Market Manipulation. Search

AMF France v. Kraay Trading I BV (spoofing, 2011)

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.

Report an error in this record (amf-fr-san-2011-09-spoofing-2011) by email

In May 2011 the AMF's Commission des sanctions fined a Dutch one-person trading company 10,000 euros for market manipulation in Nexans shares on 6 March 2008, by bursts of large orders on one side that were cancelled within minutes and replaced by opposite orders. It cleared the company of manipulation charges on four other shares and the rest of 2007 to 2008.

The record

Structured fields for this action, as recorded in our case library.
Agency AMF (France)
Release number SAN-2011-09
Date filed 2011-05-12
Date resolved 2011-05-12
Court Commission des sanctions (AMF, France)
Status judgment
Asset class equities
Instruments Nexans shares
Venue Euronext Paris
Criminal parallel No
Defendants Kraay Trading I BV (entity)
Techniques Spoofing

What was ordered

Civil penalty
—
Disgorgement
—
Prejudgment interest
—
Total relief
—
Alleged gain
—
Penalty as published
€10k

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 Commission des sanctions of the Autorité des marchés financiers (AMF, France) decided the case on 12 May 2011. The charge was notified in November 2009 to Kraay Trading I BV, a single-person Dutch trading company, under the manipulation rules of the AMF's general regulation.

The AMF's markets directorate had seen, from December 2007, bursts of large, similar orders on 25 French shares sent from two local order servers used by a clearing firm's customers. The orders were entered on one side, apparently to pull the price that way, then withdrawn a few minutes later and replaced with opposite orders. The notification alleged manipulation of Nexans, Nexity, Zodiac, Ubisoft and Hermès shares between January 2007 and June 2008.

The Commission analysed only one episode in detail: Nexans on 6 March 2008 from 13:00:45, when 101 orders were placed and cancelled within about 14 minutes. It found that the company was the author of both the executed and cancelled orders, that the pattern gave false or misleading signals on supply, demand and price, and that it was not market making or ordinary high-frequency trading. It found a gain of only 487.91 euros on that episode. For the other shares and the eighteen-month period it held that high cancellation rates and the company's share of executed orders were presumptions that had not been reinforced by further analysis, so it put the company out of the case on those charges.

It imposed a financial penalty of 10,000 euros.

This record does not show whether the company or its traders were pursued elsewhere, whether the decision was appealed, or any other trader's conduct. The sanction covers only the 6 March 2008 Nexans episode, not the broader pattern initially alleged.

This library tags the matter as spoofing. 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.

Timeline

  1. 2011-05-12 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.

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

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

Action Agency Filed Technique Penalty Status
SEC v. Frank M. Cerisano Jr. (spoofing, 2026) SEC 2026-08-10 Spoofing $335k settled
SEC v. Mingran Wang (spoofing, 2026) SEC 2026-06-25 Spoofing — settled
CFTC v. Sidney Lebental (spoofing, 2026) CFTC 2026-05-06 Spoofing $200k judgment
CFTC v. Gregg Smith and Michael Nowak (spoofing, 2026) CFTC 2026-01-16 Spoofing $350k judgment
SEBI v. Manish Mishra and others (YouTube promotion of GG Engineering, 2025) SEBI (India) 2025-12-19 Social Media Ramps , Spoofing — judgment
SEC v. Artur Khachatryan (spoofing, 2025) SEC 2025-12-16 Spoofing $112k settled

Record added October 5, 2026. submit a correction.