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The AMF Enforcement Committee fines Pharnext and its former directors a total of €800,000

AI Analysis

Executive Summary

The AMF Enforcement Committee fined Pharnext €500,000 and its former directors Daniel Cohen (€200,000) and David Horn Solomon (€100,000) on 20 January 2025 for failing to disclose inside information promptly and disseminating false or misleading information about FDA interactions for a drug candidate. This enforcement action reinforces AMF's strict stance on market abuse rules under EU MAR, highlighting personal liability for directors in listed biotech firms where investor expectations around product approvals are high. Compliance teams should note it as a reminder of timely disclosure obligations, especially amid appeals filed by the parties. #

What Changed

This is not a regulatory change but an enforcement decision applying existing obligations under the Market Abuse Regulation (MAR), specifically: - Article 17 MAR: Requirement to disclose inside information as soon as possible (breached by Pharnext's delays from 10 April 2019 and non-disclosure from 28 October 2020). - Article 12(1)(c) MAR: Prohibition on disseminating false or misleading information that could affect market prices, via press releases and shareholder letters overstating FDA progress. No new rules introduced; it clarifies application to pre-marketing FDA milestones in biotech, where market anticipation amplifies disclosure risks. #

What You Need To Do

  • Review inside information policies
  • Audit communications
  • Director training
  • Monitor appeals
  • wide actions mandated beyond general MAR compliance, but proactive gap analysis recommended

Key Dates

10 April 2019 - FDA request for additional study deemed inside information; not disclosed until 30 August 2019.
28 October 2020 - FDA 'non-agreement' on clinical study design deemed inside information; never publicly disclosed.
20 January 2025 - AMF Enforcement Committee decision imposing fines (SAN-2025-01).
23 July 2025 - Paris Court of Appeal dismissed David Horn Solomon's stay of execution application (n°25/05331).
Post-20 January 2025 - Appeal lodged by Pharnext, Cohen, and Solomon to Paris Court of Appeal (ongoing).

Compliance Impact

Urgency: Medium – This is a specific enforcement (not a new rule), but it signals heightened AMF scrutiny on biotech disclosures amid investor sensitivity to approval news; delays in similar cases could trigger investigations/fines up to 15% of turnover or €15M. Matters for listed firms with pipeline dependencies, as it exemplifies director accountability and market-wide deterrence post-MAR implem

Who is Affected

Listed companies and issuers*biotech/pharma sectors reliant on regulatory approvals (e.g., FDA interactions).Directors and senior managerslisted firms, facing personal fines for attributable breaches.Compliance officersstakes issuers must prioritize this.

Summary

Sanctions & settlements professional obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines Pharnext and its former directors a total of €800,000

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