The AMF Enforcement Committee sanctions an asset management company and two of its managers for breaches of their professional obligations
Executive Summary
The AMF Enforcement Committee sanctioned asset management company M Capital Partners and its managers Rudy Secco (€70,000 fine) and Stéphanie Minissier (€35,000 fine) with a total firm fine of €200,000 in its decision dated 31 December 2025, for multiple breaches of professional obligations spanning August 2019 to December 2023. This case underscores AMF's strict enforcement on operational compliance, scope of authorized activities, and AML/CFT systems in asset management, serving as a critical reminder for firms to ensure robust, traceable processes and manager accountability. It matters because it highlights personal liability for senior managers and recurring AMF focus on tied agents exceeding permitted services, potentially signaling increased scrutiny in 2026. #
What Changed
- This is an enforcement decision, not a new regulation, but it reinforces and clarifies existing requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) and AMF rules for asset managers:
- Asset management companies (AMCs) acting as tied agents cannot provide placement of financial instruments without a firm commitment basis, as this exceeds the restrictive list of permitted investment services.
- Investment allocation processes must be precise, operational, and traceable, with demonstrated compliance to investment procedures.
- Firms must maintain effective systems for conflicts of interest identification/prevention, AML/CFT (including adequate due diligence), and overall operational controls. These align with patterns in prior cases, emphasizing "operational" policies (not
Suggested Considerations
- Review and enhance tied agent activities to ensure no unauthorized investment services like non-firm commitment placements; map against permitted services list.
- Audit investment allocation systems for precision, operationality, and traceability; implement verifiable verifications.
- Strengthen AML/CFT frameworks: ensure due diligence is adequate, systems are operational, and staff training is regular.
- Update conflicts of interest policies with clear identification, prevention, and management procedures.
- Conduct senior manager attestations on personal oversight; perform gap analysis against this and similar cases (e.g., Eres Gestion, Inter Gestion).
Key Dates
Compliance Impact
Urgency: High - This recent (Dec 2025) decision directly implicates senior accountability and operational failures in core AMC functions, with fines totaling €305,000 showing AMF's willingness to penalize both firms and individuals. It matters amid a pattern of similar sanctions (e.g., €200k on Eres in 2023 for procedures/investor info; warnings/fines on Inter Gestion in 2024 for AML), indicating
Who is Affected
References
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Summary
Sanctions & settlements Asset management Journalists Investment management companies The AMF Enforcement Committee sanctions an asset management company and two of its managers for breaches of their professional obligations