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The AMF Enforcement Committee fines three individuals and one legal entity a total of €700,000 for insider dealing breaches

AI Analysis

Executive Summary

The AMF Enforcement Committee imposed fines totaling €700,000 on three individuals and one legal entity for insider dealing violations, demonstrating the regulator's ongoing commitment to enforcing Market Abuse Regulation (MAR) prohibitions on trading with inside information. This case underscores the AMF's aggressive pursuit of insider networks and coordinated breaches, serving as a stark reminder for firms to bolster insider trading surveillance and training programs. Compliance teams should use it to reinforce policies amid rising detections of organized insider activities. #

What Changed

This is an enforcement action, not a regulatory change; it reaffirms existing MAR requirements under Articles 7 (inside information definition), 8 (insider lists), 14 (insider dealing prohibition), 17 (public disclosure), and 19 (PDMR trading restrictions, including 30-day black-out periods before financial results). No new rules are introduced, but it highlights AMF's reliance on firms for detection via internal policies, whistleblowing, and gift/invitation controls, as echoed in recent AMF-AFA guidance. Related updates include EU Regulation 2024/2809 (effective December 4, 2024), amending MAR on disclosures and inside information management. #

What You Need To Do

  • Update insider policies
  • Enhance training and awareness
  • Strengthen surveillance
  • Report promptly
  • Conduct audits
  • Certify diligence

Key Dates

December 4, 2024 - EU Regulation 2024/2809 enters force , amending MAR on inside information and disclosures.
June 5, 2026 - Certain amendments to insider trading policies (e.g., Groupe Casino policy) apply ; others immediate from February 2025.
June 30, 2026 - AMF General Regulation updates effective , covering certifications for financial instruments and prospectuses.
Within 3 trading days - PDMRs must report securities transactions to issuer and AMF.

Compliance Impact

Urgency: High – This enforcement signals intensified AMF focus on insider networks, with fines demonstrating willingness to penalize both individuals (€700,000 total) and entities amid a "worrying trend" of organized crime infiltration. Firms face elevated inspection risks, especially post-AMF-AFA vigilance call (2025), and must act preemptively to avoid similar sanctions, as MAR breaches undermin

Who is Affected

Listed companies and issuersout periods (30 days pre-annual/interim results, 15 days pre-quarterly), and ongoing disclosure protocols per AMF Position-Recommendation 2016-08.Persons Discharging Managerial Responsibilities (PDMRs), executives, directors, and high-ranking officialsPermanent and occasional insidersout recommendations apply.Investment firms, brokers, and legal entitiesAll market participants

Summary

Sanctions & settlements Executive & other private individuals Journalists The AMF Enforcement Committee fines three individuals and one legal entity a total of €700,000 for insider dealing breaches

Relevant Firm Types

Broker DealerAll Firms
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