The AMF Enforcement Committee sanctions a media company and its director for making investment recommendations without mentioning conflicts of interest and for price manipulation

What Changed

• This enforcement decision does not introduce new regulations but reaffirms and clarifies existing requirements under AMF rules and EU Market Abuse Regulation (MAR):
• Mandatory conflict of interest disclosure: Investment recommendations must explicitly mention any conflicts, such as financial stakes or relationships influencing the advice, to ensure clear, non-misleading information.
• Prohibition on price manipulation: Practices artificially influencing security prices, including through coordinated recommendations, are strictly banned, with liability extending to directors. These align with AMF General Regulation and professional

Suggested Considerations

• Conduct conflict of interest audits: Review all investment recommendations, publications, and marketing materials for undisclosed conflicts; implement mandatory disclosure templates.
• Enhance surveillance for market abuse: Deploy monitoring tools for price manipulation indicators, such as unusual trading post-recommendation, and train staff on MAR prohibitions.
• Update compliance policies: For media/financial firms, mandate pre-publication reviews of recommendations; directors must personally attest to compliance.
• Training programs: Roll out firm-wide training on professional obligations, including clear information provision and acting in client best interests, especially for journalists/influencers.
• Inducement reviews: If paying/receiving fees tied to recommendations, demonstrate they improve client service quality via audits and reporting.
• assess against AMF Position-Recommendation 2013-10 and prepare for potential AMF requests for marketing materials.

Who is Affected