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 ad
Suggested Considerations
- Review and enhance investment/divestment procedures: Ensure completeness, traceability of all compliance checks (e.g., alignment with fund policies), and formalized pre-allocation due diligence; test for operationality via internal audits.
- Document all processes rigorously: Maintain evidence of checks and due diligence to demonstrate skill, care, and diligence in line with authorization conditions.
- Conduct gap analysis against AMF expectations: Cross-reference with similar cases (e.g., operational procedures, AML/CFT); remediate deficiencies promptly.
- Senior manager training: Reinforce personal accountability for firm compliance; update governance frameworks.
- Appeal monitoring: If similarly positioned, prepare for potential appeals to Conseil d’État.
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
References
AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.
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