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 highlighted include: - 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 pe
What You Need To Do
- Audit procedures immediately
- Enhance AML/CFT systems
- Validate marketing and fees
- Senior manager training
- Mock AMF inspections
- 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
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