The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
Executive Summary
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness in asset managers, particularly those acting as tied agents, and holds senior managers personally accountable. It matters for compliance as it exemplifies enforcement trends targeting systemic deficiencies, with potential appeals signaling ongoing scrutiny. #
What Changed
This is an enforcement action, not a regulatory change, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers: - Operational procedures: Investment allocation processes must be precise, traceable, and compliant; failure to verify or document renders systems non-operational. - Scope of services: Asset managers (and tied agents) cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing licensed activities. - Conflicts of interest: Robust identification, prevention, and management systems are mandatory. - AML/CFT: Due diligence on fund assets/liabilities must be systematic and operational, with effective risk mapping and procedures. - Senior accountability: Breaches attributable to responsib
What You Need To Do
- Immediate gap analysis
- Enhance AML/CFT
- Conflicts framework
- Senior manager attestation
- Marketing/retrocessions
- Appeal monitoring
Key Dates
Compliance Impact
Urgency: High - This reflects a pattern of 2025 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc Partners 15 Sep 2025; €400k on Eternam 9 Sep 2025), signaling intensified scrutiny post-AIFMD reviews. Matters due to personal liability for managers, appeal risks amplifying precedent, and applicability to hybrid models; non-compliance risks fines scaling to €1M+ and re
Who is Affected
Summary
Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations