AMF France v. Company X, A, B and C (front-running of a client order, 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.

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In July 2011 the Commission des sanctions found that an investment firm's facilitation trader sold shares for the firm's own account before a client had accepted a quoted price, and fined the firm and three individuals EUR 355,000 in total. It rejected the insider-dealing and market-manipulation framing of that trading and sanctioned it as an abusive use of pending client-order information.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

—

Total relief

—

Alleged gain

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Penalty as published

€355k

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 of the Autorité des marchés financiers (AMF) heard the case in public on 30 June 2011 and decided it on 4 July 2011. The decision is anonymised: the firm appears as company X and the individuals as A, B and C.

The notifications of grievances, sent in April 2010 after an inspection prompted by a former employee's letter, alleged among other things that on 9 April 2008 the firm and its facilitation trader (C) had used inside information about a second 100,000-share Veolia sell order. The trader had sold 17,775 Veolia shares for the firm's own account before the client had agreed the price the firm had just quoted. Further grievances concerned the firm's market-abuse detection system and its compliance function, and were directed at the firm's managing director (A) and chairman (B).

The Commission held that the insider-dealing grievance was not made out, because it was not shown that a reasonable investor would have used the existence of that second order as a basis for an investment decision given the volume already traded that morning. It nonetheless found that selling for the firm's own account ahead of the client's acceptance was an abusive exploitation of pending client-order information, contrary to the firm's own rules and to the duty to act honestly, fairly and professionally. It also found that the firm's main market-abuse detection tool was deficient and that it had failed to report to the AMF trades its own compliance officer had flagged as possible insider dealing or manipulation.

The Commission fined the firm EUR 250,000 and each of A, B and C EUR 35,000, a total of EUR 355,000, and ordered publication of extracts of the decision. A and B were sanctioned for their responsibility over compliance, and C for the trading.

This record does not show whether the decision was appealed, nor any profit or loss from the trades. The insider-dealing grievance was rejected, so the matter is tagged by the conduct actually found, which is closest to front-running.

This library tags the matter as front running. 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.

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

Timeline

1. 2011-07-04 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.