The AMF Enforcement Committee fines one natural person and five legal entities, including an investment management company, for failing to comply with several reporting obligations in relation to a concerted action carried out in the context of a part...
Executive Summary
The AMF Enforcement Committee imposed fines on one natural person and five legal entities, including an investment management company, for failing to comply with multiple reporting obligations related to a concerted action during a partial takeover bid.[User Query]. This enforcement action underscores the AMF's strict enforcement of transparency rules in takeover scenarios, serving as a critical reminder for market participants to adhere to disclosure timelines to avoid significant financial penalties and reputational damage. #
What Changed
This is not a regulatory change or new requirement but an enforcement decision highlighting existing obligations under French financial markets law, particularly those governing concerted actions (actions concertées) and reporting in takeover bids. Key requirements reinforced include: - Timely disclosure of positions and intentions when parties act in concert, as per AMF regulations on major holdings and takeover bids (e.g., Article L. 233-10 of the French Commercial Code and AMF General Regulation). - Reporting thresholds for share acquisitions or concerted behaviors that could influence control, typically triggered at 5% crossings or changes. No new rules were introduced; the decision reiterates the need for precise, prompt filings to the AMF to prevent market disruption.[User Query] #
What You Need To Do
- Review and enhance internal procedures for monitoring share positions, identifying concerted actions, and automating AMF filings
- Train front-office and compliance teams on takeover bid disclosures, including documentation of coordination (e
- Implement pre-trade alerts for threshold breaches and conduct periodic audits of historical filings
- For management companies
Key Dates
Compliance Impact
Urgency: High - This matters due to the AMF Enforcement Committee's pattern of fining reporting failures (e.g., €1.89M in July 2025 for late disclosures, €1.7M in June 2025 for shareholder breaches), signaling intensified scrutiny on M&A transparency amid volatile markets. Non-compliance risks fines up to €100M or 10% of turnover, plus bans, directly impacting investor trust and operations; firms
Who is Affected
Summary
Sanctions & settlements Journalists The AMF Enforcement Committee fines one natural person and five legal entities, including a management company, for failing to comply with several reporting obligations in relation to a concerted action carried out in the context of a takeover bid and, in the case of the...