AMF France v. A, B, C, D, F, J and K (insider trading, 2008)

Judgment entered

✓ Checked against the primary document on October 5, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, in a single reading of the French decision; an independent second reading of 60 of the AMF records agreed on every field for 54 and on the core fields for 59. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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On 23 December 2008 the Commission des sanctions found that seven individuals had traded in the shares and call warrants of a listed company ahead of the 7 July 2003 announcement of a EUR 41 a share takeover offer, using information that spread from an investment-bank employee to his brother and on to other investors. It imposed penalties of EUR 3.95 million in all and cleared eight others.

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

€4m

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 second section of the Commission des sanctions decided this matter on 23 December 2008, after a market inspection ordered in September 2003, an investigation report of 12 February 2007 and notifications of grievances sent on 15 June 2007 to 15 individuals and two companies. Proceedings against the two companies were severed because the notifications could not be delivered. The decision anonymises everyone; X is the bidder and Y the target listed on the Premier Marche and, through ADRs, in New York.

On 7 July 2003 X announced a takeover offer for Y at EUR 41 a share, a premium of about 20.5 per cent. The AMF said unusual purchases of Y shares and of a call warrant on Y were visible in the preceding month. It alleged that the imminent offer was inside information from early June 2003 and that A, an M&A associate at an investment bank, had told his brother B, and that others had bought on the information or passed it on.

The Commission held that the information was inside information from 3 June 2003, when X's management reported on a possible acquisition to its board. It found that B's purchases could be explained only by information from A, with whom he had close ties, and that B's company made a gain of EUR 1,253,000; that C bought shares and warrants for more than EUR 4 million through offshore companies, for a gain of about EUR 1.5 million; that D bought for clients on C's recommendation, with gains of EUR 860,000; that F, who took investment decisions for a family connected to a consultant on the deal, used the information; and that J and K bought after tips from an intermediary, J making EUR 302,534 and passing on 55 per cent of the gain, K EUR 254,200. It cleared E, G, H, I, L, M, N and O because the evidence did not show that only inside information explained their trades.

It imposed EUR 100,000 on A, EUR 1,500,000 on B, EUR 1,300,000 on C, EUR 100,000 on D, EUR 200,000 on F, EUR 400,000 on J and EUR 350,000 on K (EUR 3,950,000 in all) and ordered publication in a form preserving the anonymity of those cleared.

This record does not show how the parallel criminal procedure ended, the identity of the respondents, or whether the decision was appealed. The two severed companies are not covered.

This library tags the matter as insider trading. 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.

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

Timeline

1. 2008-12-23 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.