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 non-operational investment systems, deficient AML/CFT procedures, inadequate conflict of interest management, and poor due diligence traceability. This decision underscores AMF's focus on operational robustness in asset management, with personal liability for senior managers, signaling heightened enforcement risk for similar firms. Compliance teams must prioritize reviewing internal procedures to avoid comparable sanctions, as appeals are possible but do not suspend obligations. #
What Changed
This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under the French Monetary and Financial Code for asset managers to maintain operational procedures. Key breaches highlighted include: - Imprecise investment allocation processes lacking traceability, rendering systems non-operational. - Failure to fulfill conflict of interest identification, prevention, and management obligations. - Deficient AML/CFT systems with inadequate due diligence on fund assets/liabilities. These align with prior AMF expectations for "honest, fair, and professional" conduct with skill, care, and diligence, as seen in similar cases like Altaroc Partners (no operational investment/divestment procedures, AML failures). #
What You Need To Do
- Conduct immediate gap analysis of investment processes for operationality, traceability, and precision in allocation rules
- Enhance AML/CFT systems
- Review conflict of interest frameworks for identification, prevention, and management; document controls rigorously
- Senior managers
- Audit marketing materials, fee retrocessions, and valuation procedures (e
Key Dates
Compliance Impact
Urgency: High - This reflects a pattern of 2025-2026 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc 15 Sep 2025; €400k on Eternam 9 Sep 2025), indicating intensified scrutiny and personal accountability. Firms risk multimillion fines and reputational damage; immediate audits are essential pre-audit cycles, especially with appeals highlighting ongoing litigation ri
Who is Affected
Summary
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations