Investment Management in France

Key dates

2026-06-08

The AMF launched its public consultation on the draft recommendation on MMF liquidity.

2026-10-30

The AMF published final Recommendation DOC-2026-07 on liquidity management for money market funds.

Suggested considerations

• Consider mapping each affected MMF’s current and stressed WLA against both the applicable MMFR minimum and the AMF market-resilience reference level of 20% or 40%.
• Consider documenting fund-specific liquidity calibration, including investor concentration, expected redemption patterns, dealing frequency, portfolio composition, currency exposure and market-liquidity assumptions, rather than relying only on a static WLA benchmark.
• Consider reviewing liquidity-risk dashboards and escalation triggers so that a fall below the relevant resilience level is identified promptly and escalated through strengthened internal governance.
• Consider establishing a documented process to determine when a breach has persisted for 10 business days and when a prolonged or significant deviation is reasonably anticipated.
• Consider preparing an AMF notification package containing the duration and scale of the deviation, its causes, remedial measures, portfolio and investor-liquidity analysis, and relevant stress-test results.
• Consider reviewing stress-testing scenarios and management information to ensure they support decisions to use or rebuild liquidity buffers without automatically activating liquidity-management tools solely because the resilience level is breached.
• Consider confirming that policies distinguish the AMF supervisory resilience levels from the binding 15% and 30% MMFR WLA minima and identify the different consequences of each threshold.
• Consider monitoring coordinated guidance from the Central Bank of Ireland, Luxembourg’s CSSF and the UK FCA because comparable 20% and 40% reference levels may affect cross-border group governance and supervisory expectations.

What changed

The AMF expects VNAV MMFs generally to maintain at least 20% WLA, compared with the 15% statutory minimum under Regulation (EU) 2017/1131 on money market funds (MMFR). Public debt CNAV and LVNAV MMFs are expected generally to maintain at least 40% WLA, compared with the 30% MMFR minimum. These are supervisory market-resilience levels rather than new statutory MMFR minimums. Where a fund falls sustainably below the relevant level, its management company is expected to apply heightened liquidity-risk vigilance, rapid escalation procedures and strengthened internal decision-making.

Key dates

2026-10-13

Instruction DOC-2026-05 was published; it applies to the specified OPCIs and evergreen FCPRs, and the two-year transition period begins for funds established before this date.

2028-10-13 Deadline

End of the two-year transition period for OPCIs and evergreen FCPRs established before 2026-10-13. Management companies should have notified the AMF of compliance through ROSA and filed the prospectus or rules and required stress tests by this date.

Suggested considerations

• Firms should identify every OPCI and evergreen FCPR in scope and map its redemption frequency, notice period, current liquid-asset holdings and applicable minimum cushion under Instruction DOC-2026-05.
• Management companies should calculate whether each fund satisfies the applicable permanent cushion and assess whether the potentially reduced regime for funds marketed exclusively through eligible insurance or savings products is available and properly evidenced.
• Compliance teams may wish to update prospectuses, evergreen FCPR rules and related investor disclosures to state the minimum liquid-asset cushion using the applicable Annex VII format.
• Firms should produce or refresh liquidity stress tests using all scenarios specified in DOC-2026-05, including evidence that redemption requests can be met, and establish governance for periodic review and escalation of shortfalls.
• Management companies should review whether any proposed change to redemption frequency or notice period would alter the required cushion and, if so, plan for prior AMF approval, specific investor notification and the applicable fee-free redemption right.
• For funds existing on 2026-10-13, firms should plan the ROSA filing of the amended prospectus or rules and compliant stress tests before the end of the two-year transition period.
• Product, distribution and insurance teams should verify that marketing materials and product documentation do not imply liquidity inconsistent with the fund’s redemption terms, liquid-asset cushion or stress-test assumptions.
• Firms should monitor the forthcoming French transposition of Directive (EU) 2024/927 and assess whether subsequent statutory liquidity-management-tool requirements impose additional controls beyond DOC-2026-05.

What changed

The former authorisation approach, under which management companies generally demonstrated liquid assets equal to 30% to 40% of net assets and submitted stress tests, is replaced or formalised through a permanent liquidity cushion calibrated to the fund’s redemption frequency or redemption notice period. The AMF gives a monthly-redemption fund as an example requiring at least 25% of net assets in liquid assets.

Key dates

January 2021

- Start of the period during which Financière Fonds Privés is found to have committed unauthorised placement and advisory breaches

October 2024

- End of the factual period examined by the AMF Enforcement Committee for the identified breaches

TBD (post‑21 July 2026)

- Potential appeal phase before the Conseil d’État; the decision indicates that an appeal may be lodged, so firms should monitor for any subsequent case law impacting interpretation of CIF professional obligations

21 July 2026

- AMF Enforcement Committee decision imposing fines of €100,000 on Financière Fonds Privés, €70,000 on Pierre‑Michel Deléglise, and €40,000 on Thierry de Chambure, and attributing all breaches to the two senior managers

28 July 2026

- Public announcement of the decision via AMF news release

Suggested considerations

• Review the firm’s regulatory status (CIF versus investment services provider) and ensure that any placement or capital‑raising activities are within authorised limits; discontinue or re‑authorise any non‑guaranteed placement services currently carried out under CIF status.
• Conduct a comprehensive mapping of all services and activities (advisory, marketing, introductions, distribution) to confirm that none constitute regulated investment services (e.g., non‑guaranteed placement) without the requisite AMF/ACPR authorisation.
• Inventory all remuneration flows from issuers and third parties, including commissions, retrocessions and fees, and assess whether they are compatible with any independence claims and MiFID II inducements rules; remove or re‑label “independent” branding where issuer remuneration is received.
• Update client‑facing documentation (engagement letters, brochures, websites, emails) to provide clear, accurate and non‑misleading information on adviser independence, remuneration model, and any relationships with issuers or introducers.
• Implement or enhance procedures to ensure a written suitability statement is produced and delivered to clients for each piece of investment advice, documenting client profile, recommended products and rationale; integrate this into advisory workflows and record‑keeping.

What changed

• - Financial investment advisors must not conduct non‑guaranteed placement services (service de placement non garanti) such as actively seeking subscribers on behalf of issuers, unless they hold the...
• Firms that present themselves as independent advisors must not receive remuneration (direct or indirect) from product issuers whose instruments they recommend, unless permitted under MiFID II/French...
• When claiming independence, firms must provide accurate, clear and non‑misleading information on the nature of their independence, remuneration model, and any relationships with issuers or...
• Financial investment advisors must issue a written suitability statement formalising the investment advice provided, setting out the client’s profile, the recommended products, and the reasons why...
• Pre‑contractual documentation must include full information on costs, fees and remuneration, covering both the advised investment and any business introducer partners; omission of these disclosures...

Key dates

20 July 2026

- The AMF Enforcement Committee adopted the sanction decision against Uzès Gestion and two directors

23 July 2026

- The AMF published the enforcement committee news release summarising the decision

Suggested considerations

• Review the firm’s authorisation file, governance map, and executive-officer appointments to confirm that actual decision-making powers match the AMF-approved organisational structure.
• Update conflicts-of-interest procedures to capture conflicts arising from parent-company relationships, cross-directorships, and shared finance leadership roles.
• Test whether staffing levels and succession arrangements ensure continuity of human resources for control functions and key operational roles.
• Reassess remuneration arrangements for financial managers to verify consistency with the firm’s programme of activity, internal procedures, and regulatory requirements.
• Verify that all distributor retrocessions are fully disclosed to investors and that any claim of enhanced service is documented with evidence.

What changed

• - The AMF’s decision reinforces that asset managers must maintain continuous compliance with their authorisation conditions, but isolated overreach by a person not listed as an executive officer was...
• Firms must have procedures that identify and manage conflicts of interest, including conflicts arising from links with a parent company and from the overlapping functions of directors and financial...
• Asset managers must ensure continuity of human resources and align remuneration practices for financial managers with the applicable regulations, the approved programme of activity, and internal...
• Firms must disclose to investors management-fee retrocessions paid to distributors and must be able to justify any claimed enhancement of the service provided.
• Information provided to investors and prospects must be clear, accurate, and not misleading, including in marketing materials.

Key dates

2007

– Original Shareholder Rights Directive (SRD I) adopted, establishing a basic EU framework for shareholder rights in listed companies

2017

– Revised Shareholder Rights Directive (SRD II) adopted, introducing measures to promote long‑term engagement, improve governance transparency and regulate exercise of shareholder rights, particularly at general meetings

20 July 2026

– AMF publishes its response to the European Commission’s consultation on the SRD review, setting out its expectations and proposals on harmonisation, meeting formats and shareholder engagement

Suggested considerations

• Monitor the European Commission’s SRD review process closely, including the forthcoming legislative proposal and any related impact assessments, as these will determine concrete new obligations on meeting formats, shareholder identification and intermediaries’ duties.
• Map current practices for general meetings (physical, hybrid, virtual‑only) against the AMF’s positions and SRD II requirements, and assess the extent to which existing procedures depend on national options or flexibilities that may be removed in a revised SRD.
• For intermediaries and custodians, assess existing cross‑border voting, information transmission and shareholder identification processes to identify areas of fragmentation or reliance on local practices that may be affected by EU‑level harmonisation.
• Engage with industry associations and local regulators to provide practical feedback on operational challenges (e.g. complex custody chains, vote confirmation, cut‑off times) so that future SRD revisions reflect realistic implementation constraints.
• Update internal regulatory change logs and risk assessments to flag the SRD review as an emerging structural change to shareholder‑rights processes, with potential impacts on IT systems, contracts with intermediaries, and investor communications.

What changed

• * The AMF advocates removal of many existing “Member State options” in SRD in order to achieve greater harmonisation of shareholder rights and issuer–shareholder interactions across the EU, reducing...
• The AMF reiterates that long‑term shareholder engagement should remain a core objective of the revised SRD and that the framework should explicitly facilitate ongoing dialogue between issuers and...
• The AMF supports the development of hybrid general meetings with real‑time remote voting as a structural feature of EU listed company governance, in line with the digitalisation of the economy and...
• The AMF considers “closed‑door” general meetings (with no in‑person or remote shareholder participation) to be incompatible with SRD objectives and proposes that such formats be prohibited in the...
• The AMF proposes that “virtual‑only” general meetings should remain possible but be subject to tighter regulation at EU level, including a requirement to obtain shareholders’ approval on a regular...

Key dates

01 January 2022

- Start of the period covered by the AMF’s AML/CFT and AEI inspections synthesis (inspections leading to follow‑up actions)

June 2024

- Creation of the European Anti‑Money Laundering and Countering the Financing of Terrorism Authority (AMLA), with a mandate over financial‑sector AML/CFT supervision and rulemaking

31 December 2025

- End of the review period for inspections and enforcement outcomes included in the synthesis

January 2026

- Transfer at EU level of AML/CFT mandates and functions to AMLA and start of its 2026‑2028 work programme, including completion of the Single Rulebook and supervisory convergence

09 February 2026

- AMLA launches public consultations on draft regulatory technical standards for AML/CFT supervision and data (RTS/ITS), foreshadowing future harmonised requirements

Suggested considerations

• Review and comprehensively update AML/CFT written policies and procedures to ensure they are complete, precise and clearly adapted to the firm’s specific activities, products, distribution channels and client profiles.
• Redesign AML/CFT risk mapping to be firm‑specific, cover all relevant money laundering and terrorist financing risks, and explicitly link identified risks to the intensity of customer due diligence and transaction monitoring measures applied.
• Implement a formalised framework for the oversight of delegates, distributors, service providers and other third parties performing KYC or onboarding tasks, including documented due diligence, contractual obligations, and periodic testing of their AML/CFT controls.
• Conduct a gap analysis of client and beneficial owner data collection, storage and updating processes to ensure full traceability of KYC information, including clear documentation of PEP identification and periodic review.
• Enhance due diligence procedures for investment and divestment operations involving fund assets, including documented risk assessments and escalation paths for unusual or higher‑risk transactions.

What changed

• - The AMF has formalised and publicly communicated its enforcement findings and expectations on AML/CFT and AEI, turning past inspection outcomes into forward‑looking supervisory benchmarks for 2026...
• AML/CFT frameworks must move from generic and incomplete documentation to precise, activity‑specific procedures that clearly reflect the firm’s business model, products, distribution channels and...
• AML/CFT risk mapping must be personalised, complete, and demonstrably linked to the level and type of customer due diligence and ongoing monitoring applied; purely theoretical or non‑operational risk...
• Firms must implement robust oversight and documented supervision of delegates, distributors, service providers and other third parties involved in KYC or onboarding, rather than relying on unverified...
• Client, beneficial owner and source‑of‑funds information must be systematically collected, stored, updated and traceable, including clear identification and ongoing review of politically exposed...

Key dates

July 2021

- Period during which Mr Ytane Mamou purchased shares in the listed company on his own account, for his wife, and for his father, and when Mr Houri acquired shares following his cousin’s recommendation, prior to takeover-related announcements

20 May 2026

- AMF Enforcement Committee decision SAN‑2026‑04 is adopted, finding insider dealing by Mr Mamou and Mr Houri and imposing fines of €30,000 and €20,000 respectively

22 May 2026

- AMF publishes the news release summarising the Enforcement Committee decision and sanctions; appeal against the decision remains possible from this date in accordance with French procedural rules

Suggested considerations

• Review and update MAR market abuse policies to explicitly cover the prohibition on recommending or inducing others to trade on the basis of inside information, including for non-staff related persons.
• Enhance insider dealing surveillance scenarios to capture atypical trading patterns before takeover or M&A announcements, including trading by retail clients and accounts linked to employees’ family members where identifiable.
• Tighten procedures for the management of inside information during corporate transactions (takeovers, mergers, acquisitions), including clear designation of insiders, controlled information flows, and logging of who is aware of pending deals.
• Strengthen controls around potential transmission channels for inside information, including guidance and monitoring for staff who may informally share information with relatives or friends, and explicitly prohibit such behaviour in codes of conduct.
• Provide targeted MAR training to staff, senior management, and high‑risk functions (M&A, corporate finance, strategy, legal, finance) that uses this case as an example of how the AMF infers insider dealing and the consequences for both insiders and relatives.

What changed

• - The decision reiterates and operationalises the definition of “inside information” under the EU Market Abuse Regulation (MAR, Regulation (EU) No 596/2014), confirming that information relating to a...
• The Enforcement Committee shows that it will infer possession and use of inside information from a combination of factors (plausible transmission channels, atypical trading patterns, timing around...
• The decision confirms that the use of inside information through trading on own account and on the account of closely related persons (spouse, parent) will be treated as separate instances of misuse...
• The Committee explicitly treats recommendations to invest made on the basis of inside information as a distinct form of insider dealing, exposing the recommender to sanctions even if they do not...
• The ruling reinforces that relatives and close associates (here, cousins) who act on such recommendations can be sanctioned for insider dealing, even when they are not employees or insiders of the...

Key dates

1 January 2020

28 June 2023; Period of breaches investigated

1 April 2026

Date of AMF Enforcement Committee decision imposing fines and 5-year ban

Suggested considerations

• Immediate review: Audit marketing materials, website, and client communications for accurate authorization claims; cease any unapproved representations.
• Enhance procedures: Update conflict of interest policies to fully identify/mitigate risks from promoter ties; implement robust product governance collecting issuer details (e.g., asset managers, depositaries, marketing eligibility in France).
• Product due diligence: For all recommended securities/offers, verify French marketing authorization (e.g., AMF registration, prospectus, AIFMD passport); document high-risk features like loss exceeding contributions.
• AML/CFT strengthening: Ensure full compliance with due diligence and inspector cooperation; conduct gap analysis against AMF guidelines.
• Training and governance: Train directors/staff on personal liability; test procedures via internal audits.

What changed

• This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French financial advisor rules (e.g., derived from MiFID II and AIFMD implementations):
• Accurate representation: Advisors must not misrepresent authorization status or claim unapproved services like investment services provision.[Source URL:...
• Conflict of interest management: Procedures must identify and mitigate risks from commercial/ownership ties (e.g., to Vivat Multitalent group), beyond mere shareholding disclosures.
• Product governance: Collect and review product information to ensure investor protection; verify asset managers/depositaries for securities.
• Marketing limits: Prohibit advising prohibited securities (e.g., Multitalent AG bonds without French authorization) or high-risk offers like Guyane Agricole exceeding initial contributions.

Key dates

9 February 2026

- Consultations opened by AMLA on three draft RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]

9 March 2026

- Consultation closes on RTS for pecuniary sanctions/administrative measures

24 March 2026

- Online public hearing on CDD and business relationships RTS

8 May 2026

- Consultations close on CDD RTS and business relationships/linked transactions RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]

10 July 2026

- AMLA submits final draft RTS to European Commission for adoption

Suggested considerations

• Gap analysis and preparation: Assess current CDD/business identification/enforcement processes against drafts; identify changes for remote onboarding, PEPs, sectoral measures (e.g., asset manager Article 17 scenarios), and sanctions screening; set milestones for policy/system updates by July 2027.
• Engage hearings: Attend 24 March 2026 public hearing for CDD/business RTS.
• Monitor post-consultation: Track AMLA/EC adoption (expected Q1 2026 for some related RTS) and national implementations (e.g., CSSF data reporting).

What changed

• - CDD RTS: Builds on EBA's prior draft with AMLA refinements for legal clarity, proportionality, and risk adaptation; specifies information/sources for identity verification of natural persons/legal...
• Business Relationships/Occasional/Linked Transactions RTS: Defines criteria under AMLR Article 19(9) to harmonize identification, ensuring consistent EU-wide application beyond basic...
• Enforcement RTS (Pecuniary Sanctions/Administrative Measures): Under AMLD6 Article 53(10), standardizes supervisor assessment/categorization of breaches for proportionate, effective, dissuasive...

Key dates

August 2019

December 2023; - Period of breaches investigated

31 December 2025

- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors

08 January 2026

- Public news release date for the decision

Suggested considerations

• Conduct immediate gap analysis of investment processes for operationality, traceability, and precision in allocation rules.
• Enhance AML/CFT systems: Update risk mapping, procedures, and due diligence on fund assets/liabilities; ensure systematic application.
• Review conflict of interest frameworks for identification, prevention, and management; document controls rigorously.
• Senior managers: Demonstrate personal oversight via governance records to mitigate attribution of firm breaches.
• Audit marketing materials, fee retrocessions, and valuation procedures (e.g., for real estate or experts) against AMF standards.

What changed

• This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under the French Monetary and Financial Code for asset managers to maintain operational procedures.
• Imprecise investment allocation processes lacking traceability, rendering systems non-operational.
• Failure to fulfill conflict of interest identification, prevention, and management obligations.
• Deficient AML/CFT systems with inadequate due diligence on fund assets/liabilities. These align with prior AMF expectations for "honest, fair, and professional" conduct with skill, care, and...

Key dates

17 December 2025

- AMF Enforcement Committee decision date: €3.5M fine and warning imposed on CACEIS Bank

Suggested considerations

• Conduct gap analysis: Review depositary control frameworks against AMF expectations for verifying AMC investment monitoring, unlisted asset valuations, and prospectus compliance (e.g., 10% issuer limits, ratings).
• Enhance oversight processes: Implement robust, documented checks on AMC systems, including independent testing of ratios, legality of investments, and derivatives.
• Training and audits: Train staff on UCITS depositary duties; perform internal audits of ongoing fund oversight, prioritizing illiquid/unlisted exposures.
• Monitor appeals: Track any CACEIS appeal, as outcomes could set precedents; update policies if upheld.
• Reporting: Ensure timely escalation of suspected AMC breaches to AMF if identified.

What changed

• This is an enforcement action, not a regulatory change; it reinforces existing obligations under French UCITS rules (transposing UCITS Directive V) for depositaries. Key upheld objections include:
• Failure to perform sufficient checks on the asset management company's (AMC) systems for monitoring UCITS investment ratios and valuing unlisted securities.
• Inadequate verification of investment decision legality, such as compliance with prospectus limits on debt security ratings, derivative types, and the 10% single-issuer bond exposure cap. No new...

Key dates

10 December 2025 Deadline

- AMF Enforcement Committee decision date imposing fines; appeals possible (no specific deadline stated, but typically within 2 months to Conseil d’État)

Suggested considerations

• Review and enhance investment/divestment procedures: Ensure completeness, traceability of all compliance checks (e.g., alignment with fund policies), and formalized pre-allocation due diligence; test for operationality via internal audits.
• Document all processes rigorously: Maintain evidence of checks and due diligence to demonstrate skill, care, and diligence in line with authorization conditions.
• Conduct gap analysis against AMF expectations: Cross-reference with similar cases (e.g., operational procedures, AML/CFT); remediate deficiencies promptly.
• Senior manager training: Reinforce personal accountability for firm compliance; update governance frameworks.
• Appeal monitoring: If similarly positioned, prepare for potential appeals to Conseil d’État.

What changed

• This is an enforcement decision, not a new regulation, but it reinforces existing requirements under AMF professional obligations for asset managers (sociétés de gestion), including:
• Fully operational investment and divestment procedures that ensure traceability of compliance checks against fund policies and constraints.
• Formalized due diligence prior to allocating investment projects to funds. No explicit changes to rules; instead, it clarifies enforcement expectations for procedure completeness and documentation,...

Key dates

1 January 2019 to 30 June 2024

- Relevant period of breaches for Carat GP

5 November 2025

- AMF Enforcement Committee decision issued, imposing fines and bans

6 November 2025

- French version of press release published

Suggested considerations

• Audit documentation: Ensure all investment advice is fully documented and compliant; implement traceability for proposals.
• Strengthen governance: Deploy systems to detect/prevent conflicts, especially manager-led undocumented investments; enforce annual director training.
• Enhance AML/CFT: Prohibit personal receipt of client funds; conduct KYC and transaction monitoring.
• Improve inspection readiness: Train staff for diligent, honest cooperation with AMF; maintain secure archives.
• Senior manager reviews: Assess personal compliance liabilities; update senior managers regime policies.

What changed

• This is an enforcement action, not a regulatory change, but it clarifies and strengthens application of existing AMF rules for conseillers en investissements financiers (CIFs) under French...
• Mandatory compliant documentation (e.g., investment proposals).
• Obligation to act honestly, fairly, and professionally in clients' best interests, including systems to prevent managers exploiting positions for undocumented investments.
• AML/CFT compliance, including prohibitions on directors receiving client funds in personal accounts.
• Annual training for directors and diligent cooperation with AMF inspections.

Key dates

16 October 2025

- ESMA publishes second consolidated Annual Sanctions Report for 2024 data

What changed

This is not a new regulation but a retrospective report documenting 2024 enforcement trends; no direct regulatory changes are introduced. Key observations include a significant rise in total fine amounts to over €100 million (from €71 million in 2023) despite stable sanction volumes (975 vs. 976), with MAR (377 sanctions, €45.5 million) and MiFID II/MiFIR (294 sanctions, €44.5 million) dominating. Notable shifts: increased settlement usage (94 agreements for €21.9 million, 22% of total), with AMF at 18% of its penalties via settlements (vs.

Key dates

July 31, 2025

- EFRAG publishes draft simplified ESRS for public consultation

September 29, 2025

- Consultation closes

End of November 2025

- EFRAG submits technical advice to European Commission

June 2026

- Sector-specific ESRS adoption planned

2026 financial year (reports in 2027)

- Voluntary application of simplified standards, if legislative timeline allows

Suggested considerations

• Monitor EFRAG's post-consultation technical advice (end-November 2025) and EC adoption process; prepare for voluntary uptake in 2026 reporting cycles.
• Listed companies: Refine materiality processes to specify IRO types and use gross impacts; retain "net zero" definitions in climate plans; prioritize quantitative climate financial effects.
• Conduct or update materiality assessments per EFRAG guidance (e.g., value chain, thresholds); leverage "undue costs" relief judiciously with time limits.
• Prepare xHTML digital tagging for sustainability statements in management reports.
• French firms: Align 2026 statements with AMF supervisory expectations, noting non-adoption of ESMA's GLESI guidelines pending full CSRD transposition.

What changed

• AMF endorses EFRAG's simplifications but proposes targeted adjustments:
• Materiality assessment: Support for proportionate double materiality (impacts, risks, opportunities or IRO) but requires minimum specification of impact type (positive/negative, risk, opportunity);...
• Climate reporting: Regrets removal of "net zero" definition (90-95% gross GHG reduction trajectory), essential for 2024 comparability.
• Anticipated financial effects: Strongly backs Option 1 (quantitative info required, with exceptions) for climate matters to align with ISSB and investor needs; flexible for other topics.
• Reporting reliefs: Supports "undue costs/efforts" exemptions (e.g., metrics except Scope 3 GHG) with time-bound limits to match ISSB. EFRAG's draft cuts mandatory datapoints by 57-61%, eliminates...

Key dates

15 September 2025

- AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners, Maurice Tchenio, and Patrick de Giovanni

16 September 2025

- French version of press release published

Post

15 September 2025 (exact date unspecified); - Appeal lodged by Altaroc Partners, Tchenio, and de Giovanni before the Conseil d’État against decision SAN-2025-09

Suggested considerations

• Audit procedures immediately: Review and document operational status of investment/divestment processes, ensuring traceability of lender checks, fund policy compliance, and AML/CFT due diligence on assets/liabilities.
• Enhance AML/CFT systems: Formalize risk mapping, procedures, and systematic investor/transaction due diligence; test for operational effectiveness.
• Validate marketing and fees: Audit fund materials for accuracy; gather evidence that fee retrocessions to distributors improve client services (e.g., via service level agreements or performance metrics).
• Senior manager training: Conduct gap analysis on personal accountability; update governance frameworks to mitigate attribution of firm breaches.
• Mock AMF inspections: Simulate Enforcement Committee reviews, focusing on procedure formalization, independent valuers (if applicable), and conflict systems.

What changed

• This is an enforcement action rather than new legislation, but it reinforces and clarifies existing professional obligations under AMF regulations for asset managers (sociétés de gestion),...
• Operational investment/divestment procedures: Must be fully implemented, with traceability of checks on lender authorizations and compliance with fund policies.
• AML/CFT due diligence: Systematic verification required on fund assets and liabilities; non-operational procedures or risk mapping constitute breaches.
• Marketing and fee retrocessions: Materials must be accurate; firms must prove retrocessions enhance client service quality.
• Senior manager accountability: Breaches attributable to responsible managers, emphasizing personal liability for oversight failures. No explicit regulatory changes, but the decision aligns with AMF's...

Key dates

9 September 2025

- AMF Enforcement Committee decision imposing €400,000 fine on Eternam for breaches

Suggested considerations

• Conduct immediate gap analysis of investment procedures, marketing materials, conflict of interest policies, valuation processes, external expert oversight, and AML/CFT systems to ensure they are operational, documented, and traceable.
• Verify investor disclosures on fee retrocessions are comprehensive and understandable; update marketing materials for AIFs and club deals accordingly.
• Formalize independent valuer roles and implement monitoring for external experts per activity programs.
• Enhance AML/CFT due diligence on fund assets/liabilities, including risk mapping and procedure testing.
• Senior managers: Document personal oversight of compliance; train on attribution of breaches.

What changed

• This is an enforcement decision, not a regulatory change introducing new rules; it enforces existing professional obligations under AMF jurisdiction for asset managers.
• Providing comprehensive, accurate, and understandable information to investors on fee retrocessions to distributors in AIF marketing.
• Implementing effective systems for preventing and managing conflicts of interest, particularly in joint investments like club deals classified as Other AIFs.
• Maintaining operational procedures for valuing real estate assets, including formalizing independent valuer work.
• Adhering to programs of activity for selecting, evaluating, overseeing, and periodically assessing external experts.

Key dates

16 July 2025

- AMF Enforcement Committee decision issued imposing €300,000 fine

22 July 2025

- Official publication of enforcement decision

No specified deadline Deadline

- Appeal period available (no specific timeframe stated in the decision)

Suggested considerations

• *Audit client notification procedures for derivatives trading changes, particularly regarding position closure procedures and margin calculation methodologies, ensuring clients receive advance notice of material changes
• *Implement incident reporting protocols for securities transactions that could affect order execution, with documented evidence of timely client notification
• *Review PEA transfer procedures to ensure compliance with regulatory timeframes and proper documentation of information provided to clients regarding Brexit-related consequences
• *Strengthen information governance to ensure all material operational changes are communicated to clients within required timeframes and with appropriate detail
• *Conduct compliance training for front-office and operations staff on professional obligations regarding client communication and information disclosure

What changed

• The enforcement decision does not introduce new regulatory requirements but rather clarifies existing obligations under current French financial regulations.
• Client notification requirements for significant procedural changes affecting derivatives trading and margin calculations
• Incident disclosure obligations for securities transactions that could materially affect order execution
• Timely information provision regarding regulatory consequences of the UK's withdrawal from the European Union as they affect PEA accounts
• Operational procedures for managing equity savings plan transfers with proper documentation and client communication

Key dates

March 2023

- Pilot Regime became operational

April 9, 2025

- AMF and Consob formal proposals submitted

March 24, 2026 Deadline

- ESMA report deadline to European Commission on Pilot Regime functioning and recommendations

Q2 2026

- Expected European Commission report to Parliament and Council with recommendations on Pilot Regime extension, amendment, or permanent conversion

June 30, 2026

- End of MiCA transitional period; full crypto-asset regime implementation

Suggested considerations

• *For Market Infrastructure Operators:
• *Reassess Business Cases: Evaluate viability under revised €100 billion thresholds and expanded instrument eligibility
• *Prepare Applications: Organizations previously excluded by €6 billion threshold should prepare authorization applications under new proportionality framework
• *Monitor Commission Decisions: Track European Commission's response to ESMA report (expected Q2 2026) for final regulatory direction
• *Compliance Documentation: Prepare operational and technical documentation demonstrating alignment with revised requirements

What changed

• The proposed amendments address the Pilot Regime's limited uptake by introducing the following regulatory modifications: Scope Expansion
• Expand eligible financial instruments from current restrictions to all financial assets
• Remove categorical limitations that previously restricted participation Activity Thresholds
• Raise activity thresholds from €6 billion to €100 billion
• Introduce greater proportionality based on project scale, allowing smaller players simplified requirements Operational Flexibility

Key dates

March 6, 2025

EBA consultation launch; on draft RTS for AML/CFT standards (ongoing as of analysis)

January 1, 2026

EBA hands over AML/CFT mandates, tools (e.g., EuReCa database), and functions to AMLA; ; existing EBA guidelines remain until replaced

July 10, 2027 Deadline

New AMLD6/AMLR rules apply directly; , including CDD for new customers and start of phased compliance

2028

AMLA begins direct supervision; of selected high-risk entities

By July 2032 Deadline

Full CDD compliance; for existing customers (five-year transition from 2027)

Suggested considerations

• Participate in EBA consultation: Submit feedback on draft RTS via EBA channels, focusing on risk indicators, data frequency, and feasibility; AMF encourages French firms to act promptly.
• Conduct compliance gap analysis: Review current AML frameworks against proposed indicators (inherent risk, controls, residual risk); prioritize high-risk customers/products.
• Enhance systems: Invest in regtech for automated risk scoring, transaction monitoring, and data reporting to supervisors; update governance, policies, and CDD processes.
• Prepare for AMLA supervision: For cross-border firms, model group-wide risk profiles; develop remediation plans for breaches.
• Ongoing monitoring: Implement annual risk reviews and ad-hoc reassessments for business changes.

What changed

• The draft RTS propose harmonized methodologies for AML/CFT supervision, including:
• Risk Assessment of Obliged Entities (Article 40(2) AMLD6): A three-step process with indicators for inherent risk (customers, products/services, geography, distribution channels), control...
• Risk Assessment for Direct Supervision (Article 12(7) AMLAR): Two-stage selection for AMLA direct oversight of high-risk cross-border firms (operating in ≥6 Member States, meeting...
• CDD Updates: Risk-based approach for new customers from July 2027; five-year transition for existing customers, prioritizing high-risk.
• Pecuniary Sanctions RTS (Article 53(10) AMLD6): Structured classification of breaches, proportionate sanctions, and enforcement for serious/repeated/systematic infringements to ensure uniformity...

Key dates

October 10

16, 2019; - Five trading sessions during which manipulative "marking the close" sales occurred on Euronext Paris

2019 (exact dates unspecified)

- Instances of failing to report exceeding/falling below 5% ownership thresholds in Innate Pharma

13 December 2024

- AMF Enforcement Committee decision date imposing fines

16 December 2024

- French version of press release published

Suggested considerations

• Implement pre-trade surveillance for "marking the close" patterns, especially around issuer events like IPOs where Euronext closes influence external pricing.
• Enhance 5% threshold monitoring with automated alerts and timely filings (4 trading days post-threshold).
• Conduct senior manager training on personal liability under MAR for manipulative orders benefiting the firm (e.g., lower ADS subscription as largest subscriber).
• Review cross-border trading policies for French-listed assets, including jurisdiction assessments for non-EU funds.
• Perform gap analysis on order timing controls to flag end-of-day volume spikes.

What changed

This is an enforcement decision, not a regulatory change; it reinforces existing MAR prohibitions on price manipulation (Article 12), specifically "fixing the price at an abnormal or artificial level" through timed sales at market close to influence linked ADS pricing on Nasdaq. It also highlights ongoing scrutiny of reporting obligations under Article L. 233-7 of the French Commercial Code for crossing 5% thresholds in listed companies.

Suggested considerations

• Conduct gap analysis of operational procedures for investments/divestments, ensuring lender authorization checks (reference AMF Position-Recommendation DOC-2020-05 on portfolio management).
• Review AML/CTF due diligence frameworks for fund assets/liabilities, aligning with AMF Regulation 2016-01.
• Audit retrocession practices to distributors, documenting service quality enhancements (per AMF doctrine on inducements).
• Update marketing materials and advisory processes for compliance with honesty/fairness standards.
• Enhance senior manager attestations and training on personal liability under CMF L.621-15-1.

What changed

• This is an enforcement decision, not a regulatory change introducing new rules. It reinforces existing AMF requirements under professional obligations, including:
• Implementation of operational procedures for investment/divestment processes, such as verifying lender authorizations.
• Systematic anti-money laundering (AML) and counter-terrorism financing (CTF) due diligence on fund assets and liabilities.
• Justification of retrocessions (rebates) to distributors, proving enhanced client service quality.
• Honest, fair, and diligent business conduct with requisite skill and care, extending to marketing materials and advisory services. No new requirements; emphasis on enforcement of MiFID II-aligned...