AMF France v. SAFE S.p.a. (penny-stock manipulation, 2009)

Judgment entered

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On 9 April 2009 the Commission des sanctions found that an Italian proprietary trading firm had used a dominant position in the order books of two sub-EUR 1 shares, Alstom and Eurotunnel, to create unfair trading conditions for others, and fined it EUR 300,000. Four senior traders were cleared.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

—

Alleged gain

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Penalty as published

€300k

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars. This regulator states penalties in EUR. The figure is recorded as published and is not converted, so it does not appear in the USD totals or medians used elsewhere on this site.

What is alleged to have happened

The first section of the Commission des sanctions decided this matter on 9 April 2009, after an investigation opened in August 2005 into trading in Alstom shares (then a penny stock) and extended in November 2005 to other securities, and notifications of grievances sent on 13 November 2007. The respondents were SAFE S.p.a., an Italian company that trades only for its own account on equity and derivative markets through the broker Finecobank, and four senior traders, A, B, C and D.

The AMF alleged price manipulation in the penny stocks Alstom, Eurotunnel and Euro Disney: that the orders of SAFE and its traders, acting together, gave SAFE a dominant position in the markets for these shares so that others faced unfair trading conditions.

The Commission found SAFE held a dominant position in Eurotunnel and Alstom, though not in Euro Disney. Across the periods examined, SAFE's 14,448 orders, for over 20 billion shares, were about 20 per cent of the order volume and made it the largest participant; its orders caused nearly half of all changes in the bid-offer spread; it placed many passive orders at several price levels before provoking a spread move; and it traded 28 per cent of total volume. On shares quoted below EUR 1, where one tick is a large proportion of the price, other investors had to give up or place aggressive orders at worse prices, and SAFE could act like a market maker earning the tick. It held the manipulation established against SAFE for Eurotunnel and Alstom between April 2005 and January 2006, and said it was the first application of the dominant-position provision.

It imposed a EUR 300,000 financial penalty on SAFE, because profits could not be calculated precisely, and cleared the four traders, who had only carried out the firm's strategy without personal contributions. The decision was published with the traders anonymised.

This record does not show SAFE's profits, or whether the decision was appealed.

This library tags the matter as price manipulation. The tagging is ours, not the regulator’s.

For the regulator’s own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the decision.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Price manipulation — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2009-04-09 Commission des sanctions decision

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• AMF decision page
• Decision (PDF, French)

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added October 5, 2026. submit a correction.