The AMF Enforcement Committee fines an issuer and two of its former directors at the time of the facts for market manipulation by disseminating false or misleading information. It also fined one of the directors for insider trading breaches
Executive Summary
The AMF Enforcement Committee imposed fines on an issuer and two former directors for market manipulation via dissemination of false or misleading information, with an additional fine on one director for insider trading violations. This enforcement action underscores the AMF's rigorous enforcement of market abuse rules under the Market Abuse Regulation (MAR), serving as a stark reminder of personal and corporate liability for disclosure failures and privileged information misuse. Compliance teams must prioritize robust controls to mitigate similar risks, as such violations erode market integrity and investor trust. #
What Changed
This is an enforcement decision rather than new legislation, so there are no direct regulatory changes. It reinforces existing obligations under Book VI of the AMF General Regulation on market abuse, including insider dealing and market manipulation, aligned with Regulation (EU) No 596/2014 (MAR). Key principles upheld include prohibitions on disseminating false/misleading information that impacts security prices and trading on inside information, with no novel requirements but heightened emphasis on director accountability. #
What You Need To Do
- Implement or strengthen disclosure controls to ensure all public information is accurate and non-misleading, with pre-approval for promotional materials submitted to AMF
- Enhance insider lists and training for directors on MAR prohibitions, including trading blackouts before announcements
- Deploy surveillance systems to detect market manipulation signals, with compliance officers mandated to report suspicious transactions to AMF
- Conduct due diligence attestations for prospectuses/public offers, confirming no material omissions
- Review governance for personal liability, including cooperation incentives in investigations per proposed AMF powers
Key Dates
Compliance Impact
Urgency: High - This demonstrates AMF's aggressive stance on market abuse amid rising "insider networks" and organized crime threats, with fines signaling personal risk for directors. It matters because enforcement is intensifying (e.g., web scraping for investigations, expanded sanctions like 10-year director bans proposed in 2025 bill), potentially increasing scrutiny on disclosures amid 2026 pr
Who is Affected
Summary
Sanctions & settlements Disclosure Obligations Professional investors The AMF Enforcement Committee fines an issuer and two of its former directors at the time of the facts for market manipulation by disseminating false or misleading information. It also fined one of the directors for insider...