The decision does not introduce new regulatory requirements but rather clarifies enforcement expectations for existing obligations: - Liquidity Risk Management: Asset managers must establish procedures that are both adequate in design and operational in practice, not merely documented - Market Abuse Detection Systems: Surveillance systems must specify conditions for participation in market surveys and establish clear consequences for non-compliance - AML/CFT Procedures: Risk mapping and client 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 informat
What You Need To Do
- assessments across these areas
- *Liquidity Risk Management
- *Market Abuse Detection
- *AML/CFT Compliance
- *Compliance Monitoring
- *Documentation
Key Dates
Compliance Impact
Urgency: HIGH
Who is Affected
Summary
Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations