The AMF Enforcement Committee fines three legal entities and eight individuals for insider dealing breaches and failure to maintain and update insider lists
Executive Summary
The AMF Enforcement Committee imposed fines totaling over €3 million on three legal entities and eight individuals in its 30 January 2023 decision for insider dealing in Terreïs shares based on two pieces of inside information, and for Terreïs's failure to maintain and update its insider list. This case matters because it exemplifies AMF's rigorous enforcement of market abuse rules under the Market Abuse Regulation (MAR), highlighting indicators like atypical trading timing, order placement methods, and information transmission channels that trigger sanctions, serving as a deterrent and educational tool for compliance programs. #
What Changed
This enforcement decision does not introduce new regulatory changes or requirements; it applies existing obligations under French market abuse rules aligned with EU MAR (Regulation (EU) No 596/2014). Key reaffirmed requirements include: prohibiting the use, disclosure, or recommendation of inside information for trading; maintaining and regularly updating insider lists with details of persons having access to inside information; and ensuring issuers like Terreïs promptly detect and prevent breaches through robust surveillance. #
What You Need To Do
- Review and strengthen insider list management
- Enhance market abuse surveillance
- Conduct insider trading risk assessments
- Update compliance training and policies
Key Dates
Compliance Impact
Urgency: Medium - This 2023 decision reinforces longstanding MAR rules without new mandates, but its detailed analysis of enforcement indicators demands immediate policy reviews to mitigate fines up to €1M+ per breach. It matters for firms handling listed securities, as AMF prioritizes educational enforcement via public decisions, increasing scrutiny on insider lists and trading surveillance amid
Who is Affected
Summary
Sanctions & settlements Journalists The AMF Enforcement Committee fines three legal entities and eight individuals for insider dealing breaches and failure to maintain and update insider lists