The AMF Enforcement Committee fines an asset management company and its two managers a total of €1.3 million
Executive Summary
The AMF Enforcement Committee fined asset management company Altaroc Partners €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) a total of €1.3 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 (sociétés de gestion), particularly under the AIFM regime. Key expectations highligh
- 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 liabilities; non-operational procedures or risk mapping constitute breaches.
- Marketing and fee retrocessions: Materials must be accurate; firms must prove retrocessions enhance client service quality.
- Senior manager accountability: Breaches attributable to responsible managers, emphasizing personal liability for oversight failures. No explicit regulatory changes, but the decision aligns with AMF's educational role in interpreting UCITS/AIFM rules
Suggested Considerations
- Audit procedures immediately: Review and document operational status of investment/divestment processes, ensuring traceability of lender checks, fund policy compliance, and AML/CFT due diligence on assets/liabilities.
- Enhance AML/CFT systems: Formalize risk mapping, procedures, and systematic investor/transaction due diligence; test for operational effectiveness.
- Validate marketing and fees: Audit fund materials for accuracy; gather evidence that fee retrocessions to distributors improve client services (e.g., via service level agreements or performance metrics).
- Senior manager training: Conduct gap analysis on personal accountability; update governance frameworks to mitigate attribution of firm breaches.
- Mock AMF inspections: Simulate Enforcement Committee reviews, focusing on procedure formalization, independent valuers (if applicable), and conflict systems.
- 6 months, given the pattern of 2025 sanctions.
Key Dates
Compliance Impact
Urgency: High – 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 controls and AML gaps amid EU AIFMD reviews. Non-compliance risks personal fines up to €500,000+ for
Who is Affected
References
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Summary
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 €1.3 million