The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations
Executive Summary
The AMF Enforcement Committee fined asset management company Altaroc Partners (formerly Amboise Partners SA) €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) on 15 September 2025 for multiple breaches of professional obligations, including lack of operational procedures for fund investments/divestments, inadequate AML/CFT due diligence, unproven benefits of fee retrocessions to distributors, and shortcomings in marketing materials. This decision underscores the AMF's strict enforcement on operational controls, governance, and client protection in asset management, serving as a critical warning for firms to ensure robust, documented procedures and senior manager accountability. It matters because it highlights personal liability for executives and reinforces AMF's educational role through sanction explanations, potentially increasing scrutiny on similar firms. #
What Changed
This is an enforcement action, not a regulatory change; it reaffirms and clarifies existing obligations under French financial regulations for asset managers (sociétés de gestion de portefeuille). Key requirements emphasized include: - Implementing operational procedures for investment/divestment processes, including verification of lender authorizations. - Conducting systematic AML/CFT due diligence on fund assets and liabilities. - Proving that fee retrocessions to distributors enhance client service quality. - Ensuring marketing materials are accurate and compliant. These align with ongoing AMF expectations for "honest, fair, professional" conduct with requisite skill, care, and diligence. #
What You Need To Do
- Review and document operational procedures for fund investments/divestments, including lender authorization checks
- Enhance AML/CFT systems with systematic due diligence on fund assets/liabilities and risk mapping
- Audit fee retrocession arrangements to demonstrate tangible client service improvements (e
- Validate marketing materials for accuracy and completeness
- Conduct senior manager attestations on compliance oversight; implement training on personal liability
- Perform gap analyses against AMF sanction rationales, with board-level reporting
Key Dates
Compliance Impact
Urgency: High - This recent (2025) enforcement demonstrates AMF's willingness to impose multimillion-euro fines (€1.3M total) and hold executives personally accountable for systemic failures in core areas like operations, AML, and client disclosure. It matters for immediate risk as appeals are pending but do not suspend obligations; firms with similar setups face elevated audit risk, especially am
Who is Affected
Summary
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations