The AMF Enforcement Committee fines an asset management company and its former director a total of €500,000
Executive Summary
The AMF Enforcement Committee fined asset management company Novaxia Investissement €400,000 and its former director Joachim Azan €100,000 on 10 December 2025 for breaches of professional obligations, primarily due to an incomplete and non-operational investment/divestment procedure lacking traceability of compliance checks and formalized due diligence. This enforcement action underscores AMF's focus on robust operational procedures in asset management, serving as a deterrent and educational tool for ensuring honest, fair, and diligent business conduct. Compliance teams should prioritize procedure operationalization to avoid similar sanctions, as this fits a pattern of recent AMF fines targeting procedural deficiencies. #
What Changed
This is an enforcement decision, not a new regulation, but it reinforces existing requirements under AMF professional obligations for asset managers (sociétés de gestion), including: - Fully operational investment and divestment procedures that ensure traceability of compliance checks against fund policies and constraints. - Formalized due diligence prior to allocating investment projects to funds. No explicit changes to rules; instead, it clarifies enforcement expectations for procedure completeness and documentation, aligning with prior cases emphasizing operational adequacy. #
What You Need To Do
- Review and enhance investment/divestment procedures
- Document all processes rigorously
- Conduct gap analysis against AMF expectations
- Senior manager training
- Appeal monitoring
Key Dates
Compliance Impact
Urgency: High – This decision, part of a 2025 enforcement wave fining asset managers €400k–€1.3m for procedural lapses (e.g., non-operational investment processes, inadequate due diligence), signals intensified AMF scrutiny on operational integrity. Firms risk personal fines for managers and reputational damage; immediate procedure audits are essential to mitigate exposure, especially pre-authoriz
Who is Affected
Summary
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its former director a total of €500,000